1 unchanged sentence
You should also refer to the other information included in this report, including the Trust’s financial statements and the related notes.
+Added: ECONOMIC CONDITIONS
The value of the Shares relates directly to the value of the euro held by the Trust.
15 unchanged sentences
On October 17, 2019, the British government and the European Union announced that a withdrawal agreement had been negotiated, and such withdrawal agreement subsequently received Parliamentary approval.
−Removed: The United Kingdom withdrew from the European Union on January 31, 2020, and is in a transition period through December 31, 2020, during which time the United Kingdom is negotiating new trade agreements with the European Union, the United States, Australia and other trade partner nations.
+Added: The United Kingdom withdrew from the European Union on January 31, 2020, and was in a transition period through December 31, 2020, during which time the United Kingdom negotiated and entered into new trade agreements with the European Union and certain trade partner nations;
+Added: however, trade agreements with other trade partner nations, including the United States, Australia and others, have not yet been negotiated.
The consequences for the economies of the European Union members of the United Kingdom exiting the European Union are unknown and unpredictable, as is the future direction of the value of the euro and the Shares.
These uncertainties could increase volatility in the market prices of the euro and the Shares.
−Removed: Increased volatility could, in itself, decrease the value of the Share.
+Added: Increased volatility could, in itself, decrease the value of the Shares.
The USD/euro exchange rate, like foreign exchange rates in general, can be volatile and difficult to predict.
2 unchanged sentences
changing supply and demand for a particular currency;
−Removed: monetary policies of governments (including exchange control programs, restrictions on local exchanges or markets and limitations on foreign investment in a country or on investment by residents of a country in other
+Added: monetary policies of governments (including exchange control programs, restrictions on local exchanges or markets and limitations on foreign investment in a country or on investment by residents of a country in other countries);
changes in balances of payments and trade;
4 unchanged sentences
The resulting volatility in the USD/euro exchange rate could materially and adversely affect the performance of the Shares.
−Removed: Changes to United States tariff and trade policies may increase the volatility of foreign exchange rates.
−Removed: This volatility could materially and adversely affect the performance of the Shares.
−Removed: There have been ongoing discussions and commentary regarding potential significant changes to United States trade policies, treaties and tariffs.
−Removed: The current administration, along with Congress, has created significant uncertainty about the future relationship between the United States and other countries with respect to trade policies, treaties and tariffs.
−Removed: These developments, or the perception that any of them could occur, may have a material adverse effect on global economic conditions and the stability of global financial markets, and may increase the volatility of foreign exchange rates, including the USD/euro exchange rate.
−Removed: The resulting volatility could materially and adversely affect the performance of the Shares.
If interest earned by the Trust does not exceed the Trust’s expenses, the Trustee will withdraw euro from the Trust to pay these excess expenses, which will reduce the amount of euro represented by each Share on an ongoing basis and may result in adverse tax consequences for Shareholders.
2 unchanged sentences
accordingly, the Trustee has been required to withdraw euro from the Trust to pay these excess expenses.
−Removed: As long as the amount of interest earned does not exceed expenses, the amount of euro represented by each Share would gradually decline over time.
+Added: As long as the amount of interest earned does not exceed expenses, the amount of euro represented by each Share will gradually decline over time.
This is true even if additional Shares are issued in exchange for additional deposits of euro into the Trust, as the amount of euro required to create Shares will proportionately reflect the amount of euro represented by the Shares outstanding at the time of creation.
22 unchanged sentences
Consequently, if the Trust incurs expenses in USD, the Trust’s euro may be sold at a time when the euro price is low, resulting in a negative effect on the value of the Shares.
+Added: The Shares may trade at a price which is at, above, or below the NAV per Share.
+Added: The NAV per Share fluctuates with changes in the market value of the Trust’s assets.
+Added: The market price of Shares can be expected to fluctuate in accordance with changes in the NAV per Share, but also in response to market supply and demand.
+Added: As a result, the Shares might trade at prices at, above or below the NAV per Share.
+Added: Disruptions in the ability to create and redeem Baskets may adversely impact the price of the Shares.
+Added: It is generally expected that the public trading price per Share will track the NAV per Share closely over time.
+Added: The relationship between the public trading price per Share and the NAV per Share depends, to a considerable degree, on the ability of Authorized
+Added: Participants or their clients or customers to purchase and redeem Baskets in the ordinary course.
+Added: If the Trust were to issue all Shares that have been registered or if the Trust does not have an effective registration statement with the SEC with sufficient Shares available, each of which may happen from time to time, the Trust would not be able to create new Baskets until it registered additional Shares and those additional Shares became available for sale.
+Added: In addition, the Trust may, in its discretion, suspend the creation of Baskets for any reason and at any time.
+Added: If the process for creating or redeeming Shares is impaired for any reason, Authorized Participants and their clients or customers may not be able to purchase and redeem Baskets.
+Added: The inability to purchase and redeem Baskets could result in the Shares trading at a premium or discount to the NAV of the Trust.
+Added: Such a premium or discount could be significant, depending upon the nature or duration of the impairment.
+Added: Substantial sales of euro by the official sector could adversely affect an investment in the Shares.
+Added: The official sector consists of central banks, other governmental agencies and multi-lateral institutions that buy, sell and hold euro as part of their reserve assets.
+Added: The official sector holds a significant amount of euro that can be mobilized in the open market.
+Added: In the event that future economic, political or social conditions or pressures require members of the official sector to sell their euro simultaneously or in an uncoordinated manner, the demand for euro might not be sufficient to accommodate the sudden increase in the supply of euro to the market.
+Added: Consequently, the price of the euro could decline, which would adversely affect an investment in the Shares.
+Added: REGULATORY MATTERS
+Added: Changes to United States tariff and trade policies may increase the volatility of foreign exchange rates.
+Added: This volatility could materially and adversely affect the performance of the Shares.
+Added: There have been ongoing discussions and commentary regarding potential significant changes to United States trade policies, treaties and tariffs.
+Added: The current administration, along with Congress, has created significant uncertainty about the future relationship between the United States and other countries with respect to trade policies, treaties and tariffs.
+Added: These developments, or the perception that any of them could occur, may have a material adverse effect on global economic conditions and the stability of global financial markets, and may increase the volatility of foreign exchange rates, including the USD/euro exchange rate.
+Added: The resulting volatility could materially and adversely affect the performance of the Shares.
The Deposit Accounts are not entitled to payment at any office of JPMorgan Chase Bank, N.A.
2 unchanged sentences
Therefore, payments out of the Deposit Accounts will be payable only at the London branch of JPMorgan Chase Bank, N.A., located in England.
−Removed: The Trustee will not be entitled to demand payment of these accounts at any office of JPMorgan Chase
+Added: The Trustee will not be entitled to demand payment of these accounts at any office of JPMorgan Chase Bank, N.A.
that is located in the United States.
3 unchanged sentences
Neither the Shares nor the Deposit Accounts and the euro deposited in them are deposits insured against loss by the FDIC, any other federal agency of the United States or the Financial Services Compensation Scheme of England.
+Added: Shareholders do not have the protections associated with ownership of shares in an investment company registered under the Investment Company Act of 1940.
+Added: The Investment Company Act is designed to protect investors by preventing:
+Added: insiders from managing investment companies to their benefit and to the detriment of public investors;
+Added: the issuance of securities having inequitable or discriminatory provisions;
+Added: the management of investment companies by irresponsible persons;
+Added: the use of unsound or misleading methods of computing earnings and asset value;
+Added: changes in the character of investment companies without the consent of investors;
+Added: and investment companies from engaging in excessive leveraging.
+Added: To accomplish these ends, the Investment Company Act requires the safekeeping and proper valuation of fund assets, restricts greatly transactions with affiliates, limits leveraging, and imposes governance requirements as a check on fund management.
+Added: The Trust is not registered as an investment company under the Investment Company Act and is not required to register under that act.
+Added: Consequently, Shareholders do not have the regulatory protections afforded to investors in registered investment companies.
+Added: Shareholders do not have the rights enjoyed by investors in certain other financial instruments.
+Added: As interests in a grantor trust, the Shares have none of the statutory rights normally associated with the ownership of shares of a business corporation, including, for example, the right to bring “oppression” or “derivative” actions.
+Added: Apart from the rights afforded to them by federal and state securities laws, Shareholders have only those rights relative to the Trust, the Trust property and the Shares
+Added: that are set forth in the Depositary Trust Agreement.
+Added: In this connection, the Shareholders have limited voting and distribution rights.
+Added: They do not have the right to elect directors.
+Added: See “Business – The Shares – Limited Rights” for a description of the limited rights of the Shareholders.
+Added: Shareholders that are not Authorized Participants may only purchase or sell their Shares in secondary trading markets.
+Added: Only Authorized Participants may create or redeem Baskets through the Trust.
+Added: All other investors that desire to purchase or sell Shares must do so through NYSE Arca or in other markets, if any, in which the Shares are traded.
+Added: INSOLVENCY OR TERMINATION OF THE DEPOSITORY OR TRUST
If the Depository becomes insolvent, its assets may not be adequate to satisfy a claim by the Trust or any Authorized Participant.
17 unchanged sentences
in the U.S., greatly increasing the risk that the Trust and the Trust’s beneficiaries would suffer a loss.
−Removed: Shareholders do not have the protections associated with ownership of shares in an investment company registered under the Investment Company Act of 1940.
−Removed: The Investment Company Act is designed to protect investors by preventing:
−Removed: insiders from managing investment companies to their benefit and to the detriment of public investors;
−Removed: the issuance of securities having inequitable or discriminatory provisions;
−Removed: the management of investment companies by irresponsible persons;
−Removed: the use of unsound or misleading methods of computing earnings and asset value;
−Removed: changes in the character of investment companies without the consent of investors;
−Removed: and investment companies from engaging in excessive leveraging.
−Removed: To accomplish these ends, the Investment Company Act requires the safekeeping and proper valuation of fund assets, restricts greatly transactions with affiliates, limits leveraging, and imposes governance requirements as a check on fund management.
−Removed: The Trust is not registered as an investment company under the Investment Company Act and is not required to register under that act.
−Removed: Consequently, Shareholders do not have the regulatory protections afforded to investors in registered investment companies.
−Removed: Shareholders do not have the rights enjoyed by investors in certain other financial instruments.
−Removed: As interests in a grantor trust, the Shares have none of the statutory rights normally associated with the ownership of shares of a business corporation, including, for example, the right to bring “oppression” or “derivative” actions.
−Removed: Apart from the rights afforded to them by federal and state securities laws, Shareholders have only those rights relative to the Trust, the Trust property and the Shares that are set forth in the Depositary Trust Agreement.
−Removed: In this connection, the Shareholders have limited voting and distribution rights.
−Removed: They do not have the right to elect directors.
−Removed: See “Business – The Shares – Limited Rights” for a description of the limited rights of the Shareholders.
−Removed: The Shares may trade at a price which is at, above, or below the NAV per Share.
−Removed: The NAV per Share fluctuates with changes in the market value of the Trust’s assets.
−Removed: The market price of Shares can be expected to fluctuate in accordance with changes in the NAV per Share, but also in response to market supply and demand.
−Removed: As a result, the Shares might trade at prices at, above or below the NAV per Share.
−Removed: Disruptions in the ability to create and redeem Baskets may adversely impact the price of the Shares.
−Removed: It is generally expected that the public trading price per Share will track the NAV per Share closely over time.
−Removed: The relationship between the public trading price per Share and the NAV per Share depends, to a considerable degree, on the ability of Authorized Participants or their clients or customers to purchase and redeem Baskets in the ordinary course.
−Removed: If the Trust were to issue all Shares that have been registered or if the Trust does not have an effective registration statement with the SEC with sufficient Shares available, each of which may happen from time to time, the Trust would not be able to create new Baskets until it registered additional Shares and those additional Shares became available for sale.
−Removed: In addition, the Trust may, in its discretion, suspend the creation of Baskets for any reason and at any time.
−Removed: If the process for creating or redeeming Shares is impaired for any reason, Authorized Participants and their clients or customers may not be able to purchase and redeem Baskets.
−Removed: The inability to purchase and redeem Baskets could result in the Shares trading at a premium or discount to the NAV of the Trust.
−Removed: Such a premium or discount could be significant, depending upon the nature or duration of the impairment.
+Added: The License Agreement with The Bank of New York Mellon may be terminated by The Bank of New York Mellon in the event of a material breach.
+Added: Termination of the License Agreement might lead to early termination and liquidation of the Trust.
+Added: The Bank of New York Mellon and the Sponsor have entered into a License Agreement granting the Sponsor a non-exclusive, personal and non-transferable license to certain patent applications made by The Bank of New York Mellon covering systems and methods for securitizing a commodity for the life of such patents and patent applications.
+Added: The license grant is solely for the purpose of allowing the Sponsor to establish, operate and market a currency-based securities product based solely on the securitization, in whole or in part, of a single non-U.S.
+Added: The License Agreement provides that either party may provide notice of intent to terminate the License Agreement in the event the other party commits a material breach.
+Added: If the License Agreement is terminated and one or more of The Bank of New York Mellon’s patent applications issue as patents, then The Bank of New York Mellon may claim that the operation of the Trust violates its patent or patents and seek an injunction forcing the Trust to cease operation and the Shares to cease trading.
+Added: In that case, the Trust might be forced to terminate and liquidate, which would adversely affect Shareholders.
+Added: Shareholders may incur significant fees upon the termination of the Trust.
+Added: The occurrence of any one of several events would either require the Trust to terminate or permit the Sponsor to terminate the Trust.
+Added: For example, if the Depository were to resign or be removed, then the Sponsor would be required to terminate the Trust.
+Added: Shareholders tendering their Shares within 90 days of the Trust’s termination will receive the amount of euro represented by their Shares.
+Added: Shareholders may incur significant fees if they choose to convert the euro they receive to USD.
+Added: DEPOSITARY TRUST AGREEMENT
The Depository owes no fiduciary duties to the Trust or the Shareholders, is not required to act in their best interest and could resign or be removed by the Sponsor, which would trigger early termination of the Trust.
4 unchanged sentences
If directed by the Sponsor, the Trustee must terminate the Depository.
−Removed: Such a termination might result, for example, if the Sponsor determines that the interest rate paid by the Depository is inadequate.
+Added: Such a termination might result, for example, if the Sponsor determines that the
+Added: interest rate paid by the Depository is inadequate.
In the event that the Depository was to resign or be removed, the Trust will be terminated.
−Removed: Shareholders may incur significant fees upon the termination of the Trust.
−Removed: The occurrence of any one of several events would either require the Trust to terminate or permit the Sponsor to terminate the Trust.
−Removed: For example, if the Depository were to resign or be removed, then the Sponsor would be required to terminate the Trust.
−Removed: Shareholders tendering their Shares within 90 days of the Trust’s termination will receive the amount of euro represented by their Shares.
−Removed: Shareholders may incur significant fees if they choose to convert the euro they receive to USD.
Redemption orders are subject to rejection by the Trustee under certain circumstances.
3 unchanged sentences
In the Depositary Trust Agreement, the Sponsor and the Trustee disclaim any liability for any loss or damage that may result from any such rejection.
−Removed: Substantial sales of euro by the official sector could adversely affect an investment in the Shares.
−Removed: The official sector consists of central banks, other governmental agencies and multi-lateral institutions that buy, sell and hold euro as part of their reserve assets.
−Removed: The official sector holds a significant amount of euro that can be mobilized in the open market.
−Removed: In the event that future economic, political or social conditions or pressures require members of the official sector to sell their euro simultaneously or in an uncoordinated manner, the demand for euro might not be sufficient to accommodate the sudden increase in the supply of euro to the market.
−Removed: Consequently, the price of the euro could decline, which would adversely affect an investment in the Shares.
−Removed: Shareholders that are not Authorized Participants may only purchase or sell their Shares in secondary trading markets.
−Removed: Only Authorized Participants may create or redeem Baskets through the Trust.
−Removed: All other investors that desire to purchase or sell Shares must do so through NYSE Arca or in other markets, if any, in which the Shares are traded.
The liability of the Sponsor and the Trustee under the Depositary Trust Agreement is limited and, except as set forth in the Depositary Trust Agreement, they are not obligated to prosecute any action, suit or other proceeding in respect of any Trust property.
5 unchanged sentences
Such an amendment could impose or increase fees or charges borne by the Shareholders.
−Removed: Any amendment that increases fees or charges (other than taxes and other governmental charges, registration fees or
−Removed: other expenses), or that otherwise prejudices any substantial existing rights of Shareholders, will not become effective until 30 days after written notice is given to Shareholders.
−Removed: The License Agreement with The Bank of New York Mellon may be terminated by The Bank of New York Mellon in the event of a material breach.
−Removed: Termination of the License Agreement might lead to early termination and liquidation of the Trust.
−Removed: The Bank of New York Mellon and the Sponsor have entered into a License Agreement granting the Sponsor a non-exclusive, personal and non-transferable license to certain patent applications made by The Bank of New York Mellon covering systems and methods for securitizing a commodity for the life of such patents and patent applications.
−Removed: The license grant is solely for the purpose of allowing the Sponsor to establish, operate and market a currency-based securities product based solely on the securitization, in whole or in part, of a single non-U.S.
−Removed: The License Agreement provides that either party may provide notice of intent to terminate the License Agreement in the event the other party commits a material breach.
−Removed: If the License Agreement is terminated and one or more of The Bank of New York Mellon’s patent applications issue as patents, then The Bank of New York Mellon may claim that the operation of the Trust violates its patent or patents and seek an injunction forcing the Trust to cease operation and the Shares to cease trading.
−Removed: In that case, the Trust might be forced to terminate and liquidate, which would adversely affect Shareholders.
+Added: Any amendment that increases fees or charges (other than taxes and other governmental charges, registration fees or other expenses), or that otherwise prejudices any substantial existing rights of Shareholders, will not become effective until 30 days after written notice is given to Shareholders.
+Added: COVID-19 PANDEMIC
+Added: The novel coronavirus known as COVID-19 is harming the global, regional and national economies in unexpected, unpredictable ways that could materially and adversely affect the value of the Shares.
+Added: COVID-19 spread globally throughout 2020 and continues to spread in 2021.
+Added: This pandemic has had material adverse effects on the global economy, including lower levels of economic activity and widespread unemployment.
+Added: The economic turmoil has led to unprecedented amounts of stimulus in regional and national economies by central banks and other governmental authorities.
+Added: Despite massive intervention, the humanitarian and economic crisis continues, and financial markets have generally experienced heightened volatility.
+Added: No assurance can be given that the disruption will end soon or that the value of the Shares will not be affected materially and adversely by the pandemic and its consequences.
+Added: Escalation or prolonged continuation of the pandemic could exacerbate other risk factors identified in this Report and materially and adversely affect the value of the Shares.
+Added: Due to the increased use of technologies, intentional and unintentional cyber attacks pose operational and information security risks.
+Added: With the increased use of technologies such as the Internet and the dependence on computer systems to perform necessary business functions, the Trust is susceptible to operational and information security risks.
+Added: In general, cyber incidents can result from deliberate attacks or unintentional events.
+Added: Cyber attacks include, but are not limited to gaining unauthorized access to digital systems for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption.
+Added: Cyber attacks may also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites.
+Added: Cyber security failures or breaches of the Trust’s third party service providers (including, but not limited to, the Trustee and the Sponsor) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, the inability of Shareholders or Authorized Participants to transact business in Shares and Baskets respectively, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, and/or additional compliance costs.
+Added: In addition, substantial costs may be incurred in order to prevent any cyber incidents in the future.
+Added: The Trust and its Shareholders could be negatively impacted as a result.
+Added: While the Sponsor has established business continuity plans and systems reasonably designed to detect and prevent such cyber attacks from being effective, there are inherent limitations in such plans and systems.
+Added: For instance, it is possible that certain existing risks have not been identified or that new risks will emerge before countervailing measures can be implemented.
+Added: Furthermore, the Trust cannot control, or even necessarily influence, the cyber security plans and systems put in place by the Trust’s third party service
+Added: Since the Trust is dependent upon third party service providers (including the Sponsor and Trustee) for substantially all of its operational needs, the Trust is subject to the risk that a cyber attack on a service provider will materially impair its normal operations even if the Trust itself is not subject to such an attack.
+Added: In addition, a service provider that has experienced a cyber security incident may divert resources normally devoted to servicing the Trust to addressing the incident, which would be likely to have an adverse effect on the Trust’s operations.
UNRESOLVED STAFF COMMENTS
5 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.