Cheesecake in or next to waterbath

I've heard of two separate ways to use a water bath when cooking a cheesecake: placing the cheesecake in the waterbath, or placing a roasting pan full of water on the bottom rack of the oven, with the cheesecake on the top rack. I like the idea of not putting my cheesecake in the water, which avoids the need to wrap the pan in foil. Do these two separate methods create any discernible difference in the final result? Is one better than the other?