The Semi-Transparent ETF Ecosystem
New approaches to ETF structures have received SEC approval, including semi-transparent ETFs. These new ETFs selectively disclose portfolio holdings information to the public on a schedule similar to traditional actively managed mutual funds while still striving to maintain market and NAV parity. This is accomplished through the use of alternative methods of signaling the value of an ETFs portfolio to the market.
Since actively managed ETFs seek to outperform a benchmark through security selection and innovative weighting schemes, many money managers have been reluctant to adopt the traditional ETF structure because it demands a transparency that could expose proprietary security selection and weighting methodologies to the public. Moreover, since most ETFs’ holdings are disclosed each trading day, and their rebalances occur on a regular basis, transparent ETFs open themselves up to “front running,” a scheme where traders bid up the price of an ETF’s underlying holdings with the foreknowledge that the ETF itself will need to purchase those shares for a rebalance.
For asset managers who wish to harness the advantages of the ETF structure –
including its tax efficiency and intraday tradability – but want to avoid some of its transparency pitfalls, semi-transparent ETFs may offer a solution. With a few minor exceptions, semi-transparent ETFs utilize all the same structures and relationships as fully transparent ETFs. They are mostly distinguished from fully transparent ETFs by the methods utilized to signal the value of the ETFs underlying portfolio.
Semi-transparent licensing models
The below table outlines the various semi-transparent solution licensing models that have received SEC approval and are available in the marketplace.
Model |
Method |
Notes |
Blue Tractor |
Shielded Alpha |
Disclose holdings and weightings, but disclosed weightings deviate 10% from actual weightings. |
Eaton Vance |
ClearHedge |
Discloses a basket of liquid interests designed to have a high-degree of correlation to the fund itself. The ETF's actual holdings and weightings are shielded from public view. A swap administration agent stands ready to issue new swaps every second over the course of the trading day, which can be used to swap the performance of the actual underlying securities. |
Fidelity |
Tracking Basket |
Discloses a Tracking Basket designed to closely track the daily performance of the ETF's actual holdings and weightings, which are shielded from public view. |
New York Stock Exchange/Natixis |
Proxy Portfolio |
Discloses a Proxy Portfolio designed to recreate the daily performance of the actual portfolio using a factor model analysis of the ETF's actual portfolio. The ETF's actual holdings and weightings are shielded from public view. |
Precidian |
ActiveShares |
Trusted agents, also known as Authorized Participants Representatives (APRs) use confidential accounts to execute creations and redemptions of Authorized Participants (APRs) use confidential accounts to execute creations and redemptions for Authorized Participants. |
T. Rowe Price |
Proxy Portfolio |
Disclose a proxy portfolio to the public with holdings that exhibit a high correlation to the fund's true underlying holdings. |
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Year-over-year, the most well-known global wealth and asset managers continue to choose ACA Foreside to help expand and support their product line up of ETFs. In 2023, our specialists partnered with more than half of the ETF launches in the U.S., and we support 1,000+ ETFs distributed across 275 managers.
We work with asset management firms throughout the world to facilitate compliance and product distribution through legal underwriting, registered rep licensing and chaperoning, and DTCC/NSCC fund sponsorship. We have experience working with all types of pooled investment vehicles, such as traditional mutual funds, ETFs, alternative products, closed-end interval funds, and private placements.
Once launched, we can further support you with our broad range of advisory, managed services, and regulatory technology solutions, to help you grow and protect your business, while also addressing your compliance, ESG, investment performance, and cybersecurity challenges.