
Lead-Lag Live
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Lead-Lag Live
Webinar: Exploring the Cambria US Equal Weight ETF (USEW): Diversifying Beyond Market Cap
Tired of choosing between concentration risk and a painful tax bill? Michael sits down with Med Faber from Cambria Investment Management. We break down a smarter option: using a 351 ETF exchange to convert appreciated, concentrated stock positions into a diversified ETF without triggering taxes. Think of it like a 1031 for public equities—contribute eligible positions at launch, receive ETF shares in return, and let the portfolio rebalance inside the tax-efficient ETF wrapper.
We walk through:
The exact rules that matter
Why your largest position must be under 25% and your top five under 50%
Which assets qualify, and why contributions must happen at the seed stage.
You’ll hear real examples of prior 351 launches, learn about the upcoming U.S. equal weight fund aimed at breaking the market-cap link, and get a clear timeline: indicate interest, submit holdings, pause trading, transfer positions, and receive ETF shares on day one. We also explain the powerful benefit of multiple cost-basis lots embedded in the ETF, which can make future tax management far more flexible.
Along the way, we widen the lens to the current market: elevated U.S. valuations, heavy index concentration in the same handful of megacaps, and a stealth rotation in gold and non-U.S. value strategies. If you’ve been meaning to diversify but taxes keep you stuck, this is the actionable path. Advisors will find a field guide for client conversations—simple analogies that land, common custodian workflows, and prospecting angles for executives, VC distributions, and direct indexing portfolios.
#LeadLagLive #Cambria #USEW #IncomeInvesting #Markets #Investing
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Uh for those that are here for the CE credits, um just bear with me to the end of the presentation. I will email you afterwards, get your CE credit info. Submit this CFP board. Um, so just uh hold on. Uh don't just leave right away. Uh if you happen to be in an office and you're a financial advisor and with other financial advisors, please let them know that this webinar is taking place. I promise you you will enjoy it because MEP Favor is one of the OGs in the industry who I've known for well over a decade, who's built a hell of a company with Cambria, a number of funds, and we talked about uh some of those as well as 351 exchanges, which MEB believes are going to be the next hot thing in all of 2026. So you'll get a good insight on that process. Um, and with all that, all that said, my name is Michael Gayed. Uh, this webinar is sponsored by Cambria, one of my clients. I will introduce my friend, Mr. Mepp Favor, and uh you will all be wowed, I promise you.
SPEAKER_00:What's up, everybody? Uh happy Wednesday. I should be wearing my Dodgers hat, but it's Dodgers Blue. So um I'm a reform Rockies fan. So if anyone's uh cheering for baseball, you know, uh I'm uh I'm I'm I'm Rockies are basically a double-A team at this point. So anyway, um I got a little deck that we can run through that'll be fun. Um if uh as everyone kind of joins in here. Um what are we talking about today? This is a topic that probably 99% of advisors, investors, VCs, CEOs have not heard of. And this is the topic of 351 ETF conversions. And we'll talk about a few things as we go along here, of course. But um, you know, for those who don't know us, my day job is running Cambria ETFs, where uh you can find a bunch of information on our 19 Soon2be20 funds at CambriaFunds.com. We uh we have a little over 3 billion and 100,000 investors. We have a really nice free research website called the Idea Farm that's getting redesigned. Should be out this week. Pretty excited. It should be your institutional research homepage. Sends out an email once a week, also to over 100,000 people. Uh, we've been publishing blogs and research, white papers, books for a long time over at Meb Favor, and then more recently on the podcast, 600 episodes now, which I can't believe. Uh guy had an alum as well. But as we talk about what's going on in the world, we'll do just a quick uh update. Everybody's fat and happy. There's two kinds of topics that everyone's talking about right now. That's stocks at all-time highs and gold. You know, nobody was talking about gold when it was 3,000. Now everybody's talking about it at 4,000. There were signs. This is a chart of the U.S. valuation, you know, and we're back up to, I don't know if you can quite see it because this is updated in June, but we're we've now exceeded that little peak in 21. So the final boss is left on a PE ratio basis. This is the most expensive market since late 90s. A little different. You know, the companies have been growing, they have some cash, but still uh they're expensive. I learned yesterday that the top uh nine stocks in SP and NASDAQ are all the same names. I feel like that would surprise people. It would be the top 10, but Berkshire is not in the Nasdaq. So um so you everyone knows you got this con you got this valuation problem, you got this concentration problem. I feel like these are well-known topics, but everyone that you talk to is say, look, I bought NVIDIA, I got the Mag 7, I got Apple, I got Berkshire, I mean all these stocks, the US stocks in general, SPY, and they say, Well, I can't sell them. I know they're expensive, I want to sell them, but tax man's gonna kill me. And so you have these two options if you got concentrated stock holdings. You just hold it and just suck it up. Say, look, I'm just gonna deal with this over time. I can sit through drawdowns, or you gotta sell it, pay those capital gains taxes. You know, no one likes to uh pay to the government what um or the the tax man, right? Like that's no one volunteers to pay more than they owe. So you sell, trigger capital gains, and move on. But what if there was a third way? It's almost sounds like a eight-minute abs sort of conversation, but you know, we we think we we have found a good solution to this and other problems that are similar. So let's think about it. How are we gonna do this? Um, well, the answer we think is 351 ETF exchange. And for those who aren't familiar with that acronym, it's sort of like a 1031 real estate, but for stocks. So it's contribution that allows for the transfer of assets such as stocks or ETFs, but really it's public assets, stocks or ETFs, uh, to an ETF without realizing a taxable event. Now, it's not washing those taxes, that would be illegal, of course, but basically you're contributing property to an ETF, getting the ETF in return. Um, and so why is that interesting? Well, you could move from a very concentrated portfolio to a diversified portfolio. Uh, and then if you know anything about ETFs, the ETF can then rebalance and stay diversified uh for the foreseeable future. Most ETFs really never pay a capital gains uh uh distribution. So, um, what are the main rules? Where are we here? Why isn't this moving over? There we go. There's two big rules. First of all, you can't just give me 10 million NVIDIA. Uh the biggest position can't be above 25%. And then second, the top five positions can't be above 50. So realistically, what does that mean? Well, you need about a dozen stocks or ETFs or pass through. So spy, for example, is a pass-through security where it looks at the underlying holdings. So theoretically, you could actually contribute 100% SPY. What do people do in reality? Well, they tend to submit a little bit of both. So they may have a handful of concentrated stocks that they would like to move on from and then uh round it out with some ETFs as well. This is only on the seed, so you can't do this um after an ETF launches. Once an ETF launches, it's just like every other ETF. Uh so if you want the 351 benefit, you gotta do it at the beginning. So again, like a lot of people ask us these questions, and they're they're typical of things that qualify and don't qualify. You know, we just mentioned you can contribute stock, you know, and in various uh numbers, anything above really a dozen is is usually good to go. You could do things like ETFs, things that don't qualify, anything private, options, futures. Uh you can't do 50% NVIDIA and 50% cash, you can't do mutual funds, can't do Dogecoin, all these things. Although, by the way, I think you will be able to do next year contributions into uh 351 from various crypto positions if the underlying strategy, the ETF, uh has crypto as a part of the overall portfolio. So for uh um, I'm gonna skip over the next fund we're doing and I'm gonna jump real quick to the funds we've done. So we've done three of these already. First one was almost a year ago, uh, and uh kind of announcing it to the world. And as you can see, as they've been getting bigger and bigger, tax was 30 million-ish uh on launch, which was a U.S. stock fund avoiding dividends, targeting companies with low payouts. Endw was a uh diversified allocation fund using a little bit of leverage that launched with over 100 million. I think it's over 125 now. And then GEW launched a couple weeks ago, uh, and that one was 150 million. So they're getting bigger and bigger. That was a global stock fund. So what's the next one? Well, we got USEW as the ticker, and that's going to focus on U.S. stocks. So looking at U.S. stocks as a percentage of the whole, uh, you know, you know this concentration issue. So we're really trying to break that market cap link. Market cap to us is a dangerous place to be currently. Historically, market cap has underperformed equal weight over long periods. Although over other periods, like the last 15 years, market cap stomps everything else. Um, and if you look at the equal weight uh, you know, type of idea, we can accept any type of U.S. stocks to be the biggest and the most liquid. But more importantly, this is uh this is a fund that's coming in at a very low expense ratio of only 25 basis points. Uh pretty, pretty screaming cheap. This launches December 17th. So what do you got to do before then if you're interested? Everybody's quiet. No, no, no chat, no questions yet. So you guys throw these in if you got any um if you got any questions. Um what are the dates here? The dates are you gotta let us know now. There's two options. Uh you got to go through a financial advisor. So um you you let us know, hey, I got some clients, they're doing direct indexing, they got concentrated portfolios, I want to do a strategic rebalance, whatever it may be. Uh, I want to indicate my interest. So we'll help you, we'll give you white glove service, walk you through, kind of help go about uh contributing here. And you got to have these portfolios in by the week before Thanksgiving. So November 19th. You got about a month and a half, plenty of time. And uh and all the paperwork buttoned down by essentially Thanksgiving. And then this will launch mid-December. If you're an individual, uh if you're a family office or something, we we have um the ability to work with various RIAs or people that can upload these, that can walk you through the process. Reach out to us. Certainly we can help you. This email is golden351 at CambriaFunds.com. You can also go to the website, it's got a ton of information uh at CambriaFunds.com about our ETFs currently, but also the 351, a lot of PDFs, a lot of podcasts that'll go into uh a lot deeper discussion on uh what we talked about today. I'm giving you guys a very quick overview because everyone's so quiet. No chat, no questions yet. Um so we're kind of just uh cruising through. Um oh, chat's disabled. Well, just kidding. Throw it into the uh QA then. Sorry, you guys. If you got questions, put it in the QA, not the chat. Uh QA. Thank you, uh Kimberly. Um so if anybody's got questions, QA. So as of now, um I'm gonna uh I'm gonna kind of start to wind down a little bit on this very, very quick overview. Uh hopefully I didn't skip over too much because we've done this so many times, talked about it, that uh it's second nature to us. Um one traditional question for people is often, hey, look, Meb, I'm busy. It's year end. Will you be doing any any more of these in 2026? I expect this one to be our biggest yet, so likely in the hundreds of millions of dollars. I don't think it'll be over a billion, but it could be. But uh but we plan to lay out a buffet of a few more choices in 2026, uh, with onboarding maybe at the end of Q1, into Q3, Q4, uh various strategies. I imagine a US stock, a global stock, and an allocation will probably be the traditional uh buffet for for next year as well. Um you can come see us in Los Angeles. We're located here in Manhattan Beach. And um again, here's the website and information on the email to be able to reach out if you guys want to talk. I don't see anything in the QA. Oh, we got something. What securities can we take? You know, a lot of people who have experience with traditional exchange funds uh have had a sour experience because let's say you got 10 million NVIDIA and you reach out to Goldman or Eden Vance and they're probably charging you an arm and a leg anyway. But uh traditionally the problem with exchange fund is A, you got to hold it for seven years, B, it's expensive. C, if you got NVIDIA, they probably aren't gonna take it because they say that's all anybody's got is NVIDIA. And so um, you know, they they for at least for us, if it's some tiny microcap mining stock, you know, from Vancouver, we probably won't take it. The basic rules are is it liquid and tradable? And then does it match the the strategy? So the next fund in December is U.S. stocks, so we won't be taking any foreign stocks, we won't be taking any real estate or commodities or anything like that. It's just a stock fund. Uh, but with that on understanding, almost all stocks uh qualify. It just can't be tiny and it can't be something that's um not liquid or tradable.
SPEAKER_01:Okay, can we get a little bit into the mechanics, like in terms of now that you've done a few of these, how long is the process for an advisor? How involved is the end client? Like, what does that look like logistically?
SPEAKER_00:Yeah, I mean it's it's pretty smooth. You know, traditionally for um for the clients, certain custodians are much easier. Someone like a Schwab is uh is totally on board. They love it. Others like Fidelity, it's it's not like a universal experience. You know, you tend to have to go through your um local uh um administrator, product manager versus Schwab, which is just like a rubber stamp sort of situation. But even then, it's pretty smooth. We work with our partners, ETF Architect, Wes Gray, and Pat Cleary on this. And so they got that military efficiency. They've done a bunch of these, and we've done three. So basically, you have to submit an Excel sheet that's got the client positions. And so, hey, look, here's the tax lots, here's the cost basis, here's, you know, basically a monthly report from Schwab. And uh we make sure that it qualifies. And assuming it does, uh, then you need to sign, you know, one form client, hey, I know that this is happening, this is going on, I get it. And basically we say stop trading. So end of November, we would be like, stop trading this account. Uh, you know, you can't have margin or shorts or leverage on it. And basically, you know, a couple days before those positions will transfer to US bank, and then the day of the launch, you'll get the ETF back. Now, the cool part is let's say you submit 20 positions, you're gonna get the 20 positions with an original cost basis for the ETF. And so you can kind of pick and choose what cost basis you want to uh trade in the future. So there's no holding period. You could theoretically sell it day one. Now you're not gonna want to if you contributed NVIDIA at a dollar because you're gonna be paying taxes on that original cost basis. But if you contribute NVIDIA and maybe some SPY that doesn't have as much of gains on it, the SPY could be uh liquidated pretty quickly, and you may not have to um pay significant taxes on this. So it's a pretty flexible approach. We have people that have submitted direct indexing long-only portfolios that may have 100 or 500 positions, and then they now have all these tax slots on the ETF that they can manage going forward. And so there's some people also that say, hey, look, you know, there's like four main use cases. The first is concentrated stock, the second is strategic rebalancing. So if you're stuck in all US stocks, for example, market cap weight, and you're like, I just got to get out of this SPY or the Qs. And then third would be something like a direct indexing. Fourth, though, if you're a financial advisor, is is business development and prospecting. I mean, I can't tell you guys, I I say this, you guys now know about it, but zero VCs I've spoken to. So despite the fact their entire business model is to invest in private companies that go public and distribute these massively appreciated shares, they usually then just sell them. Well, if you're rich enough, you'll just donate them. I don't know. But uh, but again, you could uh easily contribute these and uh get a diversified portfolio and exchange. And so it's um there's a lot of different use cases. None of the companies, like if I was a local financial advisor, I'd go down to my top five biggest public corporations and say, can I talk to your investor relations? I now have a solution for your 10,000 uh NVIDIA employees that have like 20 million dollars stuck in this stock. We can be able to assist them in a way that uh will help them to start to diversify away from uh this company. So it I think it's a pretty um interesting idea that has not gone mainstream yet. I think 2026 will probably be the the year of uh the 351.
SPEAKER_01:You mentioned uh let's talk macro for a few minutes here. Um you mentioned everyone's fat and happy. Um I'm pretty sure fat and happy often leads to the conditions under which heart attacks happen. Uh won't be see is a is a legit cause there. Um are we ever gonna see risk again, man?
SPEAKER_00:I mean So Um You know, I I've said a couple things. You know, we wrote this paper, which I loved, my favorite paper of the last few years, which is called The Bear Market and Diversication, just talking about how the SP has crushed everything for the past 15 years. And then over the last year or two, you've started to see other things perk up. So the one there's the one that's everyone's talking about this year, which is gold and rightfully so, and silver, those things are up, you know, a ton at all-time highs. But then you have some other things, and I said this today kind of quietly beneath the surface. So everyone, I had a tweet when gold hit 3,000, and I was like, gold's dripping, no one in my world's talking about it yet. And so today we were like gold dripping, it's at 4,000. Seemingly everyone's talking about it now. But with U.S. stocks at all-time highs, um, there's some other things that are doing great. Foreign stocks, the value trade uh, you know, is has been fantastic X US this year. So a deep value strategy is up. Um, you know, we have an ETFG Val, which is up well over 40% this year. And I'm gonna tell you something. It's it's October, so it's Halloween, Guyad. Um, I'm gonna give you a spooky statistic where uh currently that fund, and you guys got to look it up, but certainly this month over the next few weeks, unless it uh, you know, crashes or goes down. I think this is a statistic that will surprise everyone listening. This G-Val ETF, which buys the cheapest countries in the world, so often places many people don't want to invest, and for many years was totally stinky. Uh this strategy buys countries like Brazilian stocks and Colombian stocks and Polish stocks and Turkish stocks, UK stocks, was in there for quite a while. Um this fund is now beating the SP on a one, a three, and a five-year basis. And people are like, oh my, that can't be true, right? Like US is creaming everything. And, you know, the challenge is some things are starting to really uh, you know, come around. So um that having been said, there are other areas that have not started coming around. I think the ones that are going to be most obvious to people would be uh US mid-cap, U.S. small cap, U.S. value, right? Those are doing okay, but you haven't seen the reversion the same way you have X US value. And in broad foreign developed and emerging are doing great too. I think, you know, those are in the kind of 20, 30% range, whatever they are, those are doing uh well. But but until the US market cap weight does something else. So it could be sideways, it could be down, down a lot. I don't think anyone's motivated to move. If we know anything about inertia, people, you know, they when they're fat and happy, they don't want to get off the couch. So uh, but if if something starts to jiggle or things get a little weird, you could see some pretty big shifts. Um we said the other day on Twitter it was a valuation chart of market cap versus equal weight. I said, you to me, you have to be crazy to be YOLOing into market cap weight. If you're a strategic asset allocator doing this for like, you know, the next 10 years. If you're doing if you're a trader and you're trading, whatever, that's that's a different story. But if you're an investor, I think this point in the cycle, historically from 40 plus cape ratio, we have not found a time in history where a country stock market ended the year. So we're not there yet, we got three, two, three months to go. But if we end the year above 40, there's been no year in history we could find where the future 10-year real returns are above average. So meaning like 5% real returns. And on average, it's zero real returns for the next 10 years. So not the best starting point, but you know, as a trend faller, I'm I'm happily long everything just about, you know, but uh it's uh on the value side, it's getting getting a little scary. Uh I uh I reposted then liked, as you could tell, this post from you. Ah, that was a good one.
SPEAKER_01:AI, what's coming next? You said bear market.
SPEAKER_00:Yeah. Well, I've had a lot of fun with AI. You know, I downloaded Sora. I've been um poking my favorite uh nemesis of of CalPers and other institutional managers. I I posted a video to LinkedIn. Um I posted a few commercials for our ETFs, but my my compliance friend said, you gotta take these down, Meb. Even though they're AI and even though you're joking, you can't even mention it. So I said, okay, I'll just I'll turn my attention to Calpers. But I posted a video of me presenting to the Calpers board, but the CowPers board was replaced with Lego figures, and uh they all started crying when I said I was gonna fire everyone and replace you guys with a bunch of ETFs. Uh so I'm having a lot of fun with AI, but uh it seemingly is sucking all of the air. I saw a uh I do a lot of startup private investing. I saw a stat the other day that something like 70% of all the money and deals are going to AI companies, which which jives with my deal flow that I see. I see it's all AI companies that are either have no revenue and are trading at crazy valuation or have some revenue and are trading at crazy valuation. Either way, it's crazy, it's crazy valuations across the board. I guess the question is can you have a bear market and AI and bull market and everything else? Um, you know, it uh it's interesting. Even the stuff that's in like the NASDAQ cues that's not tech is getting dragged up. Like Costco. I love Costco, but it's something like a 50 PE. You know, it's like a it's like a nutty time. Um, but again, you know, it feels like right, it feels like musical chairs right now. It feels like everyone knows. Like it's not like people are like, no, stocks aren't expensive. I was like, everyone's like, yeah, okay, I I this feels nutty, but I'm I gotta wait. Like I'm I'm just I'm gonna be the first one to jump off the Titanic. So I think there's certainly a lot of things people could be doing to diversify away from market cap US stocks, but I don't think anyone is quite yet.
SPEAKER_01:Yeah. Let's uh let's go back uh again for those I know those right here for the C credits, I'll email you afterwards. Um go back to the 351s for advisors that are curious and want to do it. How would you advise them to go about talking about it to their own clients? Because it's kind of a concept, right? There's an education process both ways, you on the advisor. Yeah, I know it worth.
SPEAKER_00:The first thing is just go to the Cambria Fund site. We got a 351 tab. There's a bunch of PDFs and podcasts that are pretty good material, gives you a broad overview. I mean, I think the simplest way is to describe it as hey, look, um having a concentrated portfolio, and there's reams of research on this, is a horrible idea on average. You'll always get the exceptions where you can point to someone and say, Well, look, but yeah, but they've owned their entire portfolio, it's been in Berkshire for 30 years. Their entire portfolio has been in NVIDIA. And you're like, well, but thousands of other stocks where their entire portfolio was in X and it lost all their money or underperformed. So uh it's even harder for individuals, particularly when they have a constant trader portfolio that made a lot of money, because then they have that hindsight bias where like, this was my ticket. You know, I I know, I know this company. I know Enron is the best place to be, on and on. So I think the way once they, if the client's on board, say, okay, yes, I realize I need to diversify. I'm I'm on board. I that's sound advice. I don't want to put all my eggs in this basket. It's kind of like saying, hey, you know, if they know what a 1031 is, say basically you can swap this building out, sell it, you get another building, and defer your taxes. I think that's the best analogy. It's not a clean one. If they've experienced exchange funds, it's not that too different. But basically, it's like, hey, you can swap out this portfolio, get this other portfolio. And then 351's been in the tax code for many decades. It just found its perfect partner with the ETF structure. Uh, and so, you know, you you've seen a lot of prior art. There's been over a hundred of these now. Uh, so it's it's kind of the best way I would describe it is that you can diversify in a tax-deferred manner and do it in a way that's that's clean with a lot of um, you know, when I we were talking about this a year and a half ago, it was a little different because people were like, Well, you haven't done any of these, is this real? Is it legal? And now, like everyone's doing it. It's you know, Goldman did one that was a billion, uh, but obviously only for one client. Um, so we're we're we're one of the uh I think us and ETF Architect are really one of the few that are doing it open enrollment, being like if you're a finance advisor, you're an individual, reach out and uh we can we can help you out.
SPEAKER_01:Oh, we got one more question. Why do you want more question? Hold on. Uh which we'd like to talk about how the Kimberly ETF gets managed once launched and all the assets are mixed.
SPEAKER_00:So uh thanks, Kimberly. Um it depends on what the strategy is. So for our next fund, it's a U.S. stock strategy. And it depends a little bit on what's contributed. So here's another example. You can go back and look at our old ones, so like our endowment ETF, ENDW. You know, ENDW is meant to be uh broadly replicate endowment style allocation and uses leverage. So it gets up to 140% leverage. So if you look at that fund, it owns ETFs, it owns some treasury futures, but it had a lot of stocks that were contributed. There's sort of a glide path, depending on what was contributed. You know, we say it could take up to a year to get to the final portfolio. That having been said, we expect month one, week one, really, because of what was contributed, and it's only under the universe that we're accepting, to really already be at a correlation, a beta to the final strategy well over 0.9. So already month one, you're kind of you've got the beta of what the correlation of where we're going. And then over time, we're extremely conservative on uh, you know, kind of not antagonizing the regulators. Others are are not. They they uh I think fly way too close to the sun on some of the ways they operate, not just uh this world, but you know, in general. And so um it it it will depend on each fund. So this one in December is US only stocks, long only. But if you look for us as in 2026, uh we may have a totally different buffet of ideas, and you can kind of pick and choose which one uh you may be interested in.
SPEAKER_01:That's uh probably a good place to wrap this uh webinar up, unless uh Web Mip, you've got anything else?
SPEAKER_00:No, you guys please reach out to me. We have uh, you know, uh a lot of folks here that'll be happily to set up a call, shoot you an email, talk about it later. And uh and if you're in the local, you can come say hi.
SPEAKER_01:There you go. Appreciate everybody that's here. You'll get an email from me shortly. Thank everybody for the uh attention, and we'll see you next time. Cheers, everybody. Good Dodgers.