Guide to the Duke University Currency Collection, 1746-1982
The Currency Collection contains 4896 pieces, 1746-1982, of which all except a small number of coins and tokens are paper currency. Most of this money is domestic, but there are a limited number of foreign items, some of them quite old and interesting. Approximately two-thirds of the collection dates from the Civil War and one-fourth from the antebellum period.
The collection is divided into ten main categories. They are:
A variety of elements are involved in the arrangement of the currency within the above categories. The first criterion of arrangement is geographical for the colonial, Revolutionary, Southern states, and foreign currency, and for the currency issued by banks and other corporate bodies, businesses, etc.: by states, provinces, countries, etc. The Confederate currency is arranged first by denominations: 50¢, $1, $10, etc. Part of the collection is deacidified and part is not, so some categories are divided into two sets on this basis.
Itemized lists have been compiled of all pieces of the currency, and the contents of these lists, which are not the same for all categories, are noted in the descriptions of the major categories. There are two sets of lists, one of which is kept with the collection and the other with the department's security copies of collection inventories. The lists in the security set are all filed together. Within the Currency Collection, the lists are divided, each folder of currency containing the list itemizing its contents.
The Information Folder filed in the first box includes a variety of material: information about the provenance of parts of the collection; reference sources; a copy of D. C. Wismer's "Descriptive List of Obsolete Paper Money: Part I - Embracing the Circulating Notes Issued by State Banks, Private Banks, Bankers and Corporations" for North Carolina published in The Numismatist during June-August, 1931; articles about early North Carolina currency; a poem about Confederate currency; an earlier description of the collection removed from the card catalog, etc.
The list in the Information Folder entitled "American Confederate State Bills Comprising over Eight Hundred Confederate State Bills, Confederate State Bank Notes, Confederate State Currency Notes, Private Scrip, Etc." (25 pp.) is dated August, 1949. It lists the joint collections of the late Judge Van Wart of New Orleans and of W. George Head of Wimbledon, Eng., formerly of Shelby, N.C. This list was apparently compiled by a dealer whose name is not on it. This list provides the provenance for a sizeable part of the Currency Collection. The part of the collection entitled "Currency Issued by Banks and Other Corporate Bodies," including both antebellum and Civil War issues and currency from the South and also from other states, came primarily from the Van Wart and Head collections. They also provided the sources of a sizeable part of the North Carolina State Currency issued during the Civil War.
- 1. Colonial Currency (27 items), 1746-1775
- 2. Revolutionary Currency (67 items), 1775-1780
- 3. Currency Issued by Banks and Other Corporate Bodies, Businesses, etc. (1225 items), 1815-1906
- 4. Confederate Currency (2616 items)
- 5. Southern States Currency (715 items), mostly 1861-1865, but also later and as early as 1786; 1 item added
- 6. Foreign Currency (174 items), 1771-1982
- 7. U.S. Currency (18 items), 1862-1899; 59 items added
- 8. Coins: U.S. & Foreign (63 items), 1875-1971
- 9. Tokens: U.S. & Foreign (8 items), 1812-1860's
- 10. Northern States Currency (1 item), 1786
- The Duke University Currency collection 1746-1982
- Duke University
- 4,896 Items
- Duke University. David M. Rubenstein Rare Book & Manuscript Library
- For current information on the location of these materials, please consult the Library's online catalog.
Please contact Research Services Staff to inquire about restrictions on access to this collection.
Researchers must register and agree to copyright and privacy laws before using this collection.
All or portions of this collection may be housed off-site in Duke University's Library Service Center. The library may require up to 48 hours to retrieve these materials for research use.
The copyright interests in this collection have not been transferred to Duke University. For more information consult the section on copyright in the Regulations and Procedures of the David M. Rubenstein Rare Book & Manuscript Library.
An excellent catalog of American paper currency from its inception in 1686 to 1789 is Eric P. Newman's The Early Paper Money of America (Racine, Wisc., 1967) . Newman noted the distinctiveness of this money: "The early paper money of America has the unique distinction of being the first paper money issued by any government in the Western World. No country, state, or colony in Europe had made a prior issue of publicly sponsored paper money."
This collection includes 27 examples of colonial paper currency from:
The Delaware bills are notable for having been printed by Benjamin Franklin. An undated bill for 5 shillings from North Carolina is colonial, for the state issued currency in dollars beginning in 1775. This bill is not listed in Newman. It is signed by Thomas Polk (d. 1793), one of the founders of Charlotte and a leading colonial and Revolutionary figure in Mecklenburg County and the state. Signatories of the North Carolina bills include Richard Caswell (1729-1789), first state governor and a member of the Continental Congress (currency of 1768 and 1771).
- Delaware (3), 1746-1759;
- Georgia (1), 1774;
- Maryland (4), 1767-1770;
- North Carolina (13), 1754-1771;
- Pennsylvania (6), 1769-1775.
There are 67 pieces of Revolutionary paper currency and one copper plate for printing a bill. They include the Continental Currency issued by the Continental Congress and also the Revolutionary War state issues. There is currency from:
From North Carolina there is a copper plate used for the printing of one of the $2 1/2 bills of the issue of April 2, 1776 (the bill with a vignette of a Liberty Cap over an altar). The other side of the same copper plate was used to print $5 bills of the same issue (version with vignette of a raven). Signatories include five members of the Continental Congress: William Sharpe and John Williams from N.C. and William Few, William Gibbons, and Edward Telfair from Georgia. Telfair signed the Articles of Confederation, and Few signed the Constitution.
This currency is arranged by colonies/states. Lists itemize each bill. The lists record: name of colony/state; denomination; serial letter; date; and occasional comments.
- The Continental Congress (10), 1776-1779;
- Georgia (18), 1776-1778;
- North Carolina (23), 1776-1780;
- South Carolina (14), 1775-1779;
- Virginia (2), 1777-1780.
The Continental Congress issued a great quantity of paper currency in order to finance the Revolution. The depreciation of this money and its economic effects produced a distrust of any national paper currency. For that reason the 1789 Constitution forbade the states to issue paper money. The Constitution was deliberately silent on the federal government's right to do so. However, there was no ban against their issuance by private organizations and local governments. This loophole was utilized to provide paper currency which was both convenient and necessary for economic life. Over 30,000 varieties of notes were issued by 1,600 different banks in 34 different states between 1790 and 1865. These figures do not include the issues of local governments and private businesses that were not banks. The history of this money ended substantially during the Civil War. The Confederate government and the various states of the Confederacy issued paper currency-during the war. The U.S. Congress authorized a national paper currency in 1861, and it is the only paper currency to survive the Civil War as a significant economic factor. Some currency and scrip continued to be issued at various times by businesses and local governments, but it was economically and quantitatively insignificant. It should be remembered, of course, that the federal government issued gold and silver coinage during this period.
The paper currency in this collection issued by banks and other public and private organizations and businesses numbers 1225 items dating between 1815 and 1906. Most of the money dates from 1815 into the 1860's. Every decade during this period is represented, but currency is most abundant during the 1850's and 1860's. After the Civil War there are occasional bills. See also the Raphael P. Thian Papers for a sizeable collection of this type of currency (Vols. 768 & 770).
This currency is divided into two sections, those bills deacidified and those bills not yet deacidified. There are 625 bills, 1815-1906, in the set not deacidified. Twenty-eight states and the District of Columbia are represented. They are:
Six states are represented in the deacidified set that contains 599 bills, 1861-1867. They are:
This currency is arranged by states. Lists itemize each note. The lists record: name of the state; place of origin within the state; issuing body; denomination; serial letter or number; date; note number; and occasional comments.
Banks were the principal issuers of paper currency. From the samples in this collection it appears that railroads and local governments (cities, towns, counties, etc.) were notable sources of paper money, but not in the same magnitude as the banks. A great variety of private organizations and businesses issued money including the following types and examples represented in this collection: savings and loan; insurance; building; a lyceum; mining; manufacturing; a rice mill; a cotton mill; an apothecary; mercantile stores; a furniture warehouse; a hotel; a bakery; associations of planters and mechanics; bridges; steamship companies; a tow-boat company; canals; turnpikes, etc.
Many bills are fine examples of engraving and printing. Counterfeiting was a problem. "The private banks retaliated against the counterfeiters and made the process of manufacture more and more complex by using fancier paper, more complicated designs, more watermarks, secret printing marks, indentures, marbling, laminated papers, polychrome printing, 'mice' and/or fiber inclusions, composite plates, elaborately engraved ornaments, and portraits engraved by the finest artists of the period. All these countermeasures helped to create some exceptionally beautiful notes, some surpassing in many respects our present-day currency with its more limited designs and subject matter" (Gene Hessler, The Comprehensive Catalog of U.S. Paper Money, pp. 11-12).
Vignettes used as decorative and protective illustrations on bills were commonplace. They depicted a great variety of scenes as well as portraits of men and women. Some vignettes contain idealized scenes, mythological figures, etc. Many vignettes, however, are useful historical representations because either they were intended as realistic depictions or because the generalized views of scenes and activities record past objects, places, technology, workers, equipment, agriculture, manufacturing, animals, buildings, ships, trains, bridges, etc. Some examples in this collection are: a turnpike booth and gate and a view of Stoddartsville, Pa., from Wilkes-Barre Turnpike Co., 1816; gathering naval stores, Timber Cutter's Bank, Savannah, 1861; interior of a tobacco factory, screw presses, and blacks at work, Bank of Yanceyville, N.C., 1856; agricultural and dock scenes; Natural Bridge, Virginia Military Institute, and Washington College on Bank of Rockbridge bill, 1859; Mount Hecla Steam Cotton Mills, Greensboro, N.C., 1837; etc.
The portraits of men and women in the vignettes included not only notable and historical persons but also local citizenry, in most cases probably people connected with the bank. Women of all ages appear. An especially illustrative example is a five-dollar bill of the South Western Bank of Virginia at Wytheville in 1857 which contains the portraits of two men, the bank's president and cashier, and of two women, Florence Nightingale and a relation, probably the wife, of the bank's president. This bill is not in the collection, but it may be seen in Charles J. Affleck's The Obsolete Paper Money of Virginia, Vol. II, p. 253. The portraits of women on the currency in this collection represent all ages except infancy.
This paper currency sometimes circulated at par, but most often at a discount in places distant from the point of issue. Counterfeiting was a serious problem. It was also necessary and difficult to keep up with which banks had failed. "The situation was so alarming and prevalent that for the years from 1826 to 1866 numerous periodicals called 'Bank Note Reporters' and 'Counterfeit Detectors' were published, most of them today comparatively scarce. Of the 153 titles of such periodicals noted in W. H. Dillistin's Bank Note Reporters and Counterfeit Detectors, 1949, the American Antiquarian Society has 28, more than any library listed" (Clarence S. Brigham, Fifty Years of Collecting Americana of the Library of The American Antiquarian Society 1908-1958, p. 139). Perkins Library has several examples of these publications. For example, Bicknell's Counterfeit Detector and Bank Note List, Vol. XV, No. 5, Whole No. 186 (Philadelphia, March 2, 1846), listed three closed banks in North Carolina and the bills of other banks circulating in Philadelphia at discounts of 1 1/2% and 2%. The American Antiquarian Society has an extensive collection of paper currency.
There is no single, comprehensive bibliography of this currency as there is for colonial and Revolutionary currency. The closest thing to it is a series of articles published over a period of time in The Numismatist, a journal unavailable in this library. These articles were D. C. Wismer's "Descriptive List of Obsolete Paper Money, Part I - Embracing the Circulating Notes Issued by State Banks, Private Banks, Bankers and Corporations." These articles were illustrated and contained descriptions of each variety of bill issued by an institution. The Information Folder of this collection contains a photocopy of the North Carolina section published in The Numismatist during June-August, 1931. A more extensive list of the currency of twenty-one North Carolina banks is J. Roy Pennell, Jr.'s Obsolete Bank Notes of North Carolina (Anderson, S.C., undated) of which a photocopy is filed in the Information Folder. Bibliographies are available for some states. An excellent example is Charles J. Affleck's The Obsolete Paper Money of Virginia.
See also the tokens in this collection which were also issued by private businesses as currency.
1 item added, 8-18-83. A dollar bill issued on Feb. 2, 1852, at New York City by the Hungarian Fund. It was one of the American issues of Lajos Kossuth, President of the first Hungarian Republic (1848-1849), in his attempt to raise funds for a return from exile. This note is considered to be currency; see Colin Narbeth, et al., Collecting Paper Money and Bonds (New York, 1979), p. 53.
- Alabama (4 bills), 1855-1871;
- Arkansas (2), 1861-1869;
- Connecticut (4), 1825-1862;
- Delaware (1), 1861;
- District of Columbia (16), 1844-1862;
- Florida (3), 1835-1859;
- Georgia (192), 1816-1862;
- Indiana (1), 1857;
- Kentucky (7), 1837 & undated;
- Louisiana (3), 1852-1861;
- Maine (4), 1854-1862;
- Maryland (8), 1841-1862;
- Massachusetts (31), 1863-1873;
- Michigan (12), 1835-1869;
- Mississippi (41), 1837-1861;
- Missouri (2), 1862;
- New Hampshire (2), 1837-1862;
- New Jersey (26), 1827-1862;
- New York (38), 1816-1862;
- North Carolina (91), 1837-1874;
- Ohio (4), 1839-1862;
- Pennsylvania (31), 1816-1865;
- South Carolina (54), 1826-1873;
- Tennessee (17), 1837-1862;
- Texas (7), 1862-1864;
- Utah (4), 1898-1906;
- Vermont (6), 1815-1863;
- Virginia (38), 1854-1862;
- West Virginia (4), 1852-1860.
- Alabama (5), 1862-1864;
- Florida (1), 1861;
- Georgia (479), 1861-1864;
- Louisiana (77), 1861-1867;
- Mississippi (36), 1861-1863;
- Texas (1), 1862.
The collection of Confederate and Southern states currency is very extensive, consisting of 3329 pieces. Of this total 2601 bills were issued by the national government, and 727 bills were issues of state governments. See also the Raphael P. Thian Papers for a large collection of Confederate and Southern States currency.
The standard catalog for this money is Grover C. Criswell, Jr.'s, Confederate and Southern States Currency. It is the basis for the identification and listing of the bills in this collection. A copy of this catalog is available in the Rubenstein Library. The latest edition available for use in describing this collection was the 1964 edition. The Confederate currency in this collection is divided into three categories:
The Ball Family Division was the gift of Mr. Douglas B. Ball and his father, Mr. George W. Ball, former U.S. ambassador to the United Nations, among whose family possessions this money was found. Mr. Douglas Ball, whose knowledge of Confederate currency is extensive, knew of the large collection at Duke and chose to augment it with the Balls' sizeable collection. Gifts from the Balls also made possible the deacidification work that has been done. Douglas Ball is author of the "Foreword" to the 1972 republication of Raphael P. Thian's Register of the Confederate Debt, a basic source for checking the authenticity of Confederate paper currency.
Douglas Ball had cataloged the Ball Collection in detail, its basic arrangement based upon Criswell. Ball's lists of the currency are filed with it. Ball sometimes deviated from or elaborated upon the listings in Criswell. For example, there are $20 bills, Type 58, Criswell No. 418/1 which Ball has further subdivided into undated, redrawn letters, and maroon letters. His lists also record his evaluations of the variety, rarity, condition and value of the bills. Mr. Ball's extensive cataloging and listing made it especially appropriate to maintain the Ball Collection as a separate division of the Currency Collection. Not all of Ball's lists itemize each bill, citing the number of each note. In these cases, additional lists have been made itemizing each bill and recording its number whenever legible. Thus, some groups of bills have two lists. The checkmarks beside the note numbers on the Ball lists were made by staff of the Rubenstein Library, the marks indicating that those bills are part of the Duke collection. Ball did not always list notes in strict numerical order. For example, among the $20 notes, Type 18, he mixed Criswell numbers as well as note numbers. His lists should always be used with this characteristic in mind.
The Confederate Currency (Deacidified and Not Deacidified) consists of the library's collection that originated from sources other than the Ball family. The Confederate Currency (Not Deacidified) consists of more recent acquisitions and other bills that were not included in the deacidification project and that have to be kept separate from the treated items. The arrangement of the Ball Family Division of Confederate Currency and of the Confederate Currency is the same. The notes are arranged first by denominations: $1, $5, $20, $50, etc. Each denomination is subdivided by Type numbers as listed in Criswell's catalog. Types are bills of different designs. Types are subdivided according to denominations, dates, internal design differences, overprints, etc., each subdivision having been assigned a Criswell number. Thus, Types are subdivided by Criswell numbers, although not always in exact numerical order. The lists record the Type number, Criswell number, denomination, serial letter, note number, condition and value (Ball's lists), and occasional comments.
The numerical count of the denominations of notes in the Ball Family Division is:
The count for the Confederate Currency (Deacidified) is:
Duplicates are numerous, but, of course, no two bills have the same note numbers which, although occasionally printed in early currency, are usually handwritten. The count of the Confederate Currency (Not Deacidified) is:
The Southern States Currency is divided into two categories in order to keep separate the deacidified and non-deacidified notes. The non-deacidified notes (549) are from the following states:
The deacidified notes (166) are from:
The engraving, printing, and decorative vignettes on the currency issued by the Confederate and Southern state governments are worthy of note, but these bills in general are not as colorful, varied, and beautiful as those issued during and before the Civil War by the private banks and other businesses. Illustrative vignettes are still common. They include portraits of men and women, public buildings, planters and slaves in the fields, Indians, railroads, steamships and sailing ships, mythological scenes, historical scenes, war scenes, agricultural scenes, places, etc. A notable vignette is a view of the port of Wilmington, N.C., that appears on a $5 bill from N.C. and also on a $100 bill from Mississippi, in the latter case not labeled on the bill.
- Confederate Currency (Deacidified), 638 items;
- Confederate Currency (Not Deacidified), 47 items;
- Confederate Currency (Ball Family Division), 1930 items all of which have been deacidified.
- $1 (6);
- $2 (15);
- $5 (569);
- $10 (662);
- $20 (514);
- $50 (106);
- $100 (53);
- $500 (4);
- $1000 (1).
- 50¢ (20);
- $1 (24);
- $2 (94);
- $5 (116);
- $10 (190);
- $20 (85);
- $50 (45);
- $100 (58);
- $500 (6).
- 50¢ (2);
- $1 (9);
- $5 (5);
- $10 (10);
- $20 (8);
- $50 (3);
- $100 (2);
- $500 (2);
- (a total of 41 pieces.)
- Alabama (2);
- Georgia (2);
- Louisiana (2);
- North Carolina (518);
- Missouri (8);
- Texas (1);
- Virginia (16).
- Alabama (34);
- Arkansas (1);
- Georgia (91);
- Louisiana (5);
- Mississippi (28);
- North Carolina (6);
- Virginia (1)
Congress authorized a national paper currency in 1861 which has continued in use since that time. A useful catalog of all issues is Gene Hessler's The Comprehensive Catalog of U.S. Paper Money (Chicago, 1974).
This collection includes 13 pieces of U.S. fractional currency. As the Civil War developed, the intrinsic value of coins exceeded their face value, and coins disappeared from circulation to such a degree that commerce was hampered. Congress, therefore, authorized the issuance of fractional paper currency that appeared in five issues during 1862-1876 in denominations of 3, 5, 10, 15, 25, and 50 cents. The twelve pieces in this collection are from all five issues and all denominations except fifteen cents. There are also five silver certificates from, 1896, 1899, and 1935.
There are 162 pieces of paper currency, 1771-1982, from 19 countries in Europe, Asia, Latin America, and North America. The countries are:
Many of the Austrian and German bills are from the severe inflationary period of the early 1920's, and many were issued by towns and cities. Two Austrian and three German bills are occupation notes issued by the Allied military authorities in 1944. Five bills from Imperial Russia include one of 1918 from the Siberian Temporary Government. Two early bills from the Soviet Union in 1919 have the slogan "Workers of the World, Unite" printed on them in various languages. French currency includes four assignats, 1792-1793, from the Revolution and several bills from World War I.
From Asia there are bills issued by banks in China during World War II. Japanese currency includes three bills of 1771 from Bungo, Kyushu. They are called bookmarks, "hansatsu," which were a long, narrow form of paper money issued in feudal Japan. They were printed on both sides by the woodblock method in black ink. Bookmarks were not produced by the central authority, the shogunate, but rather by local authorities. Thirty-five bills were issued by the Japanese government for use in the occupied Philippines, Dutch East Indies, and British colonies during World War II. The bills for the British colonies have the letters "OC" printed on them which apparently signify use in Oceania. These bills are known as occupation notes and JIMs, short for Japanese invasion money.
From Latin America there are Cuban bills dating from just before the Spanish-American War as well as earlier. There are three bills of 1914 from the state of Chihuahua during the Mexican Revolution. Two Argentine bills were issued in 1869 by the Province of Buenos Ayres. There is an 1827 bill from Haiti. Brazilian currency includes items from 1891.
The two Canadian bills of 1859 and 1861 were issued by private banks.
- Austria (10 bills), 1920-1944;
- France (19), 1792-1944;
- Belgium (1), 1916;
- Czechoslovakia (1);
- Germany (50), 1914-1944;
- Russia (7), 1918-1919 & undated;
- China (11), 1940-1944;
- Japan (7), 1771 and modern;
- Japan in Occupied Areas of Philippines, Dutch East Indies, and British colonies (35), 1940's;
- Cuba (14), 1872-1897;
- Colombia (1), 1953;
- Peru (1), 1956;
- Ecuador (1), 1958;
- Chile (2), modern;
- Argentina (3), 1869 & undated;
- Brazil (4), 1891 & undated;
- Mexico (3), 1914;
- Haiti (1), 1827;
- Costa Rica (1), 1982;
- Canada (2), 1859-1861.
An assortment of 63 coins, 1875-1971, are from:
The U.S. coins include 50¢ commemoratives for the World's Columbian Exposition in Chicago, 1893, the Lexington-Concord Sesquicentennial in 1925, and the Pilgrim Tercentenary in 1920. The British coins are from the first issue of decimal coinage in 1971.
- U.S. (9), 1875-1964;
- Great Britain (5), 1971;
- Canada (3), 1926-1944;
- Switzerland (1), 1913;
- Tunisia (1), 1941;
- Japan (1), 1966;
- Peru (2), 1946-1959;
- Brazil (41), 1938-1960.
The shortage of money during the Civil War resulted in the issuance of low-value metallic tokens as well as paper currency. First issued in late 1862, over 11,000 kinds of Civil War tokens, including die and metal varieties, were issued between late 1862 and mid-1864. They were struck largely in copper, bronze, and brass. Merchants of every conceivable type issued tokens. This practice continued until Congress forbade private individuals to issue money, including tokens, in April, 1864. Since the North had the metal and the machinery to produce coins, and the South lacked them, the issuance of Civil War tokens was almost entirely a Northern phenomenon. There are two categories of Civil War tokens: patriotic tokens parading nationalistic types and slogans; and endless varieties of commercial advertising tokens called "Civil War store cards" or simply "store cards." A concise history of these tokens is in The Macmillan Encyclopedic Dictionary of Numismatics. An extensive catalog of Civil War advertising tokens is: George and Melvin Fuld, U.S. Civil War Store Cards (Lawrence, Mass., 2nd ea. 1975). A catalog of the patriotics is George and Melvin Fuld's Patriotic Civil War Tokens; Descriptive and Price Catalogue the Die Varieties of Patriotic Type Tokens Used as a Substitute For Money During the American Civil War (Racine, Wisc., 1965).
This collection includes two advertising tokens from businesses in Troy, N.Y., and New York City. There are three patriotic tokens. Their reverse designs are illustrated in George Hetrich and Julius Guttag's Civil War Tokens and Tradesmen's Store Cards (Stow, Mass., 3rd ea. 1968).
There is one British commercial coin. It is a heavy, one penny copper token issued in 1812 by the Union Copper Company in Birmingham, England. This token is described in Robert Charles Bell's Copper Commercial Coins 1811-1819 (Newcastle upon Tyne, 1964), pp. 88-89. Another piece, a probable token, has on one side a British sailing ship and on the other side the words "Ships Colonies & Commerce."
An unidentified probable token is from a "Hotel Piscopu," place and date unknown.
There is one bill, a nine pence bill issued by the state of Rhode Island in 1786.
- Money -- United States -- History.
- Paper money -- United States.
- Coinage -- United States.
- Money -- Confederate States of America
- Bonds -- Confederate States of America
- Bonds -- United States.
- Paper money -- Confederate States of America
- Money -- France.
- Money -- Germany.
- World War, 1914-1918 -- Economic aspects.
- United States -- Economic conditions.
- Confederate States of America -- Economic conditions.
[Identification of item], The Currency Collection, David M. Rubenstein Rare Book & Manuscript Library, Duke University.
Collected by Duke University through gifts and purchases.
Guide by: William Erwin
Completed August, 1983
Encoded by Stephen Douglas Miller
This finding aid is NCEAD compliant.