NANC and KRUZ: How the Congressional Trading ETFs Actually Work

Two exchange-traded funds try to mirror the stock trades that members of Congress disclose under the STOCK Act: one follows Democrats, one follows Republicans. Both launched in February 2023 under the Unusual Whales Subversive name, and both have since been renamed. Their filings are unusually candid about the central problem: the funds trade weeks after the politicians do, because the disclosures themselves are weeks late.

Everything below comes from the funds' own pages and their SEC filings.

What are NANC and KRUZ?

NANC is the Subversive Congressional Democrats Trading ETF, formerly the Unusual Whales Subversive Democratic Trading ETF. KRUZ was the Subversive Congressional Republicans Trading ETF, formerly the Unusual Whales Subversive Republican Trading ETF; the issuer's page states that "as of 03.21.2025, KRUZ changed its ticker to GOP," so the Republican fund now trades under GOP. Both list on Cboe BZX, both show an inception date of February 6, 2023 in their fund-information boxes (the performance tables use February 7, 2023), and both are advised by Tidal Investments LLC with Foreside Fund Services as distributor. They are actively managed, not index funds: the January 2026 prospectus describes each as "an actively-managed exchange-traded fund" that invests in equities that sitting members of one party "and/or their family members" have reported buying through STOCK Act filings. The funds live inside Tidal Trust I, the registrant whose filings appear on EDGAR. See the issuer's NANC page and Republican fund page, and the 2026 prospectus.

The party test is strict. The prospectus says the Democratic fund "will not consider investments by any U.S. Congressperson who is not registered as a member of the Democratic Party," giving the example of an independent who caucuses with Democrats. The Republican fund applies the mirror rule.

How do the funds use congressional disclosures?

The raw input is the Periodic Transaction Report. The prospectus explains that PTRs "are due within 30 days from when a Congressperson or their family member becomes aware of a transaction, but no later than 45 days from the date of the transaction," and are published online by the Senate Office of Public Records or the House Clerk. The adviser reads those reports and adjusts the portfolio: each fund "will typically buy or sell a security when a position is reported as being bought or sold" by members of the relevant party. Weighting follows disclosed activity, not market cap. Holdings are "weighted based on the level of reported trading in a security," so names with "large purchases, recurring purchases and purchases from multiple" members are overweighted, while "small purchases, recent sales and one-off trades" are excluded or underweighted. Same-day PTRs in one stock are netted, and positions reported as both bought and sold within a single PTR are ignored. Source: the prospectus.

Under normal conditions the prospectus targets "between 100 to 200 holdings," though it notes the count depends on how many positions members actually trade. On September 18, 2026 the issuer's holdings files showed roughly 88 equity positions plus a money-market sweep for NANC and roughly 134 positions for GOP, so the Democratic fund was below its stated range that day.

Who supplies the data now, and why did the names change?

The original arrangement used Unusual Whales as the data provider, which is where the funds' first names came from. That ended in mid-2026. A Rule 497 supplement filed with the SEC on July 31, 2026 states that "the Funds are no longer utilizing the services of Unusual Whales, Inc. (the 'Data Provider') to provide information from Periodic Transaction Reports" and that "the Adviser now directly obtains information from PTRs filed by members of the U.S. Congress." The same supplement renamed both funds to the Subversive Congressional Democrats and Republicans Trading ETFs and disclosed a sponsorship agreement with Subversive Markets Lab, LLC, which provides financial and marketing support in exchange for a share of any profit left over from the unitary management fee. A second supplement on August 20, 2026 added Appendix A to the prospectus, a list of every U.S. senator and representative as of July 31, 2026, whose filings the funds monitor. Both documents are on EDGAR: the July 31 supplement and the August 20 supplement.

For anyone comparing the funds to a tracker such as Unusual Whales, the practical point is that the ETFs and the tracker are now separate operations reading the same public filings.

What do NANC and GOP cost, and how large are they?

Each fund charges a unitary management fee and reports no other operating expenses. The 2026 prospectus fee table for the Democratic fund shows a management fee of 0.72% and total annual fund operating expenses of 0.72%, with a $10,000 investment costing an estimated $74 in year one and $894 over ten years. The issuer's pages list expense ratios of 0.72% for NANC and 0.73% for GOP. Under the unitary structure, the adviser pays the fund's ordinary expenses out of that fee, excluding items such as brokerage commissions, interest, taxes, and acquired-fund fees. On assets, the issuer's fund pages dated September 17–18, 2026 showed net assets of about $291.4 million for NANC (5,650,000 shares outstanding, NAV $51.57) and about $93.1 million for GOP (2,100,000 shares, NAV $44.32). Reported portfolio turnover for the fiscal year ended September 30, 2025 was 10% for the Democratic fund and 16% for the Republican fund, according to the prospectus. Sources: NANC page, GOP page, prospectus.

The two funds are very different in scale. NANC held roughly three times the assets of GOP on those dates, and NANC's median 30-day bid-ask spread (0.19%) was tighter than GOP's (0.31%) on the issuer's pages.

What do the funds hold?

The top of each portfolio reflects which stocks the relevant party's members reported trading most, not a sector view chosen by a manager. On September 18, 2026 the issuer's NANC holdings file listed NVIDIA (8.49%), Microsoft (6.59%), Alphabet (5.98%), Amazon (4.83%), Apple (4.58%), CrowdStrike (4.32%), Applied Materials (3.63%), Philip Morris International (3.03%), Salesforce (2.65%), and Eli Lilly (2.51%) as the ten largest positions, alongside a small government money-market holding. GOP's file on the same date was led by Comfort Systems USA (7.18%), Intel (5.92%), JPMorgan Chase (4.43%), Arista Networks (3.61%), the iShares Bitcoin Trust (3.51%), NVIDIA (3.35%), AMD (2.95%), Allstate (2.08%), United Therapeutics (1.93%), and AT&T (1.90%). Holdings change as new PTRs arrive and the issuer publishes the full list daily on each fund page. Sources: NANC holdings and GOP holdings.

Because a single member filing many purchases of one stock can push it up the weighting, a large position may reflect one household's activity rather than broad agreement across the caucus. You can check that yourself: the trades-by-ticker index shows how many House filers disclosed a given stock and in what value ranges.

Why is the disclosure lag a structural problem for these ETFs?

The funds cannot trade when members trade, because the law gives members up to 45 days to file. The prospectus lists this as "Reporting Delay Risk" and spells out the consequence: "the Fund will not purchase or sell securities at the same time as members of Congress. As a result, the Fund may purchase a security at a higher price or sell a security at a lower price than it would have if purchased or sold at the same time as the member of Congress." It adds that "the Fund would also hold a security for a period of time even though the Congressperson no longer holds the security." On top of the statutory window, PTRs report value ranges rather than share counts, so the adviser is sizing positions from bands such as $1,001–$15,000, and the same filing can cover a member, a spouse, or a dependent child. The lag compounds: a sale disclosed 45 days late may unwind a purchase the fund only recently mirrored. Source: prospectus risk section.

There is a second structural risk the filings flag. The Ethics in Government Act makes it unlawful to use a disclosure report "for any commercial purpose, other than by news and communications media," and the Senate eFD site requires every user to acknowledge that clause before searching. The prospectus states that, absent a definitive ruling on whether the adviser's use of PTR data is a prohibited commercial purpose, the funds face the risk of "monetary penalties and other liabilities or injunctions," which could force a strategy change or liquidation.

What performance does the issuer report?

The issuer publishes standardized returns with as-of dates, and those are the only performance figures we repeat here. As of August 31, 2026, the NANC page showed a one-year NAV return of 19.32% against 20.38% for the S&P 500 Total Return, and an annualized since-inception NAV return of 23.11% versus 20.85% for the index. The GOP page showed a one-year NAV return of 27.34% against the same 20.38% index figure, and an annualized since-inception NAV return of 18.20% versus 20.85%. Quarter-end figures as of June 30, 2026 are also published on each page. Both pages carry the standard warning that past performance does not guarantee future results. These are the issuer's numbers, not ours; we have not independently recomputed them and make no claim about what they imply going forward. Sources: NANC performance, GOP performance.

Note that the comparison is to a broad-market index, and both funds are concentrated, high-turnover portfolios built from a few hundred filers' disclosures. A period in which a handful of disclosed names did well will dominate the result.

How to use the disclosures the ETFs are built on

The same PTRs that drive NANC and GOP are public, and anyone can read them without buying either fund. House filings are indexed by the Clerk and searchable in our politician-trades directory, ranked in most-active members, and downloadable with the original filing URL on every row from the congressional-trades dataset. That data is House-only, covers the 2025 and 2026 filing years, and is refreshed on weekdays from the Clerk's index; Senate filings live on the Senate's eFD system and are not included. Reading the filings directly shows what the ETF structure necessarily hides: whether a disclosed purchase belonged to the member, a spouse, or a dependent child, how many days passed between the trade and the filing, and how wide the value range was. To see the range, owner, transaction date, and filing date behind a fund holding, start with how to read a congressional disclosure and then compare tools in our tracker roundup.

Bottom line

NANC and GOP are actively managed ETFs, advised by Tidal Investments and listed on Cboe BZX since February 2023, that rebuild party-specific stock portfolios from delayed, range-based STOCK Act filings. Each charges a unitary fee of 0.72% (NANC) or 0.73% (GOP), and on September 17–18, 2026 the issuer reported net assets of roughly $291 million for NANC and $93 million for GOP. Their own prospectus states the funds "will not purchase or sell securities at the same time as members of Congress," may pay more or receive less than the members did, and may hold stocks members have already sold, because the law gives filers up to 45 days to disclose. Since a July 31, 2026 supplement, the adviser sources the filings itself rather than through Unusual Whales, both funds carry Subversive Congressional names, and the Republican fund has traded as GOP rather than KRUZ since March 21, 2025. The underlying filings are public and can be checked independently.

Sources

Subversive Congressional Democrats Trading ETF (NANC) fund page, Subversive ETFs, data as of September 17–18, 2026
Subversive Congressional Republicans Trading ETF (GOP, formerly KRUZ) fund page, Subversive ETFs, data as of September 17–18, 2026
Prospectus and SAI, Form 485BPOS filed January 27, 2026, Tidal Trust I, SEC EDGAR
Rule 497 supplement, July 31, 2026 (name change, data provider, sponsor), SEC EDGAR
Rule 497 supplement, August 20, 2026 (Appendix A), SEC EDGAR
Electronic Financial Disclosure (eFD) home and terms, U.S. Senate
STOCK Act, Public Law 112-105, govinfo.gov

This article is educational and is not investment advice. Fund holdings, assets, fees, and disclosures change; read the current prospectus before investing.