As the Dollar Ticks Up, Picking An ETF Can Be a Challenge

After months of a downhill slide, the dollar is making gains again and it's benefiting some exchange traded funds (ETFs).

It lost a little ground last week, but so far in trading today, it seems to have resumed its climb. The gains have helped calm some worries about inflation, reports Tim Paradis for the Associated Press. When the dollar is weak, it can heighten price increases. Commodities like oil then become more attractive to investors who are looking to hedge inflation.

With that, oil retreated from its record high and fell to $125.41. Last week, it gained $10.

Jack Crooks for Money and Markets points to the G7 meeting in early April as the kick-off point for the dollar's about-face. Traders began to dissect the events of the meeting and perhaps became concerned that a bottom had been hit, and now there's a battle between the dollar bulls and bears.

There are many ways to play your sentiment on the dollar and other currencies around the world. Rydex's CurrencyShares allow investors to hedge the falling dollar relative to a variety of currencies. Market Vectors has two new exchange traded notes (ETNs) that allow investors to go double long or short on the euro. And PowerShares has two ETFs that capitalize on either bullish or bearish sentiment on the dollar.

There's also an all-in-one ETF if you find it hard to pick and choose: the PowerShares DB G10 Currency Harvest (DBV). It contains exposure to the dollar, euro, yen, Canadian dollar, Swiss francs, British pound, Australian dollar, New Zealand dollar, Norwegian krone and the Swedish krona.

Among your other options:

• PowerShares DB US Dollar Index Bearish (UDN)
• PowerShares DB US Dollar Index Bullish (UUP)
• CurrencyShares Australian Dollar Trust (FXA)
• Market Vectors Indian Rupee (INR)
• CurrencyShares Swiss Franc Trust (FXF)

Read the disclosure, as Tom Lydon is a board member of Rydex Funds.

Switzerland and ETF Could Be On the Mend, But More Woes Predicted

Switzerland recently got socked by the global credit crunch, but the country and its exchange traded fund (ETF) seem to be in recovery mode.

The Swiss bank UBS (UBS) had write-downs in the billions last week. Around the same time, mutual funds investing in the country began experiencing inflows. Year-to-date, those funds have reported $2.4 billion in inflows, the bulk of which took place last week, reports Trang Ho for Investor's Business Daily.

It's a turnaround from last year, when those funds experienced $280 million in outflows.

iShares MSCI Switzerland (EWL) has gained 1% during the past year. Year-to-date, it's down 0.6%, but in the last month, it's moved up 2.9%.

One economist predicts more reports of losses and more financial turmoil through the end of the second quarter.

The financial sector accounts for 15% of the Swiss gross domestic product (GDP), and it could make or break the overall economy. The financial sector in the ETF is the third heaviest weighting at 22.6%. The top two are healthcare (30.4%) and consumer goods (25.5%).

UBS is the third-largest holding in the fund, as well, with 5.6% of the assets. The other two holdings have a bigger share of the assets: Nestle has 18.3% and Roche Holding has 14.1%.

Who's Big In The European ETF Circle?

The European exchange traded fund (ETF) market is just as hot as its U.S. counterpart. The European market is capitalizing on the rapid growth of the industry, as major providers have adopted some very different strategies in their efforts. Paul Amery for Index Universe gives a rundown of the top ten European providers.

BGI/iShares: 137 ETFs, $57.65 billion assets under management, 43.3 of the market share; the major area iShares is missing is in the leveraged/inverse ETF arena.

Lyxor: 87 ETFs, $31.48bn AUM, 23.6% market share; Possibly too equity dependent.

db xtrackers: 49 ETFs, $10.66bn AUM, 8% market share.

AXA/BNP: 30 ETFs, $6.69bn AUM, 5% market share.

Credit Suisse: 8 ETFs, $4.97 bn AUM, 3.7% market share.

Credit Agricole: 3 ETFs, $3.02bn AUM, 2.3% market share.

XACT Fonder: 9 ETFs, $2.51bn AUM, 1.9% market share.

ETF Securities: 55 ETFs, $5bn AUM, 1.8% market share.

State Street Global Advisors: 13 ETFs, $2.35bn AUM, 1.8% market share.

UBS: 9 ETFs, $2.14bn AUM, 1.7% market share.

The European ETF Market Compared To The U.S.

While most of our coverage centers on exchange traded funds (ETFs) listed in the United States, we realize that they aren't just a U.S. phenomenon. We might have the largest market for them, but Europe, Asia and Latin America all boast fast-growing ETF industries of their own.

At the end of 2007, the European ETF market had amassed assets of $128.4 billion in 423 funds, reports Paul Amery for Index Universe.

iShares is the leading ETF provider in both here and in Europe, while State Street Global Advisors is the second-largest provider in the United States. The lack of similarity of product providers within the two markets is interesting, but as time goes on there will be more overlaps.

As for asset class, fixed income has almost three times the amount in fixed income that Americans do, thanks to Europeans' historical preference for bonds. Both markets have a  strong domestic bias, but the European equity sector is less interested in overseas investing than the United States is.

More than half of the ETFs in the United States are held by retail investors; in Europe, it's closer to one-third, but data backing up this figure isn't easy to find.

Europe has special challenges, thanks to differences between the countries. Most of them might be using the same currency, but their cultures and legal systems are not the same. It's also typical to have ETFs cross-listed between exchanges, since each country generally has its own. Often, you'll see primary listings, then secondary ones.

In a country-by-country breakdown, Germany has the largest number of primary listings: 157. It's followed by France (119), United Kingdom (84), Switzerland (21) and Italy (6).

Big Banks Announce Write-Downs, But Financial ETFs Turn the Other Cheek

Swiss bank UBS (UBS) revealed big damage from exposure to the U.S. subprime crisis, but financial exchange traded funds (ETFs) don't appear to be bearing the scars.

The company said today that it expects write-downs of about $19 billion, reports Onna Coray for the Associated Press. That brings its total number of write-downs to $40 billion in the last nine months, the largest of any bank to this point. UBS Chairman Marcel Ospel stepped down.

Germany's largest bank, Deutsche Bank AG (DB), announced a write-down of $4 billion.

Oddly, though, financial ETFs are soaring today. After UBS and Deutsche Bank announced their write-downs, the European banking sector shot up 3%. UBS shares soared more than 6%, and Deutsche Bank shot up more than 3%, reports CNBC. The iShares S&P Global Financials (IXG) is up more than 4.5% today. It holds 1.2% of UBS and 1.1% of Deutsche Bank.

iShares MSCI Switzerland (EWL) and iShares MSCI Germany (EWG) are up about 1.5% so far today. UBS is 5.6% of Switzerland's fund, while Deutsche Bank is 4.9% of Germany's.

The financial sector has been given a bit of a revival from U.S. Treasury Secretary Henry Paulson's proposal for an overhaul of the financial system.

This has got some wondering if the light has appeared at the end of the tunnel. Some are skeptical and feel that the temptation to go bargain hunting should be avoided until next year.

We agree - wait until the sector has steadied some and heads back above its 200-day moving average.

Tom Lydon Talks Foreign Currency ETFs on "ETF Tracker"

Tom Lydon appeared on CNBC's "ETF Tracker" segment last Tuesday and discussed how the falling USD is opening opportunities for individual investors to buy foreign currencies as a way to hedge against low yields in money market funds, bonds, and CDs. Video from Tom's segment appears below:

Even In These Markets, You Can Still Find ETF Movers and Shakers

Yesterday, the markets delivered outstanding performance and some exchange traded funds (ETFs) finished up in the double digits.

But one good day doesn't mean we're out of the slump yet. It's still time to take a defensive stance with your portfolio and make sure you've got that exit strategy firmly in place. But while it seems as though everything is in a downward spiral, but there are still some buying opportunities, believe it or not.

At our asset management firm, we track a list of about 100 ETFs and review it daily to see how things are performing and if there are any trends emerging. Of particular interest to us is which funds are above their 200-day moving averages. We never buy something sitting below that line.

Once we own an ETF, we keep an eye on it to make sure it's still above that line and continuing to perform. Once it dips below the trend line or falls 8% off its high, we sell. No ifs, ands or buts. A sell strategy from which emotions are entirely removed is the only kind that will benefit any investor.

It can be hard to let go of a little mover and shaker you've always had that soft spot for, but if you want to protect your money, you have to. It's like your parents always said when they were grounding you every other week: "This hurts me more than it hurts you." But sometimes it has to be done for everyone's good.

There are no guarantees that when you let a fund go, it's not going to turn around and deliver the numbers again. But that doesn't mean it won't, either. It's exactly why you have to remain as stoic as possible and stick to the plan and rationalize nothing.

There are a number of ETFs sitting well above their trend lines. Take a look at them, keep an eye on them and if they fit into your overall portfolio and are moving in an overall upward direction, they could be well worth considering:

• iShares MSCI Taiwan Index (EWT), 6.2% above
• Claymore/BNY BRIC (EEB), 5.9% above
• iShares S&P Latin America 40 Index (ILF), 10.1% above
• iShares MSCI Brazil Index (EWZ), 13.7% above
• Market Vectors Russia (RSX), 8.1% above
• iShares S&P GSSI Natural Resources (IGE), 6.8% above
• PowerShares DB Commodity Index Tracking Fund (DBC), 27.7% above
• iShares S&P GSCI Commodity-Indexed Trust (GSG), 23.9% above
• United States Oil Fund (USO), 28.3% above
• iShares Dow Jones US Oil & Gas Exploration Index (IEO), 14.4% above
• Energy Select Sector SPDR (XLE), 6.7% above
• iShares Dow Jones US Energy (IYE), 6% above
• Market Vectors Steel (SLX), 14.4% above
• iShares COMEX Gold Trust (IAU), 21.2% above
• streetTRACKS Gold Shares (GLD), 21.1% above
• Market Vectors Gold Miners (GDX), 16.5% above
• iShares Silver Trust (SLV), 30.3% above
• SPDR S&P Metals & Mining (XME), 11.5% above
• PowerShares DB Base Metals (DBB), 8.5% above
• PowerShares DB Agriculture (DBA), 30.8% above
• Market Vectors Global Agribusiness (MOO), 11.4% above
• CurrencyShares Euro Trust (FXE), 6.9% above
• CurrencyShares Swiss Franc Trust (FXF), 10.2% above
• CurrencyShares Japanese Yen Trust (FXY), 8.5% above

For full disclosure, some of Tom Lydon's clients own shares of EWT, IEO, DBB and DBA.
Read the disclosure, as Tom Lydon is a board member of Rydex Funds.

U.S. Dollar Falls Further and Currency ETFs Rally

It could be just what exchange traded fund (ETF) investors who are bearish on the U.S. dollar want to hear: another day, another low.

After two days of setting records, the euro once again set one on Thursday, reports Erin Conroy for the Associated Press.

The dollar's decline could complicate the Fed's decision-making progress in regards to the economy. That's because when the Fed cuts rates in an attempt to jump-start the economy, those cuts also drive the dollar lower.

Currency ETFs rallied on Wednesday thanks to the weakness of our money, says Wanfeng Zhou for Thomson Financial. Most CurrencyShares funds have been seeing positive territory this week:

• CurrencyShares Euro Trust (FXE), up 3% in the last week
• CurrencyShares British Pound Sterling Trust (FXB), up 2.2% in the last week
• CurrencyShares Swiss Franc Trust (FXF), up 3.8% in the last week
• CurrencyShares Japanese Yen Trust (FXY), up 1.8% in the last week

Read the disclosure, as Tom Lydon is a board member of Rydex Funds.

It Could Be Time to Take a Global View with Healthcare ETFs

While the United States is still trying to sort out its own health care system, perhaps it's time to take a more global perspective with health exchange traded funds (ETFs).

Here, we're trying to figure out who will be insured and to what extent, and the FDA approval process can hinder the rate of new drug development by biotechnology companies.

With that, Gary Gordon for Seeking Alpha singles out the iShares S&P Global Healthcare Index Fund (IXJ) for several reasons:

• It's one-third less volatile than the S&P 500
• There's exposure to England, Switzerland and France (France has the world's third-largest health care budget; England provides free health care to all residents of the United Kingdom; health care is compulsory in Switzerland)
• Its five-year returns are within a few percentage points of the broader S&P 500, and with less risk

This fund sits far below its trend line (200-day moving average), so wait until it migrates back above before taking a look.

Five Global Safe Havens for Risk-Averse ETF Investors

For risk-averse investors, there are still ways to gain exposure to foreign markets with exchange traded funds (ETFs) and minimizing the homework involved with single stock-picking.

Todd Wenning for The Motley Fool points out The Economist's list of the most risk-averse countries, where global operational risk is lower. Criteria studied involved economic, government and systemic factors. Based on that, the publication came up with: Switzerland, Denmark, Finland, Sweden and Singapore.

Interesting: the United States ranked 25th on the list, behind Cyprus and Estonia.

For an all-in-one diversification investment tool, ETFs in foreign developed markets of interest are:

• iShares MSCI EAFE (EFA)
• Vanguard Europe Pacific ETF (VEA)
• iShares MSCI Sweden (SWE)
• iShares MSCI Singaopre (EWS)

The fact that a country or company is operationally safe doesn't make it a definite "buy," though. This information is merely a starting point, and it's a good idea to do your own homework.

It should also be noted that these countries are developed markets, so the growth potential within them isn't the same as it would be in emerging economies.

Five ETF Sectors To Recession-Proof Your Portfolio

The signs are all there that we're in a recession: many exchange traded fund (ETF) sectors have taken a hit, Congress is calling hearings, the Federal Reserve is talking about more rate cuts, housing, retail and unemployment numbers are unimpressive at best.

When will the government finally admit what we've all suspected for some time now - that the recession has already started? We can't answer that, but what we can tell you is that now is the time to start thinking about how you can protect your portfolio. The last thing you want to do is wait until it's too late.

Here are a few sectors that have been bucking the trend:

Switzerland's Quietly Strong Economy Could Prime Its ETF for a Takeoff

As some markets are see-sawing, Switzerland's exchange traded fund (ETF) could be primed for a rise after having underperformed.

The iShares MSCI Switzerland (EWL) ended 2007 up 4.5%, but has gotten off to a slow start so far this year. Year to date, it's down 7.9% and currently resides 7.7% below its trend line (200-day moving average).

The standard of living in the country is higher than that of any other European economy. Inflation and unemployment (3.1% in 2007) are low. The economy is heavily dependent on foreign guest workers, who make up 20% of the labor force. And the country's notorious banking secrecy laws have made it a safe haven for investors.

Let's not forget their delicious, delicious chocolate, either.

Its GDP stagnated from 2001-2003, but now there are signs of a turnaround: in 2006, it went up 2.9%, and last year it leapt another 2.6%. What's in store for 2008?

Thomas Smicklas for Seeking Alpha feels that Switzerland and its ETF could be primed for a rebound. Its political neutrality could mean that the top holdings in the fund can do business with any country in the world, which set them up for some upward movement.

Among the fund's top holdings are Nestle (17.1%), Roche Holding Ltd. (13.1%), Novartis (10.9%).

The Swiss franc has been performing strongly against the U.S. dollar, as well:

Barclays' New Currency ETNs Evolve

Barclays is expanding its line of exchange traded notes (ETNs) with three new currency-related filings. Despite the IRS ruling that these notes should be taxed as debt, and that gains from interest income and currency appreciation will be taxed as regular income tax, Barclays Capital went forward with the launch.

The new ruling will put ETNs at a slight disadvantage because noteholders will be required to pay taxes on implied interest each year. Matthew Hougan for Index Universe says the new ETNs are:

• Asain and Gulf Revaluation: Gives exposure to five Middle Eastern and Asian market currencies that are tied to the U.S. dollar and comes with a 0.89% expense ratio.
• Barclays GEMS Strategy: GEMS stands for global emerging markets strategy. The fund is a 15-currency money market account that covers five geographic zones, including Eastern Europe, Africa and Latin America. It has a 0.89% expense ratio.
  
• The Carry Trade ETN: The carry trade involves borrowing money in low-yielding currencies and investing it in high-yield currencies. This fund involves using long and short forward positions in G10 currencies to execute the trade. Among others, the index has holdings in the Norwegian krone, New Zealand dollar, Swiss Franc and Australian dollar. The fund has an expense ratio of 0.65%.

ETNs trade like stocks or exchange traded funds (ETFs), but they're debt instruments, meaning that investors are exposing themselves to risk that the issuing bank will go bankrupt.

You Can't Always Judge an ETF By Its Name

In December, Barclays added another international exchange traded fund (ETF) to its lineup: the iShares MSCI Kokusai Index Fund (TOK).

 TOK covers 1,203 holdings in 22 developed markets, minus Japan, with the United States taking the most holdings at 50%. The second-largest constituent is the United Kingdom, at 12%. There are also holdings in Austria, Belgium, Ireland, Italy, New Zealand, Spain, Sweden and Switzerland.

The largest holding is ExxonMobil Corp. (XOM) at 2%. It's most heavily concentrated in financials, at 24.7%. When the fund launched, Matt Hougan for Index Universe wondered if it wasn't a strange product to launch on a U.S. exchange since, after all, most U.S. investors are already invested in this market and would instead want exposure to Japan in their portfolios.

But the most intriguing thing about the fund, we think, is its name: "kokusai" is the Japanese word for "international." It's an interesting choice of word for a fund with no holdings in Japan.

Silver ETF Takes A New Shine

Silver has long been in the shadow of its golden counterpart, and focused exchange traded funds (ETFs) mirror that from 2006. Last year, gold finished up 28% while silver added 18%. That was after suffering a few volatile swings, though.

iShares Silver Trust ETF (SLV) has seen its rate of accumulation slow, but the addition of a silver ETF in the UK and Switzerland are turning the trend around, reports Jane Louis for Resource Investor. Demand for the commodity dipped somewhat with the advent of digital photography, as silver is a major component in developing film.

But there is still no shortage of other uses for the metal. Industrial applications are the main source of silver demand in the market, as it is a good thermal conductor, electrical conductor, batteries use it, along with water filtration systems.

Silver will be growing in popularity as new uses are being developed, such as a wood preservative. In addition to SLV, PowerShares DB Silver (DBS) tracks the metal.

The Falling Dollar and Currency ETFs

It is no secret that the U.S. dollar has been falling against other major currencies, as evidenced by exchange traded funds (ETFs) and related investments.

The dollar's value dropped 10% against the euro, and is down 40% from its October 2000 high. David Kathman for Morningstar reports that the dollar also dropped 6% versus the Japanese yen and also hit a 25-year low against the British pound. The pound, as we said earlier today, has fallen on some hard times of its own.

Essentially, this means the investors around the world have lost confidence in the future stability of the dollar, and, as a result, they are more confident in currencies such as the euro. Effects of the weakening dollar are complex, but the good side is that foreign buyers can come into the U.S. and spend their money. With the dollar's weakness, these ETFs have posted great returns the past couple of years (the percentage that follows is their one-year performance unless otherwise noted):

• CurrencyShares Australian Dollar Trust (FXA), up 19.4%

• British Pound Sterling Trust (FXB), up 5.3%

• Canadian Dollar Trust (FXC), up 19.1%

• Euro Trust (FXE), up 18.7%

• Japanese Yen Trust (FXY), up 8.3% since inception

• Mexican Peso Trust (FXM), up 6.5%

• Swedish Krona Trust (FXS), up 14%

• Swiss Franc Trust (FXF), up 16%

Performance chasing is generally not a good idea, especially since currency movements are unpredictable and volatile. Do your research first.

Read the disclosure, as Tom Lydon is a board member of Rydex Funds.

Private-Banking Assets in Singapore Could Lift ETF

If the assets keep flowing into Singapore's private banking accounts, perhaps its exchange traded fund (ETF) could see some good times ahead, too.

According to Assif Shameen for Barron's, if things keep up the pace, it could soon pass Switzerland as the world's largest private-banking center. Singapore is attractive because of Asia's stringent secrecy laws and favorable taxes, and the 30,000 new millionaires in China each year are looking for a place to stash their money.

That being said, Singapore has a ways to go: it has 6% of worldwide private-banking assets, while Switzerland has 18%. However, Switzerland's private-banking business is experiencing single-digit growth and Singapore's is expected to grow 30% this year.

Eli Hoffmann for Seeking Alpha reports on a few ways to get in on Singapore's economy. Citigroup (C) is leading the charge in tapping the Asian wealth, followed by UBS (UBS), Credit Suisse (CS), HSBC (HBC) and Merrill Lynch (MER).

The iShares MSCI Singapore (EWS) and the closed-end fund, Singapore Fund (SGF), offer investors exposure to the broader Singaporean economy, which appears to be on the upswing.

A Fresh Look at Switzerland and Its ETF

The iShares MSCI Switzerland (EWL) tends to be a more stable exchange traded fund (ETF) because of its conservative fiscal stance. In fact, Switzerland's Central Bank recently raised interest rates for the eighth quarter in a row, going against the European Central Bank and the Bank of England that kept rates the same, according to Carl Delfeld for ETF XRAY. Currently, EWL is up 3.9% year-to-date.

Switzerland's economy is based on a labor force that produces highly-skilled work such as microtechnology, biotechnology and pharmaceuticals. Most of the people working in Switzerland work in small and medium-sized companies, according to SwissWorld.org. The country also has the third largest financial center in the world after New York and London.

Carry Trade And ETFs

There are two currency exchange traded funds (ETFs) for investors who do not have access to a currency trading account. If you want to harness the upside of the yen, CurrencyShares Japanese Yen Trust (FXY) could help you out. The Swiss franc is yielding the second lowest interest rate, so look into CurrencyShares Swiss Franc Trust (FXF) which has gained 1.2% during the last week.  Matthew D. McCall for Seeking Alpha believes the debate between further unwinding of the yen carry trade will go on for weeks, if not longer. The above two ETFs would let investors participate in the unwinding and even if it doesn't happen, both funds should perform with the weakening U.S. dollar.

"Carry trade" refers to the strategy currency traders have implemented with the Japanese yen for years. They borrow money at a low interest rate, convert the money into a different currency, and invest the money into a higher yielding bond. The 0% interest rate in Japan speaks for itself. There are current reports suggesting that traders are going to unload, as the yen rallies and the U.S. dollar falls. The unwinding would equal a buyback of the yen and a selling of other currencies, resulting in a liquidity crunch across the globe.

Carry trade or not, the two ETFs offer good options for investors seeking foreign currency, if it fits in their portfolio objectives.

Read the disclosure, as Tom Lydon is a board member of Rydex Funds.

Swiss ETF Offers More Than Returns

When investing in a Switzerland exchange traded fund (ETF), remember that you're investing in stability. The country's GDP is at a 3% crawl and is expected to fall to 2% next year. However, the account surplus is at 13% of GDP and the Swiss Franc is solid and stable.

The iShares MSCI Switzerland (EWL) ETF gives investors access to a country that takes a global approach to business. John Christy of Forbes writes that this fund has sectors that the Swiss are known for: luxury and consumer goods, pharmaceuticals, and finance. Beware though, this fund is highly concentrated, but the top holdings are valuable and have growth prospects. Year-to-date EWL is up 30%.  Stability and protection are good terms to sum it up.

Country ETFs Capitalize On Eastern Europe

Gross National Product (GDP) in Eastern Europe will run 1-2% ahead of Western Europe while interest rates remain low, reports Murray Coleman at Investors Business Daily. Although there are no specific Eastern European ETFs available, the next best thing is buying ETFs representing surrounding countries.

Barclays offers iShares for both Austria (EWO) and Switzerland (EWL). Banks, telecommunication, transportation and energy companies based in Austria and Switzerland have been well established in Poland, Hungary, Slovakia and The Czech Republic for years. A booming economy and an educated and motivated people should bode well for this "New Europe" in the near term.

Single Country ETFs On Fire!

ETFzone Trading Specialist, Jonathan Bernstein points out that single country ETFs have been on a fire the past two years. Many have appreciated over 50%! Some examples include:

• like iShares MSCI Mexico (EWW) and iShares MSCI Brazil (EWZ)
• iShares MSCI Japan (EWJ), iShares MSCI Korea (EWY), and iShares FTSE China 25 Index (FXI)
• iShares MSCI Sweden (EWD) and iShares MSCI Netherlands (EWN)
• iShares MSCI South Africa (EZA)

"Despite their recent strength,  they remain relatively lightly traded and for many investors even obscure. Any investor in these or other single country ETFs should keep in mind that these funds are volatile, with betas sometimes twice that of more diversified funds. Also because these funds offer exposure to foreign entities, all have significant currency exposure. These funds can be expected to do well when the dollar weakens. A strengthening dollar is negative for these funds"

Switzerland's ETF (EWL) is Anything but Nuetral

A handful of countries and global regions have enjoyed improved economic results and their corresponding stock markets have benefited. Switzerland, for a relatively small country, has some powerful global companies (UBS , Nestlé , Novartis and Roche ) that are well positioned.

The iShare Switzerland ETF (EWL) is up 12% YTD but all of that gain has been in the last six months.

For purpose of full disclosure, EWL is part of our client accounts.