NANC and KRUZ: How the Congressional Trading ETFs Actually Work

The congressional trading ETFs admit it in their own prospectus: each fund "will not purchase or sell securities at the same time as members of Congress." Members have up to 45 days to disclose a trade, and the funds act only once it is public.

Watch it play outThe funds act only after the filing goes public

A member of Congress, or a family member, makes a trade.

Members have up to 45 days to disclose it.

Only then does the filing become public.

The funds act on it, and each "will not purchase or sell securities at the same time as members of Congress."

Replay

NANC follows Democrats; the Republican fund, once KRUZ, now trades as GOP. Both rebuild portfolios from delayed, range-based filings. Below, a simple example shows what that delay can cost, and a 10-minute exercise lets you check a top holding against the filings yourself.

Watch it play outA filing gives a range, not a trade size

Every trade a member makes has one exact dollar size.

But the filing reports only a value band, such as $1,001–$15,000.

The real size could sit anywhere inside it.

NANC rebuilds from Democrats' filings and GOP, once KRUZ, from Republicans', sizing positions from these ranges.

Replay

The short version

• Same method. Both launched in February 2023 under the Unusual Whales Subversive name and charge 0.72% (NANC) or 0.73% (GOP) a year.
• The lag is structural. The funds may pay more or get less than members did, or hold stocks members sold.

Watch it play out45 days late can mean paying more

Hypothetical, round numbers: a member buys a stock at $100.

They file on day 45. By then the stock is $110.

Only now can the fund buy, at $110.

The lag is structural: the fund can pay more, or get less, than the member did.

Replay

• New data source. Since a July 31, 2026 SEC supplement, the adviser reads filings itself instead of using Unusual Whales.
• Mixed results. As of August 31, 2026, NANC beat the S&P 500 since inception but trailed it over one year. GOP did the reverse.

Check the claimThree claims about the congressional trading ETFs

ClaimNANC copies Nancy Pelosi's portfolio.Tap to checkMythIt follows reported trades by registered Democratic members as a group, weighted by the level of reported trading. No single member's portfolio is copied.Flip backClaimThe funds trade alongside members of Congress.Tap to checkMythThe prospectus says each fund "will not purchase or sell securities at the same time as members of Congress." It acts only once a filing is public, up to 45 days later.Flip backClaimKRUZ and GOP are two different funds.Tap to checkMythSame fund. The ticker changed from KRUZ to GOP on March 21, 2025, and the name changed with the July 31, 2026 supplement.Flip back

What NANC and GOP are

Both list on Cboe BZX, with Tidal Investments LLC as adviser and Foreside Fund Services as distributor. Inception is February 6, 2023 in the fund-information boxes and February 7, 2023 in the performance tables. Tidal Trust I is the EDGAR registrant.

Sources: the issuer's NANC page and Republican fund page, and the prospectus filed January 27, 2026.

The prospectus calls each "an actively-managed exchange-traded fund," not an index fund, buying stocks that sitting members of one party "and/or their family members" reported buying in STOCK Act filings. The party test is strict: the Democratic fund "will not consider investments by any U.S. Congressperson who is not registered as a member of the Democratic Party," which rules out an independent who caucuses with Democrats. The Republican fund mirrors that rule.

Party registration decides whose trades count

NANC follows

• Sitting members registered as Democrats
• And/or their family members

GOP follows

• Sitting members registered as Republicans
• And/or their family members

Neither follows

• An independent who caucuses with Democrats
• Anyone not registered with the fund's party

How a disclosure becomes a holding

The input is the Periodic Transaction Report (PTR), filed for each trade. It is due within 30 days of a member or family member learning of a trade, and no later than 45 days after it. The Senate Office of Public Records and House Clerk publish PTRs online.

The fund only moves once the trade is public

1. Member trades (Or a family member) to PTR filed (Up to 45 days later)
2. PTR filed (Up to 45 days later) to Published online (House Clerk, Senate)
3. Published online (House Clerk, Senate) to NANC or GOP trades (Weighted by reported trading)

Per the prospectus:

• Each fund "will typically buy or sell a security when a position is reported as being bought or sold" by members of its party.
• Holdings are "weighted based on the level of reported trading in a security," not by company size (market capitalization).
• "Large purchases, recurring purchases and purchases from multiple" members get more weight; "small purchases, recent sales and one-off trades" get less or none.
• Same-day PTRs in one stock are netted; a position bought and sold within one PTR is ignored.

The prospectus targets "between 100 to 200 holdings," depending on member trading. At roughly 88 positions on September 18, NANC sat below that range.

NANC holds fewer stocks than its own target

Prospectus target100–200 holdings

NANC88

GOP134

50100150200

Who supplies the data now

Unusual Whales, the tracker, was the original data provider, hence the first names; it and the ETFs are now separate operations. A Rule 497 supplement filed on July 31, 2026 says "the Funds are no longer utilizing the services of Unusual Whales, Inc. (the 'Data Provider') to provide information from Periodic Transaction Reports." Instead, "the Adviser now directly obtains information from PTRs filed by members of the U.S. Congress."

It also renamed the funds and named a sponsor: Subversive Markets Lab, LLC provides financial and marketing support for a share of any profit left over from the management fee. A second supplement on August 20, 2026 added Appendix A: a list of every U.S. senator and representative as of July 31, 2026, whose filings the funds monitor. Both are on EDGAR: the July 31 supplement and the August 20 supplement.

From Unusual Whales branding to in-house data

1. Feb 2023Both funds launchAs Unusual Whales Subversive ETFs
2. Mar 21, 2025KRUZ becomes GOPTicker change
3. Jan 27, 2026Current prospectus filed
4. Jul 31, 2026Unusual Whales droppedAdviser reads PTRs itself; funds renamed
5. Aug 20, 2026Appendix A addedEvery member whose filings it monitors

What they cost

Each fund charges a unitary management fee: one all-in fee from which the adviser pays ordinary expenses, excluding brokerage commissions, interest, taxes, and acquired-fund fees. The prospectus fee table for the Democratic fund shows 0.72% in total annual operating expenses: an estimated $74 in year one on a $10,000 investment, and $894 over ten years.

NANC has roughly three times GOP's assets and a tighter bid-ask spread, the gap between the buying and selling price.

What 0.72% a year costs on $10,000

0.72%NANC total annual expensesGOP: 0.73%

$74Year one on $10,000Prospectus fee example

$894Ten years on $10,000Assumes 5% yearly growth

Worked example: checking the issuer's numbers

You can rebuild the headline figures from the table above with a calculator.

Spot the red flag

GOP's fee is only $1 a year higher than NANC's. Which line makes it the costlier fund to buy and sell?

Costs on a $10,000 investment$

NANC yearly fee, 0.72%72NANC's all-in management fee.GOP yearly fee, 0.73%73Just $1 more than NANC's.NANC spread cost per round trip, 0.19%19The tighter spread, thanks to roughly three times GOP's assets.GOP spread cost per round trip, 0.31%31About $12 more than NANC's per round trip, twelve times the fee gap.

Tap the line you think is the tell.

Spotted it.Not that line. The spread, not the fee. On a $10,000 round trip, GOP's wider bid-ask spread costs about $12 more than NANC's ($31 − $19), against a $1 gap in yearly fees.

Explain every lineHide the other explanations

The prospectus shows $74 rather than $72 for year one mainly because the standard SEC fee example assumes the investment grows 5% a year, so the fee applies to a slightly bigger balance.

The spread cost is a rough guide: buying at the ask and later selling at the bid costs you about one spread per round trip. On a $10,000 round trip, GOP's wider spread costs about $12 more than NANC's ($31 − $19), far more than the $1 gap in their yearly fees.

What they hold

The top of each portfolio reflects what the party's members reported trading most. Ten largest positions, September 18, 2026:

Holdings change as PTRs arrive; the issuer posts the full list daily: NANC holdings, GOP holdings.

Five big tech names make up almost a third of NANC

• 30.47%NVIDIA, Microsoft, Alphabet, Amazon, Apple
• 16.14%Next five largest
• 53.39%Everything else

One member filing many purchases can push a stock up the weighting, so a big position may reflect one household. The trades-by-ticker index shows how many House filers disclosed a stock and in what value ranges.

Member research: The holdings list tells you what members bought, not whether those businesses are worth owning. Take AMD, 2.95% of GOP: our AMD case study tests what its CPU and accelerator evidence showed as of February 4, 2026, using only what was public then.

Why the lag can't be fixed

Under "Reporting Delay Risk": "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."

PTRs also report value bands such as $1,001–$15,000, not share counts, so positions are sized from ranges, and one 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 just mirrored. Source: prospectus risk section.

Worked example: what 45 days can cost

Hypothetical example with round numbers. A member buys a stock at $100 and files on day 45. By then the stock is $110, and the fund buys. Later the member sells at $120, files 45 days after that, and the fund sells at $105.

Make a guess

Same stock, same decisions: the member made 20% on the round trip. What did the fund make, buying and selling 45 days later?

Tap your guess

It lost moneyYour guess0% to 10%Your guess10% to 20%Your guess20% or moreYour guess

−0123456789.0123456789%Fund return

Spot on.Close, a little low.Close, a little high.Way off, too low.Way off, too high. It was −4.5%.

About −4.5%. The fund bought at $110 and sold at $105, while the member bought at $100 and sold at $120. The result depends on what happens during the lag.

Fund return−4.5%

Member return+20.0%

Same stock, same decisions, opposite outcomes. The numbers are invented, but the mechanism is the one the prospectus describes. It can also work in the fund's favor when a stock keeps rising after disclosure. The point is that the fund's result depends on what happens during the lag, not only on what members chose.

The legal risk: the Ethics in Government Act bars using a disclosure report "for any commercial purpose, other than by news and communications media," a clause every Senate eFD user must acknowledge. With no definitive ruling on whether the adviser's use counts, the prospectus warns of "monetary penalties and other liabilities or injunctions" that could force a strategy change or liquidation.

Performance the issuer reports

The issuer's standardized figures as of August 31, 2026, compared with the S&P 500 total return, which includes reinvested dividends. Quarter-end figures as of June 30, 2026 are also on each page (NANC, GOP).

The last two columns are our subtraction: for example, 19.32% − 20.38% = −1.06 percentage points.

Each fund beat the S&P 500 over one period and trailed over the other

GOP, one year+6.96 pts

NANC, since inception+2.26 pts

NANC, one year−1.06 pts

GOP, since inception−2.65 pts

Both funds are concentrated portfolios built from a few hundred filers' disclosures, measured against a broad index, so a stretch when a handful of disclosed names did well dominates the result.

Try it yourself

You don't need either fund to read the same PTRs. Our politician-trades directory covers House and electronically filed Senate reports for the 2025 and 2026 filing years, with a most-active members ranking and a congressional-trades dataset that keeps the filing URL on every row. They show what the ETF hides: whose account traded, how long filing took, and how wide the range was.

1. Pick one name from the top-10 table above, such as NVIDIA or Comfort Systems USA.
2. Look it up in the trades-by-ticker index and count how many members disclosed it.
3. Open one trade and note the owner, transaction date, filing date, and value range. Subtract the dates to get the lag.
4. Follow the filing link to the original PDF and confirm the fields match.
5. Enter the range into the range uncertainty calculator to see how wide the possible trade size is.

You should now be able to answer: is this holding driven by many members or by one household, and how stale were the filings behind it by the time the fund could act? For more on each field, see how to read a congressional disclosure, then compare tools in our tracker roundup.

Our read

These ETFs are a convenient, delayed copy of public filings. You pay 0.72–0.73% a year for someone to size positions from ranges, weeks after the trades. The record doesn't show that beats the market: each fund leads the S&P 500 over one period and trails over the other.

What we'd watch:

• Holdings count. Whether NANC reaches its own 100-to-200 target.
• The legal question. A ruling on commercial use of PTR data.

Questions readers ask

Is NANC the "Nancy Pelosi ETF"?

Not in the way the nickname suggests. The fund follows reported trades by registered Democratic members of Congress as a group and weights stocks by the level of reported trading. No single member's portfolio is being copied.

Are KRUZ and GOP the same fund?

Yes. The Republican fund changed its ticker from KRUZ to GOP on March 21, 2025, and the July 31, 2026 supplement changed its name to the Subversive Congressional Republicans Trading ETF.

Can a fund that trades weeks late still beat the market?

It can over some periods, but the record so far is mixed, and the lag cuts both ways. As of August 31, 2026, each fund led the S&P 500 over one period and trailed it over the other.

Is it cheaper to follow the filings myself?

The filings are free, so reading them costs only time. The fund charges 0.72–0.73% a year, which is $72–73 on $10,000, to do the reading and rebalancing for you. You face the same 45-day delay either way.

Go deeper with member research

Several of the funds' top holdings are companies we've researched in depth. Start with NVIDIA, NANC's largest position, then the GOP names:

• NVIDIA’s growth has a financing bill: Our free issue on NVIDIA’s receivables, supply commitments and what they mean for the price you pay.
• Issue 05: NVIDIA Is Building the Credit Market for AI: How NVIDIA turns its roadmap into cheaper capital for customers, and why AI infrastructure could move into private credit, insurance balance sheets and securitized debt.
• Comfort Systems and the scarce capacity behind AI construction: Whether the backlog and cash conversion looked investable on February 20, 2026, and what the later gains really rewarded.
• Intel’s manufacturing option needs a cash-flow bridge: What Intel’s recovery evidence showed on January 23, 2026, separated from the catalysts nobody could have predicted.

Limits of this data

• Holdings, assets, fees, and disclosures change; figures here are from the issuer's pages on September 17–18, 2026.
• Performance numbers are the issuer's, not recomputed by us, and past performance does not guarantee future results.