Defiance files six funds to buy short-term calls on QQQ, DRAM and SMH
ETF Series Solutions filed Wednesday, September 30 to register six proposed Defiance funds that would buy cash-settled calls expiring in one to five business days on QQQ, DRAM and SMH.

Key takeaways
ETF Series Solutions filed a post-effective amendment on Wednesday, September 30 to register six proposed Defiance funds that would buy short-term calls on three ETFs. That is the filing that adds series to a trust already on file with the SEC, and it leaves the tickers and the management fees blank.
Three of the funds would own the ETF and use what is left to buy the calls. They are the Defiance 100 Growth Convexity ETF, the Defiance DRAM Convexity ETF and the Defiance Semiconductor Convexity ETF. Each would invest substantially all of its net assets in one fund, then use the remainder to buy short-term calls on that same fund.
The growth fund would hold the Invesco QQQ Trust QQQ, which tracks the Nasdaq-100. The semiconductor fund would hold the VanEck Semiconductor ETF SMH, a fund of companies that make semiconductors and the equipment to make them. The memory fund would hold the Roundhill Memory ETF DRAM, a fund of memory-chip companies.
The calls would be cash-settled, paid in cash rather than in shares, and they would generally expire in one to five business days. The filing calls that window an options period. It says the strategy is meant to provide convexity, its word for exposure that does not move in a straight line with the ETF's price. Milliman Financial Risk Management LLC, named as sub-adviser, would choose the calls. In the growth fund's summary, Milliman anticipates spending about 3% of net assets on premiums in each options period.
The filing describes the other three from the calls, not from a holding in the ETF. The Defiance 100 Growth Ultra Convexity ETF would buy calls on QQQ, the Defiance DRAM Ultra Convexity ETF on DRAM, and the Defiance Semiconductor Ultra Convexity ETF on SMH. Milliman would choose the calls it believes provide upside in the share price.
A holder of one of the three that would own the ETF would also pay that ETF's fee. QQQ charges 0.18% a year, SMH charges 0.35%, and DRAM charges 0.65%. The new fund's own management fee is blank.
What else is tied to DRAM
Defiance already sells a fund that seeks twice the daily move in DRAM, before fees and expenses. That is the Defiance Daily Target 2X Long DRAM ETF DRAL, which began trading on Thursday, June 25. DRAL resets every day. The proposed funds would buy calls that expire in one to five business days.
On Wednesday, May 13, the same trust filed a Defiance DRAM Option Income ETF. The prospectus says it may use a traditional or synthetic covered-call strategy to seek income from DRAM, with a limit on gains. A later amendment set Monday, July 27 as that registration's effective date.
For the growth fund, the one that would hold QQQ and buy the calls, the filing says the loss in an options period will generally track the premium spent that period, plus any loss on the shares.
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Frequently asked questions
How short are the calls?
They would be cash-settled and generally expire in one to five business days.
Do the funds hold QQQ, DRAM and SMH, or only the calls?
Three Convexity funds would hold one of those ETFs and buy calls on it, while three Ultra Convexity funds would buy only the calls.
What will they cost?
The new funds' management fees are blank, and a holder of a fund that owns the ETF would also pay that ETF's fee.
How is this different from Defiance's existing DRAM fund?
DRAL seeks twice DRAM's daily move and resets every day, while these proposed funds would buy calls expiring in one to five business days.


