buy hyzaar online canada no prescription where can i buy the cheapest xenical online doxycycline 100mg buy quiero comprar antabuse canada pharmacies online that sell fluoxetine us pharmacy for cialis long term side effects of ventolin lisinopril and birth control pills adalat retard side effects what does ditropan xl do buy voltaren fast shipping is mail order coreg safe best site to buy pariet can i get live sports on roku why is there a shortage of zanaflex estradiol implant supplier buying zaditor from canada no prescription buspar and cold medicine cheap famvir 100 mg what does green tea with ginseng do for you comprar cipro portugal legal buy uroxatral online canada generic provera usa pharmacy herbal medicine for abortion in the philippines what is the dosage for zovirax for cold sores healthy manicotti chicken acai berry sales australia purinethol drug schedule epivir-hbv rx can you buy hytrin in ireland best site get zaditor fucidin h cost amantadine dosage elderly diltiazem 120 mg tablet tev cost of ciprodex otic suspension buy cheap brand cialis online hyzaar side effects liver zerit for men in usa can american prescriptions be filled in canada bystolic order cheap cialis100mg is generic rocaltrol effective synthroid weight gain 2012 can you get high on diamox tizanidine generic zanaflex api t.c. tetracycline anti-bacterial fish medication alli 10 mg buy compazine 80 mg online carbozyne side effects uk where to get bupropion viagra online orders furosemide company costa rica pharmacies no prescription anxiety medication herbal remedies celebrex cost canada forzest 20 mg tab accutane african american women levothroid online order topical nitroglycerin otc valtrex coupons german remedies india vigora what are clomid pills where to buy viagra feldene with no rx paxil generic cheap costs could you order claritin canadian pharmacy best price for real colchicine zyrtec over the counter side effects doxazosin generic drug tesco pharmacy opening times hayes buy abilify no prescription information fake viagra tadacip western australia how long does it take lexapro to work for depression medicine for abortion of one month hydrochlorothiazide brands india biaxin 2 tablets once daily minocin online usa no prescription instructions taking accutane buy tramadol online pay with cod how to make powerful viagra at home using fruits avi buy kamagra review online pharmacy side effects of toradol im buy diclofenac with paypal detoxing from seroquel femcare order canada where to voltaren rogaine 2 uk buy augmentin with paypal payment where cane i buy trimethoprim cystitis buy genuine dilantin uk rumalaya gel generic wikipedia drugs buy levitra plus overseas generic for celebrex can you plus in ireland buy levitra online free coupon for proscar diamox billig kaufen accutane online mastercard zanaflex india pharmacy side effects of thyroid medicine synthroid fertomid for sale buy generic rogaine 5 online canadian pharmacist viagra prandin drug classification generic pamelor buy canada can you buy viagra over counter germany better than uroxatral escitalopram online no prescription uk buy levitra is crestor generic available azithromycin chlamydia how long to work what is sumycin for no prescription needed kamagra soft can you buy zestril discount pharmacy vermox worm tablets uk suprax gonorrhea cost of xenical australia medicine like abilify antipsychotic billig dulcolax online kaufen sale imuran effexor xr brand positioning where to eat in calangute goa viagra brand names ventolin prix en pharmacie en france levofloxacin eye drops brand name how to use diflucan for yeast infection saw palmetto berries sale acai berry in canada stores order generic atorlip-10 what is metformin medicine used for buy parlodel online usa is unisom a prescription drug pravachol usa cvs prices paxil pills for anxiety fight store shipping worldwide flomax canadian source order flagyl rx mail order pharmacy technician duties sinequan generic reviews can u buy viagra over the counter in spain cafergot dosage forms buy flomax online india minocycline pas cher buy prozac canadian pharmacy# how much is a prescription of valtrex without insurance long time side effects promethazine hydrochlorathiazide without prescription terramycin australia buy discount lipitor levitra professional prescription levaquin without a script styplon himalaya drug promethazine uk nhs buy indinavir usa canadian viagra generic noroxin lawsuit canada gabapentin cause high blood sugar betnovate n cream for fairness leukeran 2 mg tablets is atorlip-10 a prescription drug tegretol discounts max dose of diclofenac per day metformin hcl 500mg no prescription where to buy serpina in canada safely how to use singulair granules can you buy pills from canada 5mg lexapro weight gain zestoretic online in usa order zovirax from uk without prescription purchase metformin on line in canada zentel syrup albendazole 10 ml how to take red panax ginseng extractum aristocort ordering online pharmacy cheap atacand pills diclofenac overnight shipping cheap generic and trade name for furosemide snovitra super power now co uk purchase alli online ireland ed pills that work release date for generic lexapro tamoxifen shortage 2012 etodolac 400 mg dosage effexor xr generic australia adalat cc 60 mg generic duphalac women buy habana pharmacy tampa fl order tadalis online midamor mg buy actos pioglitazone wiki penegra prices usa can you buy nizoral online him methotrexate dose for cancer can you take cialis under the tongue buy female viagra visa india drugs controller general does astelin cause weight gain red cialis viagra kullan?m? there generic form mirapex best lotrisone prices how much is zofran without insurance cheapest venlor tablets uk order betnovate online with visa generic pills for atorlip-20 what does roxithromycin contain buy cheap lady era using pay pal naprosyn brand order us online pharmacy no prescription blopress tetracycline on line no script is lamictal a prescription drug best wellbutrin sr generic orlistat online buy what is propecia propak doxycycline online sales buy sinequan new zealand online erythromycin fish medicine low price isoniazid uk comprar levlen original what is the medicine colchicine used for order diclofenac injections prescription proscar prescription online depo medrol tablets allopurinol long term side effects aricept overnight delivery seroquel emc spc cucumber make birth control costco pharmacy propecia price keflex non perscription countries sambazon power caps acai capsules is himplasia available over the counter where to buy finasteride uk forum zanaflex high bluelight better than tinidazole glycomet capsules levitra plus pills drugstore buy malegra fxt with e check cheap order diclofenac gel is it safe to buy generic viagra what are the side effects of taking premarin natural viagra alternative for women yasmin birth control pill reviews methotrexate price india bupropion smoking cessation side effects comprar lotensin pela internet brand ophthacare buy generic blopress paypal lisinopril drugstore com buy coreglow buy robaxin without a subscription locion eritromicina usos aciphex legal us pharmacy has best price brand advair diskus how to use promethazine syrup buy cheap anafranil pills viagra de venta libre how much does actos cost omnicef cost without insurance cymbalta commercial script post cycle therapy alli evista package insert eli lilly buy dilantin 30 mg doxycycline hyclate 100mg dosage hyzaar drug classification himalaya haridra reviews lotensin tablets 150 mg misoprostol side effects after abortion alphagan 100 review common side effects of lithium treatment purchase generic cialis jelly acyclovir over the counter nz where to buy cheap generic shallaki prednisolone canadian medications without prescription finest natural ginseng capsules review sale buy order lotensin walmart viagra cost cheap prednisone india benzac 40mg where to buy allegra d 24 hour can 500mg of zithromax cure chlamydia acheter pas cher cialis sublingual anafranil overnight online clomid purchase libido edge labs testosterone cream reviews how to purchase lithium online are alligators related to dinosaurs benzac online store lincocin con eucalipto inyectable roche accutane sale can i get high from snorting seroquel sinemet shoppers drug mart buy medicines online delhi atlantic drugs online review lithium online ordering capoten shortage flagyl er shoppers drug mart kamagra made china dilantin buy canada mobic tablets purchase on line 1000 mg naproxen dosage comprar vytorin 10/40 anafranil 10 mg kullananlar can i get high off nexium best place to buy zoloft in mexico zofran iv dose for children acyclovir and alcohol nhs appalachian ginseng prices what is brafix tadapox shortage 2012 online no prescription cheap abilify viagra sublingual online pay paypal what drug category is indocin where to buy fucidin drugs online buy tramadol cod fedex medrol fast india doxazosin where to purchase critical high dilantin level where to buy cheap drugstore makeup buy alligator clips hair hair clips prong how much will toradol cost buy sinequan no prescription buy over the counter trandate online buy betnovate c cream zofran medicine cytotec women buy i;m the one that;s cool fosamax tablets online over the counter premarin lasix dosage too high finasteride use women hair loss buy wellbutrin sr online no prescription metformin shoppers drug mart discount pharmacy no prescription how to order kamagra gold online purchasing epivir-hbv online uk reviews on lipitor bupropion tablets generic fml forte uk paypal is amaryl available on line in canada does taking premarin cause weight gain order dipyridamole drugstore buy thyroxine pharmacy times top 200 prescription drugs viagra 100mg vs cialis 20mg risperdal consta italiano billig amaryl online kaufen 2.5 cialis generic original chloramphenicol online wholesale viagra from china buy triamterene online usa canadian alliance party leader very cheap proscar generic flagyl er paypal diamox drug oversea costo del nootropil buy brafix inhaler canada brand cialis lawsuit buy benfotiamine 250mg through canada buy albendazole delivery plendil without paypal cheap uk pills generic actos western drug brand advair diskus organika korean red ginseng 60 capsules cancer drug sales 2011 buy roxithromycin astrailia naprosyn women buy what is fluoxetine capsules used for zenegra 100 is malegra fxt legal in uk pariet side effects insomnia mail order ventolin kamagra oral jelly pharmacy prices list grifulvin v pills sweat brand cialis trial pack trusted order eulexin generic viagra professional uk lady era medication side effects where am i from plavix discount prices what is the drug bystolic for problems with crestor medicine abilify reviews for children what is sumycin made of where can i buy viagra soft florida snovitra super power without a script buy cod abana can you get high off triamterene why is there a shortage of endep is citalopram 10mg effective for anxiety generic zyloprim usa sale nero cipro proprieta` generic hytrin usa pharmacy americans buying prescriptions from canada piracetam effects on memory singulair 10 mg cena leku what do furosemide pills look like buy fucidin h cream online high blood pressure water pills side effects tofranil pas cher lamictal shipping overseas what is trileptal medicine myambutol generic canada us online pharmacy no prescription rogaine 2 where to buy cheap generic vasotec nizoral 2 shampoo for hair loss buy ayurslim cheap danazol 100mg bula astepro vs astelin atarax online usa mestinon drug schedule best pharmacy to order female viagra order nolvadex online uk panax ginseng indian name buy actonel 5 synthroid doses and colors canadian alliance terminals ltd business pharmacy has best price tricor generic moduretic usa generic bystolic switzerland what does plavix do for you what does alliance mean in social studies finasteride 1 mg online pharmacy generic propecia 1 mg buy celebrex online lopressor side effects weight gain buy viagra plus online with mastercard is there going to be a generic for plavix erythromycin generic brand name zaditor compare prices meridia skyrim choice can you get a rash from cephalexin propecia - union pharmacy flovent dose asthma metformin india price doxycycline shortage lyme disease antabuse tablets 200 mg information actos india forum can you buy acivir pills online lexapro medicine assistance generic name for cipro hc elavil prescription assistance where to buy d generic allegra ayurslim pharmacy zyprexa mg price dulcolax 5 mg tablet propranolol india erection packs 1 order online over the counter proventil what is the medicine procardia used for citalopram 10mg anxiety buy alligator clips for hairstyles american express canada travel insurance what does zantac 150 look like part 120 drug alcohol testing program cheap generic prozac no prescription is tinidazole a prescription drug where to buy valtrex in the uk american xeloda amitriptyline 20 mg insomnia online apotheke kamagra kaufen will generic benicar available cardura online ordering liv 52 shopping average retail cost of cymbalta buy luvox 5 how to get the best results from cialis order stromectol 6mg ciprofloxacino 500mg prec,o where to buy cheap generic trileptal cheap accutane 20mg order best online pharmacy generic seroflo medicien without prescription acticin shoppers drug mart bystolic blood pressure medication side effects doxycycline hyclate 50 mg canada how to administer imitrex injections where to buy propranolol in australia advair diskus side effects weight gain buy zyrtec hong kong viagra non prescription benicar pharmacy triamcinolone cream over the counter comprar atorlip-10 portugal prescription meds without prescriptions birth control pills naprosyn bupropion discount card pfizer viagra pharmacy augmentin to purchase without a prescription diprosone cream no prescription how to purchase glycomet online vantin express canada vitamin shoppe coupons printable april 2011 buy lithium ion batteries camera cost of cialis without insurance order uk buy crestor online emsam now fluoxetine uses medication what is serophene crestor online meds kamagra soft prices at costco anacin women buy doxazosin india plavix 75mg india cheap allegra uk generic pharmacy dementia action alliance the right prescription lowest priced nizagara seroquel tablets online avodart side effects uk antibiotics in pregnancy fluconazole for thrush dosage metformin cancer stem cells triamterene tablets for sale buy baclofen cheap low price female viagra 20mg tab buy altace online with mastercard is there a generic form of zoloft grifulvin v canada overnight delivery tenormin supplier in uk brand advair diskus without a script who has the best prices for viagra how to buy zoloft online zoloft generic name sertraline synthroid 100 mcg picture canada drugs voltaren with prescription © viagra ® official site cipro canada companies only cheap generic pamelor nortriptyline 25mg cost comparison pharmacy silagra online discount atrovent mg roche xenical side effects letra de la cancion llevate mi tristeza del padre chelo sonata prescription lowest price no prescription abilify pharmacy online actos dosage too high ciprofloxacin uses diarrhea prescription cardizem effexor xr spain over counter nymphomax suppliers overseas weight gain after taking topamax how much does club liv cost buy generic doxycycline online no prescription the active ingredient in the allergy medication claritin pastillas cytotec precio en farmacias generic plavix cost without insurance purchase buspar pills suhagra tablets uk famvir on line duetact uk brand name buy rumalaya forte in uk hyaluronic acid in drug delivery systems cialis super active medication where to buy genuine renagel 100mg order brand levitra tablets where can i buy deltasone celecoxib without a prescription aciphex medication cost mirapex dose for restless legs syndrome order phenergan from australia without prescription avapro online price daily cialis vs. regular cialis atorlip-5 tablets legal to buy ranitidine what is micardis telmisartan used for prometrium for men in usa buy wellbutrin without rx floxin for daily use canada meloxicam for cats and dogs benemid billig kaufen vardenafil hcl 10mg who makes nexium medication cost lisinopril 20 mg over the counter buy actos rx buy cheap online pharmacy alesse canada purchase fresh acai berries buy indocin australia nolvadex without is mevacor legal in uk cheap genuine probalan online no prescription celebrex sale buying nootropil using paypal how much is allegra d otc confido canadian pharmacy cyklokapron in croatia over the counter bronchial asthma inhalers onde comprar cialis generico no brasil how much is tadacip tablets ibuprofen overdose side effects of diovan hct 160 25 mg buy azulfidine boots pharmacy non prescription abana want buy viagra india quickest zetia best online viagra prices strattera price insurance brand viagra pills buy online risperdal consta price india ver arjuna online latino buy kamagra gold with no rx online no prescription purchase maxalt zentel worm medicine instructions what is xenical tablets how to buy elimite in london gazeta kosovarja magjistarja citalopram over the counter india safe pills for erectile dysfunction cheap gasex pills accepted provera without script no prescription avandamet buy over the counter quibron-t online atarax online pharmacy uk dilantin noprescrition needed usa online pharmacy antibotics by mail promethazine codeine cough syrup walgreens musli power extra vs viagra list of tesco stores selling lynoral clomid generic cost cialis once daily cost cheap revatio india cipla pharmaceuticals india hamied online pharmacy probalan eurax hydrocortisone used sumycin over counter what does celexa pills look like legal viagra in the uk lasix iv side effects metformin otc miami order viagra professional from australia without prescription buy mobic online no prescription geriforte price india britney spears buying zovirax bupropion online order what is minocin used to treat holland & barrett acai capsules triple strength 1500 mg reviews bentyl online no prescription what is the gene responsible for ampicillin resistance canada drug store chains where to buy alligator meat in pa how to find a reputable pharmacy in canada can you buy nootropil in ireland strattera online ordering viagra philippines makati pyridium medication information propecia finasteride difference clomid nolvadex and aromasin for pct allegra prescription coupons maxaman order online ciprofloxacina cistite dosaggio naprosyn echeck medication etodolac 400 mg atarax without prescription miami cheap lotrisone 40 mg why has voltaren been discontinued where to alligator wrestle order depakote level buy flagyl pills in the india cheap canadian albendazole no prescription antivert express canada cipla ltd quotes can i buy abilify online ginseng now reviews differin rx list forzest doctors online avodart canada overnight delivery where to buy fluconazole online brand name diamox online to buy cabgolin in uk revatio 100 buy erythromycin without a prescription from canadian pharmacy best price for lipothin cost of mycelex-g without insurance order endep cod discount nizagara generic name silagra generic 2013 drugs ventolin inhaler salbutamol sulfate what are celebrex pills for generic extendaquin cost prescription baclofen 10mg onlinepharmacieswithoutprescription cheap gasex pills prescription generic how long does it take risperdal to start taking effect proscar prescription best actonel prices phenergan syrup pediatric dose aldactone tablet sale where can i get some levitra propranolol refills revia drug canadian pharmacy liquid lozol review flomax cheap lamisil tablets mg over counter leukeran can i make erexor best elocon prices health canada aciclovir generic pharmacy online how to get kids to take ceftin metformin for sale philippines zyban side effects australia zenegra shortage 2012 buy mifeprex and misoprostol online viagra plus sale order mg isoptin brand order pet meds canada cheap lopressor dosage range can you get zithromax coreg for hypertension reviews kariva without prescription levitra plus online coupon code american menosan buy flomaxtra line lov cost accutane how to buy metoclopramide mircette birth control ingredients buy nizagara standard aspirin dose for pain no script wellbutrin mg wellbutrin online legally iai arava aircraft comprar accutane portugal cheapest kamagra chewable tablets uk cardizem non perscription countries online generic diltiazem best site get aspirin buy lozol online amazon long lasting erection pills india lopressor by mail adalat free shipping sale leukeran fucidin h cream uk canada drugs proventil with prescription cipla medpro south africa ltd baclofen 10 mg price dulcolax for sale baclofen discount medications insulin sensitivity index alli looking for kamagra chewable online remeron without prescription to purchase online effexor price canada pamelor pharmacy prices list best online pharmacy generic diclofenac buy triamterene lowest price relafen australia price can i get antibiotics without a doctor;s prescription plavix 75 mg online kaufen reviews on furosemide over the counter isoniazid cheapest place to buy prilosec otc pill identifier pictures hydrocodone brand cialis pill shop discount code buy nolvadex online express mail viagra pills phenergan without persc where to buy passion rx in canada adalat non perscription countries ralista phone orders phone in order for lioresal order generic prazosin aceon uk next day delivery chloroquine cost us generic metformin no prescription is the uk law on drugs right how to use entocort buy lisinopril in australia donde puedo comprar malegra fxt orlistat over counter australia chloromycetin for dogs does too much synthroid cause weight gain oregon state police records best viagra prices pill comprar estrace original en madrid bupron sr online pay paypal all types renagel pills how long do withdrawal symptoms from paxil last long term side effects of malegra dxt no prescription rogaine 5 sale phenergan next day shipping viagra plus canada metformin hcl reviews clonidine canada head office buy uk deltasone pills prescription prednisone prednisolone cat trazodone dosage forms florida lotensin buyers of baclofen canada australian equivalent to trazodone himalaya ayurslim order online buy diovan online at canada pharmacy buy pravachol 10 retino no prescription overnight delivery purchase generic casodex safe to buy generic elavil from usa how to buy epivir-hbv in london buy vermox online india no prescription i pill lipitor website glass atorvastatin low dose prozac and weight gain agencia de modelos allegra models elavil no rx us only compazine capsules anxiety medication for dogs natural ivermectin albendazole side effects safe buy noroxin online amoxil 250 mg/5ml can you buy aleve in australia buy prednisone for pets diclofenac gel 1000g certified pharmacy technician online program is lithium sold over the counter purchase betnovate cream betapace by mail best rx sites is ortho tri-cyclen a prescription drug citalopram on line for sale no script silagra by cipla (india) seroquel generic canada what is ezetimibe alli class action lawsuit can you buy viagra sublingual in ireland sildenafil citrate generic shuddha guggulu switzerland fluoxetine cheap canada pharmacy hcg and clomid post cycle risperdal consta reviews finasteride side effects pregnancy purim order online what is adalat xl 30 mg used for keppra pediatric safe dose buy eldepryl without a script what type of medication is lithium is viagra an otc drug buy tadacip cheap reglan zanaflex spain astelin nose spray coupons voveran medicine is used for blue mountain pharmacy columbia free online birth control pills wellbutrin coupons pyridium discontinued diovan for sale usa artane max dose generic viagra price compare buy cialis in india order amitriptyline cats discount tinidazole australia pharmacy dutas over the counter buy nymphomax in singapore buy cefadroxil in singapore seroquel 300 mg cost why no alcohol when taking flagyl valium soma overnight no prescription prednisone order mastercard trazodone weight gain forum buy xalatan online overnight lipitor 5mg tablets us online pharmacy no prescription artane lexapro tablets purchase on line us online pharmacy no prescription haldol mevacor from usa buy cialis 10mg tablets where to buy siberian ginseng tea prescription only accutane must hoodia prime cheap buy aygestin next day extendaquin with paypal payment cialis pharmacy usa flagyl syrup used synthroid noprescrition needed usa online pharmacy tetracycline without prescription paxil capsules benadryl prices zestoretic tablets us online can you order zestril buy brahmi online amazon low cost arimidex without sertraline withdrawal symptoms how long order ampicillin online without rx where coumadin cancer buy januvia online uk what is mentat drugs mexican pharmacies without prescriptions buy plendil online from usa rachael ray weight loss lipothin fda generic nitroglycerin withdrawal from skelaxin chocolate covered acai berries costco generic cafergot us best place to buy kamagra in canada hyzaar without prescriptionj pharmacie en ligne france viagra levitra generico precio mexico can i make azulfidine pharmacy mexico aciphex luvox suppliers overseas maxalt canada price prescription celebrex celecoxib arthritis prednisone for dogs medication hyzaar visa acivir pills canadian pharmacy why do people gain weight on zoloft pariet prescription how much is generic plavix overnight xenical xenical medication canada buy generic digoxin decadron online sales elavil overnight shipping minocycline spain rosacea after accutane canada non perscription abuterol antivert without a prescription from us health canada differin buy generic betnovate with bonus lasix water pill buy online research grade methotrexate order atarax pill buy ciplox online with mastercard buy nymphomax with visa long time side effects levitra lipitor generic recall glass propecia prescription over counter what is lamisil mg used to treat ordering baclofen online protonix mg no prescription generic of allegra 180 is luvox cr better than luvox cost of iv ampicillin proscar dosage bph prednisolone price india altace generic what is the proper dosage for aleve getting digoxin in australia septilin for sale australia 100 mg amoxil what do wellbutrin pills look like how to order seroflo cardizem pills sweat allopurinol shortage long term side effects of grifulvin v augmentin duo 1000 mg dosage strattera pharmacies side effects of mixing prednisone with alcohol buy brand amoxil with a mastercard suppliers of viramune in us what are the side effects of taking erythromycin omnicef mail order india retin-a ge medication how much is cialis at cvs lowest price atorlip-10 how to get avapro the evolution of a viagra salesman by jamie reidy codeine promethazine cough syrup erowid buy methotrexate in uk do they sell nexium in mexico uk order cheap doxycycline cheap buy diclofenac gel trileptal buy no prescription cheap levothroid uk genuine tadalis sx best price canada pharmacy american express xenical medicinenet free or low cost tamoxifen clozaril purchase discount canadian pharmacy didronel purchase cheap prescription zovirax online isola di cipro wiki canadian family pharmacy advair diskus for sale bactrim 400 mg tablet list of tesco stores selling imuran low cost levothroid is it safe to order duetact can keppra make you gain weight buy mircette cheap estrace online sales amitriptyline hydrochloride 10 000 games review phenergan pharmacy coupons propranolol hcl 20 mg side effects toradol 10 mg po pill rx health silagra products buy levaquin fast shipping are prescription drugs really cheaper in canada brand antivert buy pfizer viagra online europe prednisolone tablets 5mg pill best pharmacy to order zofran cialis daily dosage floxin medication use how to buy combivent in london pharmaceutical wholesalers europe avapro online online cialis jelly buy canada cheap aricept no prescription zyban suppliers overseas alli orlistat generic atrovent nasal comprar is there a drug comparative to coumadin where can i buy omnicef buy prevacid online with mastercard buy retin a 0.025 uk buy sinemet overseas zyrtec d buying restrictions proscar shortage 2012 altace medication overdose where can your buy diflucan over the counter zerit dose malegra fxt for sale abilify from usa discount ventolin inhaler buy cheap remeron pills finax woldwide shipping frye boots promo code 2012 can use fucidin cream pregnancy avapro tabletas de 150 mg clonidine mechanism of action for opiate withdrawal voveran sr australia price effexor xr generic drug interactions venlafaxine get zaditor las vegas how long does it take for omnicef to leave your system what is ic doxycycline used for azithromycin 250 mg 6 pack buy trental from india cytotec without rx testosterone therapy side effects acne generic form of dramamine water pills to lose weight ralista medication side effects best site to buy hydrochlorothiazide confido bank salerno zoot z-pack training bag 2011 buy urispas pills which uk site to buy minipress buy propecia finasteride tablets online pharmacy proventil para que sirve el medicamento ciprofloxacina overnight delivery order wellbutrin sr buy online no prescription reviews on effexor for xr for anxiety where to get coumadin pct cialis jelly online pay paypal buy anti anxiety pills online generic toprol xl equivalent can we trust celexa online buy testosterone cream no prescription is it legal to buy canadian drugs online trileptal for sale usa where do acai berries grow can i order levlen no prescription in the usa top drugstore lipsticks buy brand motrin where to advair diskus mestinon shortage glucophage shortage propranolol mail order india overnight no prescription pharmacy avodart mg usa comprar exelon original en madrid order voltaren cheap when to take omeprazole for gerd sale nitrofurantoin can you only get rumalaya liniment on prescription ventolin nebules use side effects of orlistat capsules low potassium and digoxin toxicity rxlist tramadol gabapentin high yahoo answers lamitctal 300mg lotrisone online ordering online medsource inc prilosec otc dosage forms can i buy antibiotics for my dog online pharmacy generic effexor xr reviews baclofen side effects alcohol generic chloromycetin buy singulair capsules flonase daily use reviews lasix 20 mg tablet what is prednisone used for drug is there a generic brand for singulair zetia no prescription reviews suprax 200 mg 5ml suspension ralista australia price buy over the counter confido online buy cephalexin tablets us billig floxin online kaufen best acai prices promethazine 25 mg tablet san albuterol inhaler no prescription needed generic adalat oros canadian avalide comparison dutas order canada lipitor 10 mg every other day how to import biaxin acquisto voveran sicuro online where to buy tamoxifen citrate no prescription nolvadex no prescription cardizem fluoxetine uk boots propecia lawsuit news purchase septilin pills canadian pharmacy exams free download wellbutrin sr for men sale in uk purchase antabuse without cheap atorlip-20 no prescription canada doxycycline hyclate 20mg tablets acne voltaren without a prescription from uk retino-a cream 0,05 generico italiano amoxil side effects in children cephalexin for dogs generic xenical diet pills side effects low cost alligator shoes mezlan dramamine tablets online dostinex discontinued lifta tadalafil canadian differin tablet can 5mg of prednisone cause side effects viagra sin receta farmacias buenos aires pharmacological mechanism of action for glyburide noroxin tablets overnight pharmacy cialis super active discount pharmacy mitchell half price carbozyne nizoral from australia sumycin ordering online pharmacy order abilify online no presctiption ciprofloxacin pregnancy category buy flonase no prescription fast delivery meloxicam mobic tablet low cost overnight carafate ho to buy adderrallw amaryl india generic drugstore capoten generic for prandin generic date what is paxil used to treat best price for baclofen what does female viagra do for women what is the cost of prednisone for dogs zyban with american express combivent dosage use buy kamagra soft online reviews better than minocycline can you buy levitra professional in ireland pharmacy cipla cheap atacand how to buy celexa chloroquine purchase where to buy lasix water pills advair diskus wiki can you buy innopran xl online amantadine for men sale in uk order paxil 40 mg where to buy propranolol online india vpxl without a prescription from canada where can you buy diflucan lipitor 10mg tablets albuterol inhaler for weight loss tretinoin cream usp o 1 discount micardis medicine what is calcium carbonate used for in toothpaste what does albendazole do antabuse dosage and administration physician viagra clear lake city texas ensenada mexico pharmacies what does renagel treat oder mg tablets of sominex flomax generic mexico allegra d over the counter coupon diflucan order online no prescription buy pariet generic viagra jelly pills drugstore norfloxacin & tinidazole uses what is the generic name for wellbutrin disulfiram-like (antabuse effect) etodolac prescription coupon where can i get lisinopril pills get prevacid las vegas purchase haridra pills atorlip-20 cheap metoclopramide sale where to buy viagra in london anxiety treatment natural side effects of seroquel xr 50 mg singulair sales 2007 boner pills sold in stores are drugs from canada safe side effects of accutane skin rash pilex mail order india where could i buy astelin without prescription promethazine tablets for sale cheap adalat usa 30mg pharmacy has best price lipitor pil perancang keluarga yasmin switching from lexapro to cymbalta how to use citalopram buy protonix greece canadian alliance terminals ltd bc purchase allegra prescription cardizem cd drug class can you rewards on prescription medication au generic form of allegra quickest female cialis online drug store benicar hct costco genuine brand levitra best price can you buy asthma inhalers over the counter in spain coversyl 2mg side effects how much is generic zoloft without insurance can buy estrace online cheap rx7 upgrades alli diet pills where to buy digoxin patient reviews state wise list of pharmacy colleges in india lopid shipping overseas licensed pharmacy buspar endep fast canada generic prevacid solutab 30 mg what is baclofen used for topamax tablets on line to buy glycomet echeck lowest price voveran sr canadian glucotrol xl drugs discount wellbutrin generic for drugs forum co uk viagra jelly without prescription medication reglan online usa what is valacyclovir hcl 500 mg cipro medication for bladder infection buy isoniazid generic prednisone 20mg for dogs side effects tricor suppositories buy what is avapro drugs vytorin mg price aldactone usa pharmacy furosemide without a script buy brand advair diskus pills online medrol mg india recommended prednisone dosage for sarcoidosis high blood pressure pills diovan buy cleocin online from usa buy renagel 50 common pharmacy drugs abilify 5 mg tab female cialis online purchase are branded indian viagra safe dramamine roche precio argentina can you use ceftin for uti dapoxetine from europe co diovan forte what does furosemide 40 mg look like mentat on line no script amitriptyline cheap us pharmacy canadian pharmacy himcolin can order zyrtec canada when will alli become available again cordarone canadian online overnight pharmacy cheap luvox tofranil for men in usa seroquel lawsuit topix forum premarin drug classification maximum mirapex dose prilosec pas cher italie buy glucophage xr 500 mg vardenafil 20 mg buy generic wellbutrin weight gain what is haridra used for what is himcocid for zyprexa cost help cheapest avapro paypal doxycycline hcl manufacturer india ordering low dose reglan how to take remeron for sleep purchase cheap extendaquin online order diflucan no rx online pharmacy stores in india zofran shortage alternatives beta blockers online pharmacy sample sildenafil how to order remeron carafate canada online no prescription best drugstore foundation 2012 full coverage elocon cream use generic from liposafe order snovitra super power 120 mg where can i purchase arjuna irbesartan hydrochlorothiazide is for hypertension sildenafil citrate 100mg dosage what is cytotec tablets is nexium better than zantac strattera 40 mg buy brand cialis online at canada pharmacy atarax overdose side effects price increase paxil brand inderal for sale buy vasodilan boots etodolac 400 mg wiki trazodone uk brand name asthma inhalers linked to serious side effects order generic zoloft online atarax pills side effects of coreg medication legal buy revatio online canada buy generic augmentin generic clomid nitrofurantoin for sale australia buy alli now flomax noscript where to buy amaryllis in mn drugs antabuse for sale australia generic mentat ds syrup usa pharmacy florida accutane lawsuits can you get high off avalide buy tinidazole 5 common side effects of aciphex trimox roche precio argentina buy tofranil online no prescription us atorlip-5 sale fosamax alternative medicine lexapro costco generic cialis oral jelly 5mg buy azulfidine online comprar abilify original 100 mg levitra super active can drink alcohol while taking accutane will flonase cause weight gain bactrim ds urinary tract infection dosage premarin prices costco flonase usa sale hyaluronic acid max dose rhinathiol cold megfa'za'sra list of tesco stores selling deltasone viagra jelly 10 mg cost order canada prescription drugs cheap lisinopril 5mg tablets order antabuse overnight mirapex uses medication anything better than minocycline buy haridra online usa compare prices dostinex metoclopramide reviews benicar medicine children buy lasix fast shipping resources for mircette why has lopressor been discontinued buy grifulvin v without rx sildenafil citrate tablets side effects buy prandin mg online fast sustiva deleviery hyaluronic acid price india buy albendazole with paypal betapace shipping overseas requip modutab 8 mg how to get tadacip what is metoclopramide drugs comprar tadalafil contra reembolso safe place order precose drug market order zyrtec alesse discount card canada lotrisone on the internet best place to order zyprexa in us how to buy coreg in canada minocin sale generic from glyset boots pharmacy placement login safe to buy generic doxazosin from usa generic finasteride online prograf results forum imuran order depression pills without prescriptions how to take vermox suspension avamigran dosis prograf maximum dosage advil nuprin and motrin are brand (trade) names for the generic medication online pharmacy uk midamor purchase prednisone 50 mg brand grifulvin v for sale brand viagra sale prescription what is the medication requip used for buspar from india can you get ventolin where do i buy vasotec can you buy elocon over counter purchase generic emsam is there a generic imitrex can you buy artane online cost of generic paxil without insurance tetracycline dosage for dogs zanaflex tablets versus capsules shelf life of wellbutrin sr pletal shop net generic tadalafil reviews prednisone 20 mg and alcohol consumption atarax 10 mg during pregnancy clonidine hydrochloride 100mg generic name for toradol menosan side effects uk beta blockers online pharmacy how long does levitra last lipothin tablets online diovan pills pictures cheap uk buy depakote online can order female cialis canada renagel prescribing information rumalaya forte tablets 150 mg stieva-a for wrinkles where is asacol made paxil generic name paroxetine orlistat in the uk now cialiis in ireland over counter revatio albendazole roche precio argentina mantras healthy pregnancy real levitra online best place buy emsam pct how to use flovent inhaler instructions levlen pharmacy online voveran sr 100mg cheap discount retin-a 0,05 mg what is ciprofloxacin 500mg used to treat how to get levitra super active drug discover adventure jobs what is omnicef all types ponstel pills venta de viagra sin receta en buenos aires how to buy alphagan my atorlip-20 coupons buy phentermine 37.5 mg tablets online brand levitra without prescription miami where can i get alliance vanguard tabard discount coupons for prilosec otc aleve maximum daily dosage over counter promethazine codeine pure hoodia gordonii capsules how to get buspar on line prometrium mg canada cheap accutane 40 mg online generic is it legal to buy prednisone online generic generic ponstel cost acai berry dark chocolate costco nutrition propecia no prescription from canada cymbalta copay discount card plavix cats isoptin sr side effects buy crestor 20 mg online siberian ginseng recommended dosage cheap levlen pills vytorin 10/20 buy premarin from canada pastillas cytotec uso pharmacy that sells moduretic mircette sold over counter order viagra plus what are medrol 4mg tablets used for bystolic medication where to buy yagara dosage recommended bactrim canada lopid daily use reviews difference entre viagra and levitra phenergan suppository frequency triamterene 100mg cheap evecare shelf life lopid generic release date online pharmacy uk chloromycetin where abana depakote er 500 mg cost can you purchase alli in canada buy forzest hong kong preis fu"r cialis in holland aygestin discount erythromycin daily use reviews over the counter antivert for vertigo sumycin shelf life alli over the counter weight loss pill approved is there a drug comparative to cefixime over counter viagra alternative gnc buy minocin new zealand online chloramphenicol discount no prescription safe place order viagra diflucan non perscription countries how to get cialis without a prescription neurontin pharmacy prices list buy periactin tablets uk cyproheptadine flomax for sale online buy flonase in australia online sale of nitroglycerin generic benicar hct 40 25 mg voveran suppositories buy evista best online non prescription pharmacy what are the side effects of generic synthroid what is dramamine made of buy meds online cod femara birth control online us buy tadacip tablets online plendil online in usa why has sumycin been discontinued generic pills for torsemide paxil medication on line where can i get ayurslim pills flovent medicine online order tofranil cheap how to take singulair tablets arava in the uk cheapest acai powder prednisolone over the counter uk do i need a prescription to order from a canadian pharmacy buy ditropan canada l-tryptophan prices at costco how long does levitra 20 last buy alavert online how much does neurontin cost on the street difference between cialis super active and cialis professional augmentin antibiotic coverage cleocin precio mexico can i make bupropion resources for minipress can order antibiotics online canada buy xenical 120mg capsules serpina prix en pharmacie en france piracetam powder 500g generic form haldol hydrochlorothiazide for sale canada minipress online order skelaxin for sale where to buy trileptal sale micronase levitra over the counter uk acivir pills order on web what are the side effects of antabuse trazodone prices usa mantras healthy living what happened to allie brosh keftab from usa discount code for acticin saw palmetto reviews antabuse online price paroxetine generic paxil clorfenamina compuesta ky6 grifulvin v rx drugs from mexico statistics generic drug for aciphex generic pills for urispas comprar arjuna original en madrid genuine purim best price medicine chloromycetin what does lithium do to the body buy promethazine without prescription hydrea prescription coupon most reliable place to buy metoclopramide online clomid pct reviews olmesartan side effects hair loss amantadine india amantrel generic symmetrel cheap hyaluronic acid buy online fastest duphalac uk delivery lukol online pharmacy uk pictures of reglan pills discount buy valaciclovir birth control pills lasix do you need rx viramune buy childrens alavert buy mobic 15 mg what does diclofenac gel do oral erythromycin acne dose what is the medication voltaren gel used for what is prednisolone 5mg tablets used for precio del viagra en mexico 2013 get geriforte syrup las vegas lexapro perth australia what types of diamox are there uroxatral pas cher buy hydrochlorothiazide without a prescription from canadian pharmacy risperdal cost in canada is flexeril better than skelaxin buy hydrochlorothiazide with no prescription cheapest acivir pills to buy buy retin a online canada levlen pill shortage can you buy nizagara over the counter in germany what does cephalexin do blue pill vgr 100 pfizer cutting celexa pills pet medications no prescription needed what is the drug sinequan used for tamoxifen cost uk buy procardia online no prescription usa strattera cheap india pharmacy cheap alli uk prescription cost of lithium batteries over time too much levothyroxine and hair loss coupons for 247 overnight pharmacy female viagra cost without insurance crestor class action lawsuit canada cheapest place to buy seroflo top 200 pharmacy drugs 2012 ditropan in canada 6 mercaptopurine wiki citalopram generic price allopurinol price philippines what does real cialis look like zovirax 800 mg tab buspar pills drugstore what is champix valtrex western australia what cold medicine can i take with wellbutrin cardizem drip 20 mg/hr ritalin vs adderall weight loss brand advair diskus woldwide shipping generic effexor xr manufacturers costo de nootropil rx mountainwest apothecary zetia tablets buy mail order snovitra super power v-gel shopping generic cymbalta online us pharmacies online that sell amitriptyline where to buy seroquel online finasteride atepros aldactone side effects breast bentyl side effects canadian online pharmacy percocet walgreens viagra substitute strattera and weight loss reviews liv bill of costs benadryl medication order half price rumalaya forte metoclopramide compazine generic european pharmacy cheap kamagra 100 mg what is wellbutrin supposed to do kamagra chewable uk online generic for amitriptyline cipro price list etodolac prices cvs decadron dosage for brain tumor nolvadex d 20mg tamoxifen printable zyrtec coupons 2013 effetto antabuse wiki is fenofibrate a generic for tricor malegra fxt pills drugstore online sale of zyvox where do i wellbutrin sr in india toradol without rx canada and styplon female generic keppra overnite shipping buy flagyl er online reviews best pills to get high baclofen buy online ireland mail order silagra online keflex dosage for preseptal cellulitis levitra super active tablets online compounded testosterone cream for women risperdal consta annual sales side effects of yasmin pill weight loss brand name kamagra oral jelly online what does the parietal lobe do when driving a car ordering alesse medication oral contraceptive difference between viagra and viagra professional class action lawsuit against cymbalta phenergan with codeine cough medicine what is the generic name for paroxetine voltaren no prescription needed order generic trileptal what types of eldepryl are there reglan uk brand name vente de paxil au quebec cheap feldene mg amantadina y alcohol liquid xenical review buy dilantin online at canada pharmacy top drugstore bb creams 2013 levlen pill
Friday, November 28, 2014
Text Size

Search our Site or Google

The Seven Sins of GLD

Articles & Blogs - Gold Commentary

User Rating: / 587

Given my scathing criticism of most (so-called) “bullion-ETF's”, I frequently get reader questions about the “prospectus” of one fund or another. I freely confess to not having read these documents. My (stated) reasons for not doing so are that I do not, and would not hold such investments, and that I have already provided enough reasons to doubt the legitimacy of these investment vehicles that such an analysis would be moot.

However, at the persistent urging of one reader, I finally caved-in and went through the prospectus of The Mother of all Bullion Scams: GLD. It was at this point I had to deal with my third, unstated reason for avoiding these documents – they make your head hurt. This is especially true for those with a background in law, as we have been trained to attempt to discern the “intent” of every word of such documents, which means attempting to reconstruct the thinking of the lawyer(s) at the time the document was drafted.

At first glance, the SPDR Gold Trust (which trades under the symbol “GLD”) is the epitome of simplicity. In the first paragraph of the Prospectus Summary, it states:

“The Trust holds gold bars...”

Then, a few paragraphs later, is a section titled “Trust's Gold Holdings as of March 31, 2010”. It lists the total holdings as approximately 36.5 million ounces, almost all of it in “allocated” gold bars. So far, so good...The problem is that as soon as one scratches the surface, to attempt to verify that this ETF-behemoth is actually the straightforward “trust” that is presented, we immediately encounter one serious issue after another, which I am labeling the “seven sins” of GLD.

1) Lack of transparency:

In the page which immediately follows details of the Trusts “gold holdings”, is “The Offering”. In that section, it lists the total number of units of the Trust. Two facts leap out at us. First, the total number of units is over 390 million, with the date of that total being May 26, 2010.

Given that GLD is priced, and presented by the media as one unit equaling 1/10 ounce of gold, we immediately see that there are 7% more units than there should be at that rate of conversion, or in other words, the units clearly represent less than 1/10 ounce of gold. The problem is that it is impossible to determine precisely how much less, because of the inexplicable gap in reporting.


“Total gold holdings” are reported only up to the end of March. Presumably, the “custodian” of all that bullion (the infamous bullion-short, HSBC) is keeping track of the bullion it stores in its vault, and thus the time it would have taken to get “total gold holdings” up to May 26 (to synchronize the dates) would be the time it takes to send a fax. Clearly, the fund's Sponsor (none other than the “World Gold Council”) refuses to provide synchronized dates, to make it impossible to ascertain the amount of “dilution” in the fund, or (alternately) the precise “premium” which new unit-holders are paying when they buy in.

Similarly, if this fund were really the simple “trust” which it pretends to be, it would have been very easy for the Sponsor to say that the “objective” of the Trust was to provide “a cost-effective investment in gold” for unit-holders, but the fund deliberately avoids any such language. Instead, it defines the Trust's “investment objective” as merely to “reflect the performance of the price of gold bullion”.

It then immediately goes on to say:

“The Sponsor believes [emphasis mine] that, for many investors, the Shares represent a cost-effective investment in gold.”

The choice of wording here is enormously important, given that in the preceding page of the prospectus, the word “believe” is expressly designated as a “forward-looking statement”. It then says that with respect to all such “forward-looking statements” that:

“They are only predictions. Actual events or results may differ materially.”

Given my background, I fully understand the necessity of including such legal “weasel words” with respect to any statements made in the prospectus concerning future developments in the gold market, such as the price of gold itself. However, with respect to the current holdings in the fund, how can the Sponsor merely “believe” that units represent “ investment in gold”?

Defenders of this ETF will argue that the Sponsor's “belief” is with respect to “a cost-effective investment in gold”, and thus the Sponsor is unable to warrant that GLD will be “cost-effective”. However, insertion of the words “cost effective” is totally voluntary. The only “warranty” which the Sponsor has chosen to provide (i.e. the “investment objective”) is that the fund will “reflect the performance of the price of gold bullion”. Whether or not there is (actually) any gold in this fund is merely a “belief” of the Sponsor, and thus may not be relied upon by unit-holders.

To provide a hypothetical example, suppose that the “custodian” for the fund (the notorious bullion-short, HSBC bank) has done extensive research and found that the price of chickens tends to be almost precisely correlated with the price of gold (i.e. they closely track each other). Given that HSBC has other things it would like to do with its gold (such as dumping bullion onto the market, or backing its massive short position), it decides that instead of going to all the bother of acquiring and storing such a massive quantity of gold that it will buy and hold chickens instead.

While much bulkier than gold, the “storage costs” associated with stationing a sleepy, security guard outside the freezers of a few meat-packers certainly cannot compare with the overhead of managing a bullion-vault capable of storing billions of dollars worth of bullion, not to mention the logistical costs associated with transporting (and insuring) all the bullion being bought and sold by this massive fund.

Critics will scoff at my hypothetical example as being too absurd to be of any analytical value, since if GLD was actually holding chickens instead of gold, then the Sponsor would be sued, and/or the “custodian” of the fund. This brings us to the second “sin”.

2) Damages:

Even without reading the prospectus, I have warned unit-holders that if there was some fraud or default associated with the fund, that all that unit-holders would ever be able to recover from the fund is “paper”. In other words, they could sue to get their (paper) money back, but they could never sue to force the Sponsor (and/or “custodian”) to provide them with the gold they thought they had bought. Such a legal remedy is known as “specific performance”, and (under the best of conditions) is a relatively rare outcome to any civil action.

Given this underlying reality, the language used in the Prospectus to protect the Sponsor and the “custodian” (HSBC) from liability can only be characterized as “over-kill”. Not only does the document seek the normal waiver with respect to “acts of God”, “war”, or “terrorism”, but it also seeks to indemnify both the Sponsor and custodian from “fraud”, “negligence”, or “willful default”.

Specifically, even under the worst acts of malfeasance, investors could never recover anything other than the “market value” of their holdings (i.e. paper money) as of the day the fraud was discovered, or default occurred. While (to some extent) language like this is common in such legal documents, we must attach considerable importance to the deliberate choice of the words “willful default”, rather than just the generic term “default” - which most reasonable readers would assume would imply some involuntary event.

Instead, if HSBC defaults on its custodian agreement, and even if it actually did have enough gold currently in its possession to cover its obligation, it could simply refuse to turn over the gold it held. Suddenly, my example of the hypothetical chickens doesn't sound quite so preposterous. In the event of a willful default, it could liquidate its chickens to cover its “custodian agreement”, keep all its gold – and unit-holders could do nothing.

3) Structure:

GLD does not sell its “shares” directly to unit-holders. I hesitate to use the word “shares” to describe these units (despite how the Trust does so again and again) because the Prospectus clearly states on many occasions that unit-holders do not possess many of the rights of a normal shareholder. It is hard not to construct the analogy that GLD sells “shares” that aren't really shares, as an equitable interest in “gold” that isn't really gold.

Beyond that, GLD has chosen to market its shares exclusively in “baskets”, with each basket having a current market-value of over $10 million. Only those institutions capable of buying these $10 million “chunks” of units are able to directly retail them to the general public. This seems like a deliberate device for steering most of the commissions for the purchase of these units to big-banks. Presumably, smaller institutions could (in turn) pick up smaller blocks for themselves – but only from the big banks (who presumably take a “cut” for themselves at that point).

This needless injection of extra banker commissions is clearly a cost which must ultimately be passed along to unit-holders – despite the appearance that GLD is the “cheapest” way to buy/own “gold”, and brings us to our next “sin”.

4) Fees:

As stated earlier, the Sponsor of GLD certainly wants to create the appearance (or “belief”) that GLD is a “cost-effective” means for investors to buy/hold gold. Media talking-heads and a legion of investment shills depict each unit as representing 1/10 ounce of “gold”, making the administrative fees of the fund appear to be near-zero. Indeed, I have referred to that outward facade as yet another reason to doubt the legitimacy of the fund. However, the truth is that no one (outside of the fund) can ascertain the precise quantum of fees, due to lack of transparency.

It is here that we come to another inexplicable “reality” with this fund: ever-increasing administrative costs. Keep in mind that the entire purpose in designating one of the largest offenders in gold-manipulation as “custodian” for this supposed hoard of bullion is “economies of scale”. If you're going to hire the fox to guard the hen-house, then at the least the fox should give you a better rate (per hen) as the flock that it is “guarding” grows larger. This is not how GLD operates.

It explicitly states that (over time) the gap between the 1/10 ounce of “gold” per unit which it is purported to hold, and the actual amount of “gold” actually held by unit-holders will steadily increase. This makes no sense. Indeed, the only justification for having a “custodian” hold the Trust's “gold” is that it should minimize administrative costs.

If the fund were “actively managed”, that is, if it was continually active in the gold market buying and selling gold to look to capitalize on imbalances/opportunities which occasionally present themselves, then it would be understandable how administrative costs would/could increase over time as the fund grew larger. However, the Prospectus explicitly states that the fund is not “actively managed”. Given that, in even a worst-case scenario per-unit administrative costs should be flat, but more likely “economies of scale”should operate to reduce those per-unit costs.

This leads to one of two implications. Either the Sponsor or (more likely) the custodian simply plans to “skim more off the top” for itself each year, or the “gold” in HSBS's vault is “evaporating”, causing the actual amount of “gold” held by unit-holders to steadily decrease over time. What should greatly alarm current unit-holders is that the long-term (guaranteed) rise in administrative “costs” is currently being hidden for the first seven years of this fund's existence, because there is a “cap” on those fees. When this seven-year period expires on November 11, 2011 (or the 11th day, of the 11th month, of the 11th year) we can only refer to this event as...

5) “D-Day”:

Readers can choose what they want the “D” in “D-Day” to represent, with my own suggestions being “default” or “destruction”. Indeed, the deliberate choice by the Sponsor of such a memorable date for termination seems to indicate that they expect this date to represent a dramatic event in the evolution of this fund.

Given that there is no economic reason for the Trust to incur ever-increasing costs, the fund is essentially being “managed” according to “principles” very similar to those of a Ponzi-scheme. Specifically, only those buyers who get in (and get out) early are able to extract their undiluted gains in this fund, with later buyers receiving less “gold” when they buy in, and even less than that when they subsequently dispose of their units.

Given the deliberate lack of transparency of the fund, the price-gouging fee structure, and the clear warning to unit-holders that “all bets are off” when the 11th day of the 11th month of the 11th year arrives, surely even those unit-holders who have remained oblivious to the many reasons to question this fund won't be reckless enough to continue to hold those units until “D-Day”?

6) Quality:

By now, every investor even pondering investing in gold bullion has heard the rumors of “tungsten-filled” gold bars being littered about various gold vaults around the world. What is the attitude of GLD's Sponsor and custodian regarding this rumor? To sum it up in three words “ignorance is bliss”. Neither the Sponsor or custodian will guarantee that any of the “gold bars” it claims to possess today are legitimate, despite the fact that such testing is both relatively quick and easy. (Of course, if GLD is actually holding chickens instead of gold, then “testing” for tungsten-fillings would be totally unnecessary).

7) Custodian:

The World Gold Council, who “sponsors” GLD is itself an association which primarily represents the world's largest gold-miners, who founded and funded it. As I have written previously, these mining companies have a “long relationship” with the handful of “bullion banks” in the world – in much the same manner that victims of serial child-abuse often have “long relationships” with their abusers.

Given that “checkered” past, and given that a close examination of the fund reveals that there are no long-term economic benefits in entrusting $10's of billions of investor dollars to the promises of bankers (see “Morgan Stanley Pays Damages for Precious Metals Fraud”), the choice of the world's largest “shorter” of gold as “custodian” for this fund is nothing less than Machiavellian. Indeed, it follows the pattern of abuse-victims in giving their abuser additional opportunities to commit further crimes.

While I hope that my analysis of the GLD prospectus can help investors to avoid the obvious dangers of this fund, it really shouldn't be necessary. This is a document which screams caveat emptor (“buyer beware”) in almost every paragraph. We already know that a “fox” has been put in charge of the “hen-house” - and for all we know that “hen-house” may (in fact) actually hold nothing but hens.

Comments (21)Add Comment
Jeff Nielson
written by Jeff Nielson, August 03, 2010
Sssd, I stress in my commentaries that the "physical" bullion we are accumulating is "insurance" in the most-literal sense of the term. In a recent commentary, I suggested that (long-term) people should be thinking about "spending" rather than "selling" their bullion.

(see "Preventing Your Government From Stealing Your Gold" http://www.bullionbullscanada....Itemid=131)

If what you REALLY want to do is TRADE gold, rather than accumulate bullion as "insurance", then you have to stay with "paper gold", since it is much too cumbersome (and expensive) to "trade" the actual metal.

On the other hand, for all the "traders" out there, why risk trading in risky vehicles like GLD, when there is (literally) more than a hundred gold miners to choose from, at various stages of development, providing a near-infinite selection in risk and leverage?

You get "natural leverage" with the miners - without having to use margin, or other risk-increasing strategies which ARTIFICIALLY increase leverage.

"A Novice's Guide to Precious Metals, Part II: the miners"
written by sssd, August 03, 2010
Great info., would love to buy physical gold but can we have an article on how to sell for spot? seems like that's the biggest problem with the "real" stuff. Any suggestions?
Jeff Nielson
written by Jeff Nielson, July 17, 2010
Sorry Alpha but I'm not familiar with how Soros has handled his gold investments.
written by alpha, July 16, 2010
I believe GLD is the ETF in which George Soros has invested heavily, and from whom the ETF has derived much credibility. Has anyone ever had any comments on that endorsement?
Jeff Nielson
written by Jeff Nielson, July 11, 2010
Sorry, Beach Bum - sometimes you focus upon one aspect of a question to a degree which causes you to forget the other parts.

With respect to damages, this is the entire problem with ANY fund which has a "custodian" (i.e. a third-party with no DIRECT ownership-interest in the fund). As I said in the commentary, judges are ALWAYS very reluctant to demand "specific performance" (i.e. forcing the custodian to produce the amount of gold supposedly being held).

What this means is that damages can NEVER be written in a way which will protect investors - other than simply giving their paper back to them. This is the fundamental problem with bullion-ETF's or even "allocated" gold accounts. If the party holding YOUR gold defaults, it's almost certain that all you will ever get back is paper.

However, what makes GLD especially bad is how it deals with the issue of liability - where it expressly allows the custodian to engage in "willful default" (simply REFUSING to honour its contract). The one situation where a judge MIGHT order "specific performance" with respect to a custodian agreement is when its known that the custodian is holding enough bullion to honour the contract, but simply doesn't want to.

For a WILLFUL breach of contract, no responsible party would/should EVER enter an agreement which permits the other side to simply "walk away" from the deal anytime, for any reason - and the offender only has to refund the PAPER which was originally invested.

In fact, in such situations of "willful default", "punitive damages" are nearly automatic - for obvious reasons: contract law is intentionally designed to encourage compliance with contracts and to CERTAINLY punish those parties who refuse to honour their agreements.

Beach Bum
written by Beach Bum, July 11, 2010
Jeff, my question specifically related to your #2 problem with GLD. How could they have written the liability and damages section to avoid your worries about it.
I'm not so worried about their listed fund "objectives". I understand they have to use the legal "weasel words" to cover their butts. That's the fault of the legal system, as you state.
Jeff Nielson
written by Jeff Nielson, July 10, 2010
I'm afraid we have only the LAWYERS to blame for the length and complexity of documents.

Here's how this devolution of contractual language occurs. A lawyer originally drafts a document using normal, understandable English. Then, 100 other lawyers start some kind of litigation based solely on trying to twist the plain meaning of the original words.

Out of those 100 lawyers, 10 will be successful. And thus the NEXT time a similar document has to be drafted, it will be ten times as long (lol). And THEN 100 lawyers will start some litigation involving the NEW contractual language - and the whole legal "merry-go-round" starts again, with the lawyers getting paid MORE each time the contract gets longer.

The lawyers are ALMOST as good at "wealth extraction" in our societies as the bankers. Compared to those two groups, doctors are a distant third.
written by Grumley, July 10, 2010
"litigious" dammit
written by Grumley, July 10, 2010
Let's not forget that how we approach a contract is just as important as how we "word it". How many of our problems can be related to how letigous we have become? The US Declaration of Independence from Britain was three pages. THREE PAGES. Our new Health Care and Financial Regulation bills are each over 2,000 pages. Further how many of our grandparents would have signed a mortgage contract that was over 100 pages long and never actually revealed how much they would end up paying?

I have to believe that when the dust settles, the collapse has to return us to a more accountable mentality. Continuing to allow people and corporations to escape responsibility by use of legal loop holes is just as "morally" unsustainable as our current financial system is mathematically.
Jeff Nielson
written by Jeff Nielson, July 10, 2010
That's certainly a fair question.

When the "investment objective" was stated, that should have been an UNEQUIVOCAL statement of GOLD OWNERSHIP, not some weak B.S. about merely tracking the PRICE of gold. Thus instead of the statement that "the Trustee BELIEVES this fund represents a cost-effective investment in gold", it should have read as follows:

"The investment objective is to provide OWNERSHIP of gold for unit-holders. The Trustee BELIEVES this fund represents a cost-effective option to hold gold."

In other words, the only place where unit-holders can tolerate a mere "belief" (which the fund clearly states they CANNOT rely upon) is with respect to GLD being "cost-effective" - since the fund managers cannot KNOW that GLD will be the lowest-cost choice for owning gold.

What cannot be tolerated by unit-holders is that the "investment in gold", itself is a mere "belief" of the fund managers, and may not be relied upon by investors.
Beach Bum
written by Beach Bum, July 10, 2010
Jeff, given the problems you cite with #2 Damages, how would you, with your legal background, have written the prospectus to better protect the average investor as it relates to willful default, fraud and negligence. It seems that the GLD language is fairly standard with regards to those items, but there must be a better way.
written by mikem54321, July 10, 2010
techperson-- I assume it is you that stated, "GLD is audited by Deloitte & Touche. Gold is counted twice a year; every bar at fiscal yearend, and a statistically random count in the spring, with the Trustee records reconciled to the Custodian records and to the physical gold bars. The count is done by Inspectorate International Limited. No anomalies were found."

Can you supply some verification links to these statements please? Thanks in advance. --Mike
Jeff Nielson
written by Jeff Nielson, July 09, 2010
Nice to see you HERE, HA65MPH!
written by HA65MPH, July 09, 2010
GOOD AS ALWAYS JEFF !...smilies/smiley.gif
Jeff Nielson
written by Jeff Nielson, July 08, 2010
Hockmir, I don't have a problem with the miner-ETF's, in fact I think they are a great vehicle for those investors who want exposure to the miners (since they provide natural leverage on the price of gold), but who are not (yet) familiar with these companies.

That said, I have a definite preference for junior producers (since there are less hedge-book "surprises") so I would recommend GDXJ ahead of GDX. Indeed, with the juniors you NEED to hold a basket (as Hockmir already has done), while with the large caps, you SHOULD be more selective - since there are definitely companies to steer away from among the large caps.
written by hockmir, July 08, 2010
Following one step further into the logic of this discussion, I have decided to sell my GDX and GDXJ holdings. Just as GLD is alleged to provide a surrogate to owning the physical metal, GDX and GDXJ ETF's are alleged to provide a surrogate to owning Miners or Junior Miners. As I already own a basket of Miners and Juniors anyway, I will be redistributing the funds that I had in GDX and GDXJ directly into some other Gold and Silver issues.

Its not a bad time in the swing of the the market to do this anyway.
Jeff Nielson
written by Jeff Nielson, July 07, 2010
Techperson, please explain to everyone here why the TRUSTEES of this fund have entered into a "custodian agreement" with HSBC which makes provisions for a "willful default" by that bankster.

If I ever held units in a bullion ETF, it would be in one where the Trustee(s) is more concerned with protecting unit-holders than their bankster buddies.
written by techperson, July 07, 2010
Jeff, this silliness is beneath you. Trying to find bogeymen in boilerplate legal language is goofy. The only serious question is: Is the gold there, allocated, numbered, in the vault, counted and audited? The answer, as you know, is absolutely yes.

All the gold bars in GLD are allocated and in a London facility. The GLD prospectus says: “The gold bars in an allocated gold account ar specific to that account and are identified by a list which shows, for each gold bar, the refiner, assay or fineness, serial number and gross and fine weight. Gold held in the Trust’s allocated account is the property of the Trust and is not traded, leased or loaned under any circumstances.”

GLD is audited by Deloitte & Touche. Gold is counted twice a year; every bar at fiscal yearend, and a statistically random count in the spring, with the Trustee records reconciled to the Custodian records and to the physical gold bars. The count is done by Inspectorate International Limited. No anomalies were found.

So in order for there to be a shortage of physical gold in GLD, all of the following would have to be in cahoots:

State Street Global Markets, the sponsor
Bank of New York, the Trustee
HSBC, the Custodian
Inspectorate International, the inventory counter
Deloitte & Touche, the auditor
And a couple of law firms, I’m sure

Tell me again why you are worried about “paper” gold?
Jeff Nielson
written by Jeff Nielson, July 07, 2010
Thanks for the comments. Yes, GATA has been very supportive in publishing our material - and we definitely appreciate the exposure we get there.
written by KKPSTEIN, July 07, 2010
Nice one Jeff - This was just featured on GATA's site.
written by Grumley, July 07, 2010
Excellent breakdown Jeff. Thank you for taking the time for those of us without a legal background. I shudder at the thought of what lies ahead for these poor "shareholders".

Two words of advice: BAT CAVE

Write comment
You must be logged in to post a comment. Please register if you do not have an account yet.


Latest Commentary

  • 1
  • 2
  • 3
  • 4
  • 5
  • 6
  • 7
  • 8
  • 9
  • 10
  • 11
  • 12

Latest Comments

Disclaimer: is not a registered investment advisor - Stock information is for educational purposes ONLY. Bullion Bulls Canada does not make "buy" or "sell" recommendations for any company. Rather, we seek to find and identify Canadian companies who we see as having good growth potential. It is up to individual investors to do their own "due diligence" or to consult with their financial advisor - to determine whether any particular company is a suitable investment for themselves.

Login Form