Arca Review 2026: ArCoin Fees, Redemptions and Why Its Adviser Owns 91%
Arca's Treasury fund was the first SEC-registered fund to issue its shares as tokens, and its aggregate token supply has matched the share count the fund reports within half a share at every semiannual date AltStreet checked. Six years after launch the fund held $451,341, and its own adviser owned 91.53% of the shares at the latest disclosed ownership date, April 1, 2026.

No platform response on record for this review. Is this your platform? Respond or claim it.
What the data actually shows - TL;DR
The Arca U.S. Treasury Fund is an SEC-registered interval fund that holds Treasury bills and issues its shares as ArCoin (RCOIN), an Ethereum token, to U.S. investors from $1,000. It launched on July 6, 2020 as the first registered fund to issue shares as digital securities.
Read the full assessmentShow less
At June 30, 2026 it held $451,341 of net assets; its adviser owned 91.53% of the shares on April 1, 2026, so outside holders had about $38,000 in it (AltStreet arithmetic), and new share sales were $2,300 in 2025. The net expense ratio is 0.78% against 95.56% gross (prospectus, May 1, 2026): the adviser caps covered expenses at 0.75% through April 30, 2027 and paid $1,376,941 of them in 2023 to 2025 while waiving fees of $190 to $217 a year. Aggregate token supply matched the fund's reported shares outstanding within half a share at every semiannual reporting date AltStreet checked.
Repurchase demand has been light: $2,072 in 2025 and zero in the first half of 2026. The prospectus describes trading on the Securitize Markets ATS since June 2024, while the November 2, 2026 repurchase notice says no secondary market exists. Arca's private business is larger: Arca Investment Management reports $188.1 million of regulatory assets under management (Form ADV, November 4, 2026) across crypto funds for qualified purchasers, including two BlockTower funds folded in on April 30, 2025. Those funds publish no terms or results.
Arca U.S. Treasury Fund net assets at June 30, 2026, six years after launch; the prospectus says the fund estimates it 'needs to raise $100 million' (N-CSRS; prospectus, May 1, 2026).
Share of the fund owned by its adviser, Arca Capital Management, on April 1, 2026; trustees and officers own 0% (SAI). On that date the largest ArCoin wallet also held 91.53% of on-chain supply (AltStreet arithmetic).
Expenses the adviser reimbursed in 2023 to 2025 to hold covered expenses at the 0.75% cap (0.78% net against 95.56% gross in the May 1, 2026 prospectus), against advisory fees of $190 to $217 a year, all waived (SAI; AltStreet arithmetic).
Largest gap between aggregate on-chain ArCoin supply and the shares outstanding the fund reports, at every semiannual date AltStreet checked, December 2020 to June 2026 (archive eth_call against N-CSR and N-CSRS).
Regulatory assets under management reported by Arca Investment Management, the adviser to Arca's private crypto funds, across 8 accounts (Form ADV Item 5.F, November 4, 2026, adviserinfo.sec.gov/firm/summary/298298); the Treasury fund adviser reports $32.8M.
Fund figures are from the audited annual reports, the June 30, 2026 semiannual report and N-PORT filings. On-chain figures are AltStreet's reads of Ethereum at block 26,413,707 (November 14, 2026). Wallet ownership is not identified by AltStreet; the transfer agent's records, not the chain, are the fund's official register.
Quick Verdict
Is this platform right for you?
Arca's registered Treasury fund does what its prospectus says: it holds Treasury bills, its aggregate token supply matched its reported shares outstanding within half a share at every semiannual date AltStreet checked, it offers monthly repurchases and its audits are clean. It is also about $451,000 in size, 91.53% owned by its adviser and kept at a 0.78% net expense ratio by an adviser subsidy of about $400,000 to $500,000 a year, and its repurchase notices still say no secondary market exists while its prospectus describes ATS trading. Arca's larger business, private crypto funds for qualified purchasers, discloses little beyond Form ADV.
Best for
- Small investors who specifically want a registered Treasury fund held as an Ethereum token and accept that it may be closed or changed.
Avoid if
- You want a tokenized Treasury fund with real outside scale.
- You need assurance the 0.78% net cost will last beyond April 30, 2027.
- You want published terms and results for a crypto fund.
Top strengths
- SEC-registered, Treasury-only, audited by RSM US every year with no qualified opinion.
- Aggregate on-chain supply matched reported shares within half a share at every semiannual date checked since 2020.
- Monthly repurchase offers never oversubscribed; no disciplinary record or lawsuit located.
Key limitations
- $451,341 of net assets, 91.53% adviser-owned.
- A 95.56% gross expense ratio carried by the adviser under a cap renewed yearly.
- Site and repurchase notices contradict the prospectus on the secondary market and other points.
- Private funds publish no terms or results.
Compare Before Deciding
Where Arca fits against alternatives
Use these hooks to pressure-test whether this is the right platform, or whether a nearby alternative matches the job better.
How this compares to Securitize Review
Securitize Review
Arca's transfer agent, token developer and ATS operator.
How this compares to Franklin Templeton Benji Review
Franklin Templeton Benji Review
A larger registered fund with on-chain shares.
How this compares to Superstate Review
Superstate Review
Tokenized Treasury funds for qualified purchasers.
Quick Answers
What most investors want to know first
The highest-signal facts first: minimums, liquidity reality, K-1 timing, and whether distributions are actually part of the experience.
Liquidity
An ATS exists; no public prices and no trade data located.
K-1 Timing
Not applicable (Form 1099).
Distributions
Last business days of March, June, September and December, visible on chain as clusters of small mints.
Overview
Platform Overview
A concise read on what the platform is, how the structure works, and where the practical friction shows up for real investors.
Arca was founded in 2018 in Los Angeles by Rayne Steinberg (CEO; his bio says he co-founded WisdomTree) with partners including Jeff Dorman (CIO) and Phil Liu (Chief Legal Officer). It has two SEC-registered advisers. Arca Capital Management, LLC (CRD 305964), owned by Arca Labs, LLC, advises the Arca U.S. Treasury Fund and a private Arca Institutional U.S. Treasury Fund ($32.8 million of regulatory assets).
Arca Investment Management, LLC (CRD 298298) advises the private crypto funds: a liquid token master fund ($119.6 million) with four feeders, two of them former BlockTower funds, an NFT fund, an early-stage venture fund and their offshore parallels ($188.1 million of regulatory assets). Praesidium Holdings, Inc., a privately held Delaware corporation formed in 2024, owns both; neither Form ADV names an individual 25% owner. Arca Labs is also the Treasury fund's blockchain administrator, and Securitize runs the token's smart contracts, its transfer agent record and the ATS where it trades.
The prospectus says Arca and its affiliates managed about $243 million at December 31, 2025; the two advisers' Form ADVs report $220.9 million of regulatory assets together. RSM US LLP audits the Treasury fund, UMB Bank holds its custody, Ultimus administers it and Securitize keeps its share register.
Who can buy
Treasury fund: U.S. persons from $1,000, no accreditation, ACH or wire only (no crypto). Private funds: qualified purchasers, $100,000 to $5 million minimums.
Treasury fund size
$451,341 (June 30, 2026); 91.53% owned by the adviser (April 1, 2026); 25 wallets on chain.
Costs
0.78% net (0.75% cap plus 0.03% acquired fund fees) against 95.56% gross; cap until April 30, 2027.
Returns
4.02% (2025), 5.03% (2024), 5.26% (2023); 2.80% a year since July 2020, after the waiver.
Liquidity
Monthly offers of 5% or 6% at NAV; Securitize Markets ATS since June 2024; peer to peer between whitelisted wallets.
Token
RCOIN, ERC-20 on Ethereum (DS Protocol); aggregate supply matched reported shares outstanding within 0.5 share at every semiannual date checked.
Regulatory
Two SEC-registered advisers; no disciplinary disclosures; no lawsuit against Arca located.
Visual Summary
Arca's funds
Gross assets from the advisers' Form ADV Schedule D (August 25 and November 4, 2026); Treasury fund net assets from the June 30, 2026 semiannual report. Master and feeder gross assets overlap: the master's figure includes what its feeders invest in it. Form D figures are cumulative sales, not current assets.
Arca U.S. Treasury Fund (ArCoin)
Adviser
ACM
Assets
$451K
Owners
32 investors (2025)
Minimum
$1,000
Status
Open
Institutional U.S. Treasury Fund
Adviser
ACM
Assets
$32.3M
Owners
about 11 (98% Arca)
Minimum
$100,000
Status
Open
Digital Assets Master Fund
Adviser
AIM
Assets
$119.6M
Owners
4 feeders
Minimum
n/a
Status
Active
BlockTower feeders (2)
Adviser
AIM
Assets
$57.6M
Owners
350
Minimum
not stated
Status
Active
Arca Endeavor Fund
Adviser
AIM
Assets
$31.7M
Owners
102
Minimum
$500,000
Status
Active
Arca NFT Fund and offshore
Adviser
AIM
Assets
$33.6M
Owners
247
Minimum
$500,000
Status
Active
Investor Operations
The practical questions investors actually care about: when tax documents arrive, how cash distributions work, and whether capital can be exited before the underlying asset is sold.
Tax Documents
K-1 Timing
What to expect
Not applicable (Form 1099).
Cash Flow
Distributions
Frequency
Quarterly.
Timing
Last business days of March, June, September and December, visible on chain as clusters of small mints.
Consistency
Follows Treasury bill yields; 30-day SEC yield 2.63% as of October 31, 2026 per the site.
Liquidity
Exit Reality
Holding period
None.
Exit options
- Monthly repurchase offer at NAV.
- Sale on the Securitize Markets ATS.
- Peer-to-peer transfer to another whitelisted wallet.
Secondary market
An ATS exists; no public prices and no trade data located.
Investment Structures
Arca U.S. Treasury Fund
Registered interval fund of Treasury bills issued as RCOIN; monthly repurchase offers of 5% or 6%.
Institutional U.S. Treasury Fund
Private 3(c)(7) Treasury fund from July 2025, $100,000 minimum, marketed by tZERO Securities.
Liquid token strategy
Arca Digital Assets Master Fund and four feeders, including two BlockTower funds.
Venture and NFT funds
Arca Endeavor Fund; Arca NFT Fund and its offshore parallel.
Proposed money market fund
Arca U.S. Treasury Money Market Digital Fund, not effective.
Risk
Risk Structure
This is where the marketplace pitch gives way to the actual operating reality: delayed exits, limited disclosure, fee drag, and path-dependent outcomes.
Claim
Shares of a registered fund holding Treasury bills; the token is the share, and the transfer agent's register is the legal record.
Scale
About $451,000 of net assets; the 2025 gross expense ratio was 95.53% before the adviser's reimbursement.
Control
Transfer agent can freeze, revoke and reassign tokens; the token proxy is owned by one externally owned account and its implementation is unverified.
Liquidity
Monthly offers of 5% to 6% required by fundamental policy; ATS trading with no public prices.
Private funds
Crypto exposure with terms, fees and results not public; qualified purchasers only.
Subsidy dependence
The 0.78% net expense ratio holds only while the adviser keeps paying expenses of about $400,000 to $500,000 a year under its cap.
Why it matters
Without it, costs would consume the fund's income many times over.
Mitigation / verification
Check each May prospectus for the cap's new end date.
Fund closure
A fund this small and this owned by its adviser could be closed or reorganized by the board.
Why it matters
Holders would receive NAV in cash, ending the token position.
Mitigation / verification
Watch for a supplement, proxy or N-8F filing.
Token administration
Administrator powers and an upgradeable, unverified implementation.
Why it matters
Ownership is governed by the transfer agent's records whatever the chain shows.
Mitigation / verification
Ask for verified source and the proxy owner's controls.
Stale site information
Several pages contradict the current prospectus.
Why it matters
A buyer relying on the site would read the wrong expense ratio, bank and secondary market status.
Mitigation / verification
Use the prospectus and the filed reports.
ASRisk signals to watch
- The May 2027 prospectus: expense cap, adviser ownership and the $100 million line.
- ArCoin supply and holder count (AltStreet refreshes them daily).
- A burn of the 5,523.55 units moved on October 19, 2026 after the November 16 offer.
- Effectiveness of the Arca Open-End Fund Trust and an order on 812-16050.
- Any new Form D or Schedule D change for the private funds.
Regulatory & Legal Posture
Security Status
Registered closed-end interval fund under the Investment Company Act of 1940 (811-23392); private funds under Section 3(c)(7) and Rule 506(c); two SEC-registered investment advisers.
The Treasury fund files the full 1940 Act record (prospectus, audited annual reports, semiannual reports, N-PORT, N-CEN, monthly N-23C3A repurchase notices). Its shares are digital securities: the 2020 staff correspondence shows the SEC required the transfer agent's records to be stated as the official register and asked for plain language that the fund 'will not invest directly or indirectly in digital assets'. The private funds file Form D notices under Rule 506(c); Form D figures are cumulative sales at the filing date.
- Exemptive orders: monthly repurchase offers (Release No. 34055, October 20, 2020; amended Release No. 34952, June 28, 2023).
- Pending or unresolved: joint insurance application with Arca Insurance Company Limited, Bermuda (812-15400, 2022); dealer relief for the proposed money market fund (812-16050, 2026).
- Arca Investment Management says it relies on CFTC exemptions for commodity pool and trading adviser activity (Part 2A, March 31, 2026). NFA BASIC (November 14, 2026) lists Arca Capital Management LLC (NFA ID 0531675) as an exempt commodity pool operator and exempt commodity trading advisor, not an NFA member, with no regulatory actions, and Arca Labs LLC (NFA ID 0572926) with no registration and no regulatory actions. AltStreet found no NFA BASIC record for Arca Investment Management, the adviser whose brochure states the reliance; which exemptions it relies on is an open question.
- Courts: no suit against an Arca entity located on CourtListener (November 14, 2026); PACER, state courts and offshore courts not searched directly.
Disclosure Quality
Full statutory disclosure for the registered fund; none beyond Form D and Form ADV for the private funds.
Custody Model
UMB Bank, N.A. custodies the Treasury fund's assets; Securitize keeps the share register and runs the token; private crypto funds use Anchorage Digital, Coinbase Prime, Copper, Fidelity Digital Assets and others.
Regulatory Backing
SEC (advisers and the registered fund); Securitize Markets is a FINRA member broker-dealer; Securitize Transfer Agent is an SEC-registered transfer agent.
Tax Treatment
Reporting
Form 1099 for the Treasury fund (FAQ); private funds not stated.
Annual.
Income Character
Questions to put to the fund and a tax adviser
The fund is a regulated investment company distributing Treasury bill income quarterly and reinvesting it by default.
Limitation
AltStreet is not a tax adviser.
Account Suitability
Taxable
Distributions are taxable when paid, reinvested or not.
Roth IRA
IRA availability was removed from the registration statement in June 2020 (SEC staff correspondence); confirm with the fund.
Traditional IRA
As for Roth IRAs; confirm with the fund.
HSA
Not stated.
Before You Invest
Get AltStreet's weekly briefing on Arca and its peers
Changes to fees, liquidity and investment terms across alternative platforms, including Arca, read against the filings. One email a week.
- Weekly platform research focused on tax timing and liquidity reality.
- Signals on distributions, risks, and structural tradeoffs before capital is locked up.
- Coverage of adjacent platforms so you can compare better options faster.
Get weekly platform signals
Track fee changes, liquidity updates, risk flags, and adjacent platforms before you invest.
Independent intelligence from AltStreet. No hype. No sponsor spin.
AltStreet Data Layer
What the data actually shows
What the filings and the chain show.
Outside subscriptions remained small
Net assets grew from $123,631 (2020) to $451,341 (June 2026); the largest inflow was a $250,000 purchase in January 2022, and new share sales were $2,300 in 2025.
What this means
The fund's growth since 2022 is mostly reinvested income on the adviser's stake.
Supply matches reported shares
Aggregate on-chain supply within 0.5 share of reported shares outstanding at every semiannual date AltStreet checked since December 2020, including through the 2021 contract migration.
What this means
Aggregate supply tracked the register at every date checked; the transfer agent's records remain the legal record of ownership.
One wallet
On April 1, 2026 the largest wallet held 91.53% of supply, the adviser's SAI percentage that day; on November 14, 2026 it held 91.32% of 455,428 units, and the top five wallets 95.52%.
What this means
A matching percentage on one date, not an identification of the holder.
Repurchase demand light
$2,072 repurchased in 2025 and $0 in the first half of 2026 across monthly offers of 5% or 6%.
What this means
Liquidity has never been tested at this size.
Data as of 2026-11-14 . AltStreet review evidence layer . Public-source analysis
Full datasetDecision Fit
Investor Fit
Who this works for, who it does not, and what level of patience and complexity tolerance the platform really demands.
Investors who want to hold a registered Treasury fund as an Ethereum token
It works as described and reconciles on chain, but the fund is about $451,000 and depends on its adviser's subsidy.
Investors seeking the cheapest or largest tokenized Treasury fund
Larger tokenized funds exist with far more outside holders; this one's net cost holds only under the cap.
Qualified purchasers looking at crypto hedge or venture funds
Audited, outside-administered funds with institutional custodians, but no public terms or results to judge.
Tradeoffs
Key Tradeoffs
The attraction of pre-IPO access is real, but every benefit comes bundled with a corresponding liquidity, transparency, or pricing cost.
Structure
Tiny and 91.53% adviser-owned.
Cost
Gross 95.56%; the cap is renewed one year at a time.
Liquidity
No public ATS prices; site and notices still say there is no secondary market.
Avoid
Who This Is Not For
This section should be read as a filter, not an afterthought. If you need income, simplicity, or near-term access to capital, the structure is working against you.
Investors who want a tokenized Treasury fund with many outside holders
Outside holders own about $38,000 of this one.
Investors who rely on the issuer's website for current terms
Several pages contradict the current prospectus.
Editorial View
AltStreet Perspective
The compressed version of the review: what matters, what marketing tends to obscure, and how we would frame the platform for a serious allocator.
Verdict
ArCoin proved that a registered fund can live on a public blockchain with aggregate token supply that matches its reported share count; it has not attracted outside money, and its economics are the adviser's subsidy. Arca's business today is its private crypto funds, which this review can describe only from their filings.
Positioning
Among AltStreet's tokenized Treasury reviews, Arca is the earliest registered fund and by far the smallest, beside Franklin Templeton's Benji funds and Superstate; it shares Securitize as transfer agent and ATS with the funds in the Securitize review.
The Bottom Line
The first tokenized registered fund, its token supply reconciled to its reported shares, and still almost entirely its manager's own money.
Action
Next Steps
If you still want to engage after reading the review, these are the practical next moves that reduce avoidable mistakes.
Read the May 1, 2026 prospectus and the latest semiannual report rather than the website tiles.
Ask Arca whether the expense cap and its own stake will continue after April 30, 2027.
Ask Securitize Markets for ArCoin ATS trade history and commission rates before relying on the ATS to exit.
Qualified purchasers: request each private fund's fees, liquidity terms and audited net returns, including the Terra/Luna period.
AltStreet Research Desk
About to invest in Arca, or in an offering we haven't covered?
Commission an independent diligence report: the same filing-based analysis behind this review, applied to the specific investment in front of you before you wire the money.
- Built from primary sources: SEC filings, court records, capital structure, and marketing-versus-filings comparison.
- From $750; full reports from $1,495. Fixed price confirmed up front, delivery in 3-5 business days.
- Independent by design: we work for investors and accept no compensation from the companies we cover.
Want this on every new deal, not one? Deal Intelligence sends the alert the day a new offering appears on a covered platform and follows with an analyst-approved investment committee memo.
Deal Intelligence →Appendix
Sources, Disclosures, and Supporting Context
The lower section is structured like a report appendix: relationship context first, adjacent reading second, and evidence last.
Report Appendix
Disclosure
Relationship and compensation context
+
Report Appendix
Disclosure
Relationship and compensation context
Report Appendix
Related Resources
Adjacent platform comparisons, frameworks, and category links
+
Report Appendix
Related Resources
Adjacent platform comparisons, frameworks, and category links
Further Reading
Related Resources
Adjacent frameworks and reviews that help place the platform in a broader allocation or due-diligence context.
Similar Platform Reviews
- Securitize Review
Arca's transfer agent, token developer and ATS operator.
- Franklin Templeton Benji Review
A larger registered fund with on-chain shares.
- Superstate Review
Tokenized Treasury funds for qualified purchasers.
- tZERO Review
The broker-dealer marketing Arca's Institutional fund.
- Stone Ridge Review
Another manager reviewed with its funds as deals.
Report Appendix
Evidence & Methodology
23 cited passages on file; sources, scope, and how the review was assembled
+
Report Appendix
Evidence & Methodology
23 cited passages on file; sources, scope, and how the review was assembled
Evidence on file
23 supporting passages on file for Arca and its offerings from 15 source documents, 6 discrepancies flagged. Each passage records the metric it supports, the value read from the document, the page, and the verbatim text where the document has it. Terminal subscribers read the passages; open them in the terminal.
- Cited passages
- 23
- Source documents
- 15
- Analyst verified
- 0
- Discrepancies flagged
- 6
ASReview Evidence
Methodology
The full EDGAR record of the Arca U.S. Treasury Fund and every Arca Form D; Form ADV Parts 1A and 2A of both advisers; BrokerCheck, IAPD and OFAC; 223 web pages and 25 fund documents with Wayback history; every ArCoin and predecessor event log, month-end archive supply and current holders on Ethereum; CourtListener and press.
Scope
The two advisers and every fund under them; the Treasury fund and its token in depth. PACER, state and offshore courts not reached.
Key Findings
- *SAI: Arca Capital Management, LLC owned 91.53% of outstanding shares as of April 1, 2026.
- *Annual report 2025: 'net assets of $443,597 across thirty-two different investors'.
- *Prospectus: the transfer agent can 'freeze, revoke and reassign ArCoins'.
- *Repurchase notice, November 2, 2026: the offer is made 'since no secondary market exists for these shares'.
Primary Source Pages
Comparable Platforms
- Franklin Templeton Benji
Registered money market fund with on-chain shares at scale.
- Superstate
Tokenized Treasury funds for qualified purchasers.
FAQ
Frequently Asked Questions
High-intent search questions answered directly, without making users hunt through the full review.
Is Arca legit?
Arca's two advisers are registered with the SEC, the Treasury fund files audited reports with the SEC, and AltStreet located no disciplinary action or lawsuit against Arca. What to weigh is the fund's size and ownership: $451,341 at June 30, 2026, 91.53% owned by Arca's own adviser, with a 0.78% net expense ratio held there by the adviser's reimbursements.
What is ArCoin?
ArCoin (RCOIN) is the share of the Arca U.S. Treasury Fund, issued as an ERC-20 token on Ethereum at 0x252739487C1fa66eaeaE7CED41d6358aB2a6bCa9. One token is one share. The fund holds Treasury bills, not crypto, and the transfer agent's records are the official register.
What does the Arca U.S. Treasury Fund cost?
0.78% a year net under the prospectus of May 1, 2026: a 0.75% expense cap plus 0.03% of acquired fund fees, against 95.56% gross. The adviser pays the difference until at least April 30, 2027 and can recoup it within three years if expenses fall below the cap.
Can I sell ArCoin?
Yes, three ways: tender in the fund's monthly repurchase offer (6% of shares a month since May 2026, at NAV, no fee), sell on the Securitize Markets ATS (commission on both sides, no public prices), or transfer to another whitelisted wallet. Repurchases have been tiny: $2,072 in 2025 and nothing in the first half of 2026.
What are Arca's private funds?
Crypto funds for qualified purchasers run by Arca Investment Management: a liquid token master fund ($119.6 million) with four feeders including two BlockTower funds, the Arca Endeavor venture fund ($31.7 million) and the Arca NFT funds ($33.6 million), per Form ADV of November 4, 2026. Their fees and results are not public.
Who owns Arca?
Praesidium Holdings, Inc., a privately held Delaware corporation, owns both advisers through Praesidium Partners and Arca Labs. Neither Form ADV names an individual 25% owner. BlockTower's liquid funds joined Arca on April 30, 2025.
Update History
What's changed in this Arca review
New data, new findings, corrections, and confirmations as they emerge. Most recent updates appear first.
- Correction
FEES: 0.78% net against 95.56% gross as the headline figures; 0.75% cap on covered expenses to April 30, 2027; 95.53% identified as the 2025 reported gross expense ratio (TL;DR, verdict, stat callouts, trade-offs, FAQ). Analysis
- Correction
ON-CHAIN: 'the chain is an accurate copy of the register' and 'its token matches its share register' replaced with the measured claim (aggregate supply within 0.5 share of reported shares at every semiannual date checked); April 1, 2026 wallet comparison kept together, November 91.32% separate. Analysis
- Correction
LIQUIDITY AND PRIVATE FUNDS: prospectus vs repurchase-notice contradiction in the summary; $60 ATS volume attributed to AltStreet's own guide; $188.1M labeled as reported RAUM with the Form ADV link; master and feeder overlap noted; NFA inference removed. Analysis
