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EventShares 2Q 2019 Policy Tracker

05.02.2019 | Ben Phillips, CFA

EventShares Policy Tracker

Policy Tracker 3Q18 blog image BIG

(click to enlarge)

 

The EventShares Policy Tracker is a summary of the current legislation and regulations our investment team is monitoring in Washington D.C. The above image displays each of these items by market sector.

 

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Below we provide a short summary of each policy item, including links to primary source documents, such as a bill, press release, or agency rulemaking notice. We also provide our view on how the policy may impact both market segments and individual companies. At the bottom of each policy section, you can find a link to relevant EventShares research reports.

 

This Policy Tracker was last updated 5/2/2019 for the 2nd Quarter 2019. Sign up below to receive the quarterly Policy Tracker!

 

 

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Financials


 

Capital Markets

 
  • Impacted Companies
    • Stock Exchanges (+) CBOE, ICE, NDAQ, CME

 

  • Market Impact: SEC Commissioner Jackson questioned the business model of stock exchanges selling market data through a combination of public and private feeds. Jackson claimed the exchanges under-invest in the public data feeds, while at the same time over-invest in their private data feeds. Regulation of private data feeds may lead to lower revenue and / or discontinuation of private feeds, which are a source of significant revenue for stock exchanges.

 

  • Our Take / Timing: Commissioner Jackson's speech is an important policy to monitor in our view. It highlights a potential priority of the SEC in the coming years. However, as a minority commissioner, Jackson doesn't hold much sway at the moment. This could take multiple years to unfold.

 

 

 

Deregulation - SIFI Threshold

 

  • Impacted Companies
    • Super Regional Banks (+) ASB, KEY, AXP, STI, BBT, FITB, PNC, MTB, USB

 

  • Market Impact: Systemically Important Financial Institution (SIFI) threshold raised from $50 billion to $250 billion may benefit smaller, regional banks by lowering their compliance costs. Increased potential for regional bank M&A as banks look to scale their operations. A decrease in capital requirements may free up cash to return to shareholders or grow the business, while relaxing oversight may lead to lower compliance expenses.

 

  • Our Take / Timing: This is an example of a law that has already passed Congress and is now in the hands of a federal government agency. The next step is for the agency to implement the law, which is currently occurring.

 

 

 

Fannie Mae & Freddie Mac Privatization

 

  • Impacted Companies
    • Government Sponsored Housing Entities (+) FNMA (Common stock), FMCC (Common stock), FNMAS (Preferred stock), FMCKJ (Preferred stock)

 

  • Market Impact: The U.S. government seized control of Fannie Mae and Freddie Mac during 2008 in an attempt to support the U.S. housing market. The role of the GSEs is under review today. The market and economy have recovered from the depths of 2008. The question is: Should the GSEs continue to be government owned? Or should they be allowed to return to private ownership?

 

  • Our Take / Timing: This policy has been kicked around Capitol Hill for the last decade. It rises to the top of the news flow every so often when something "big" happens. Two things happened recently: (1) Mark Calabria, a supporter of privatization, took over the FHFA and (2) Donald Trump signed an executive order directing the Treasury and HUD to "craft administrative and legislative options for housing finance reform".

 

 

LEARN MORE: This research is a byproduct of our active ETF.

 

 

 

Gambling


 

Sports Betting

 

  • Impacted Companies
    • Bookmakers (+) WMH (GB), GVC (GB)
    • Casinos (+) PENN, BYD, ERI, CHDN, MGM
    • Gaming Technology (+) IGT, SGMS, TSG

 

  • Market Impact: SEC Commissioner Jackson questioned the business model of stock exchanges selling market data through a combination of public and private feeds. Jackson claimed the exchanges under-invest in the public data feeds, while at the same time over-invest in their private data feeds. Regulation of private data feeds may lead to lower revenue and / or discontinuation of private feeds, which are a source of significant revenue for stock exchanges.

 

  • Our Take / Timing: Commissioner Jackson's speech is an important policy to monitor in our view. It highlights a potential priority of the SEC in the coming years. However, as a minority commissioner, Jackson doesn't hold much sway at the moment. This could take multiple years to unfold.

 

 

 

 

Education


 

Student Lending and Loan Servicing

 

  • Impacted Companies
    • Student Lenders (+) NNI, NAVI, SLM

 

  • Market Impact: The Department of Education is currently working to update the federal student loan program through a project called NextGen. The overhaul initially focused on selecting one company to service student loans. However, that request for proposal (RFP) was later ended and a new RFP is being opened after lawmakers and student debt activists highlighted the risk of one company controlling the student loan servicing market. As part of the NextGen proposal, the student loan servicers would assume the role of debt collection over private debt collection agencies. In our view, this could be positive for company revenues if the companies can successfully work with the student to avoid a default, which would allow the companies to continue earning fees by servicing the loans.

 

  • Our Take / Timing: Student loan servicing is an important policy item due to the high number of students incurring student debt. Most movement will primarily be regulatory driven in our view. While regulation may be decreasing, issues with debt collection and lawsuits cause us to be cautious with student lending companies. In the background, state attorneys general and students continue to file lawsuits against multiple student loan servicers. The students claim the companies did not follow regulations when helping them restructure and pay off their loans. This is a major risk for the companies.

 

 

 

Higher Education Rules Overhaul

(e.g. Gainful Employment & Accreditation Regulations)

 

  • Impacted Companies
    • For Profit Colleges (+) CECO, ATGE, LAUR, LOPE, STRA

 

  • Market Impact: The Trump administration, via the Department of Education (ED), recently released a group of sweeping proposals to deregulate a broad range of the higher education industry. The rules range from granting accreditation agencies more leeway to approve nontraditional educational models (e.g. online programs and outsourcing classes), enhance protections for religious colleges, and eliminate the Obama administration definition of a "credit hour". The above is in addition to the ED proposal to rescind the Gainful Employment Rule and update the ‘College Scorecard’ to provide information on all Title IX institutions, not just for profit and nontraditional colleges.

 

  • Our Take / Timing: The Trump administration is pushing aggressively to deregulate the education industry, especially for-profit colleges. The regulations impact a significant piece of the education business model: federal student aid dollars. By giving college accreditors more independence, the ED is indirectly supporting revenue and enrollment growth at for profit colleges. Whereas the Obama administration tended to cut off federal student aid for students attending certain colleges, the Trump administration is attempting to walk back restrictions arising from bad behavior and student complaints. In our view, this removes a risk from the education industry business model.

 

 

  

 

Technology


 

Social Media and Data Regulation

 

  • Impacted Companies
    • Social Media (-) FB, TWTR, GOOGL, AMZN
    • Data Brokers & Aggregators (-) RAMP, CLGX, IPG
    • Credit Reporting Agencies (-) EFX, TRU

 

  • Market Impact: Rapidly expanding technology and social media companies may not be able to collect and monetize individual user data resulting in less data revenues. Third-party data brokers and aggregators may face increased compliance costs and/or not be permitted to compile user data to target specific advertising groups. This would be a significant disruption to their business models. Credit reporting agencies may be subject to increased compliance costs. Incoming House Democrats have made it a priority to monitor credit reporting agencies and how they safeguard sensitive consumer data.

 

  • Our Take / Timing: Various committees in both the House and Senate have called executives from the major tech companies to testify before Congress. Republicans accuse them of censorship, while Democrats are concerned about user privacy. Globally, governments are starting to awaken to the need for data regulation. The E.U. has largely taken the lead by passing GDPR and fining technology companies that mismanage data. In our view, technology companies will continue to face headline risk related to data scandals and governmental oversight.

 

 

 

Deregulation - SIFI Threshold

 

  • Impacted Companies
    • Super Regional Banks (+) ASB, KEY, AXP, STI, BBT, FITB, PNC, MTB, USB

 

  • Market Impact: Systemically Important Financial Institution (SIFI) threshold raised from $50 billion to $250 billion may benefit smaller, regional banks by lowering their compliance costs. Increased potential for regional bank M&A as banks look to scale their operations. A decrease in capital requirements may free up cash to return to shareholders or grow the business, while relaxing oversight may lead to lower compliance expenses.

 

  • Our Take / Timing: This is an example of a law that has already passed Congress and is now in the hands of a federal government agency. The next step is for the agency to implement the law, which is currently occurring.

 

 

 

5G Development

 

  • Impacted Companies
    • Network Infrastructure Providers (+) ERIC, NOK, CIEN, DY
    • Communications Hardware (+) QCOM, SWKS, QRVO, CSCO, XLNX
    • Cell Towers & Comms Equipment (+) ZAYO, AMT, GLW, CCI, UNIT, SBAC, UBNT, WIFI, CMTL, COMM, MSI
    • Technology Patents (+) IDCC
    • Telecoms (+) T, VZ, S, TMUS

 

  • Market Impact: 5G development is an increasing priority for both the U.S. and China, which was a primary factor in the Trump administration's blocking of AVGO's takeover of QCOM earlier this year. The Federal Communications Commission (FCC) is one of the agencies tasked with promoting the growth of 5G development. Its strategy includes freeing up wireless spectrum and eliminating barriers to the deployment of communications infrastructure. CIFIUS is the U.S. body tasked with reviewing foreign acquisitions. Recent legislation in Congress has been aimed at reviewing these foreign acquisitions, particularly around technology. In our view, this represents an opportunity for U.S. based communications equipment companies to increase revenue as they participate in the 5G buildout.

 

  • Our Take / Timing: 5G will be the next battleground for global tech supremacy. Policymakers in Washington DC understand the importance of building out the required infrastructure, while at the same time not permitting China to become the dominant 5G player. The 5G battle will play out over the coming years, and we think U.S. policymakers will work to accommodate its growth. The FCC has already taken deregulatory steps, such as decreasing the allowed time for reviews associated with attaching small cells to existing structures and declaring small cells exempt from environmental and historic preservation review requirements (e.g. eliminates cost and delay when deploying small cells).

 

 

LEARN MORE: This research is a byproduct of our active ETF.

 

 

Energy


 

Fossil Fuel and Energy Infrastructure

 

  • Impacted Companies
    • Liquefied Natural Gas Terminals (+) LNG
    • Energy Infrastructure Builders (+) PWR, FLR, HAL

 

  • Market Impact: The Trump administration has aggressively pushed to deregulate energy infrastructure, including natural gas pipelines, oil drilling, and gas shipping terminals. For example, one aspect of the administration's overall plan would shorten the time a state has to issue water permits, which are needed for construction of interstate natural gas pipelines under Section 401 of the federal Clean Water Act. Increasing pipeline capacity and energy transportation networks may lead to increased exports of crude and/or natural gas. The Trump administration has also pushed to redefine "navigable water" under the Waters of the United States rule. If the Trump administration is successful in changing the definition of navigable water, the energy sector may be able to expand infrastructure more quickly and less expensively.

 

  • Our Take / Timing: President Trump campaigned on building energy infrastructure and expanding the U.S. pipeline network. However, the Trump administration has not experienced much success in rolling out new energy infrastructure. We attribute this to broad energy changes away from fossil fuels to cleaner, more renewable energy sources. While the Trump administration has pushed aggressively to save the coal industry, we note that even the president can't stop changing industry dynamics. However, the broad environmental deregulation push will benefit liquified natural gas and oil pipeline development. As the U.S. extracts increasing amounts of oil, the country's infrastructure will have to be built out. In our view, the administration's regulatory actions (e.g. limiting the amount of waterways under federal jurisdiction in the Clean Water Act and opening up federal lands to energy infrastructure) will play a role in that build out.

 

 

 

  

Pharma


 

White House Prescription Drug Price Plan

 

  • Impacted Companies
    • Drug Manufacturers (-) AGN, MNK, VRTX,TEVA, MYL, PFE, LLY, GILD

 

  • Market Impact: The White House's push to increase generic drug approval by FDA may offer pharmaceutical companies with large generic drug lineups the opportunity to take market share from companies with branded drug lineups. Potential regulations include the required disclosure of prices in prescription drug ads and changing the rebate system (see 'Drug Rebates' below).

 

  • Our Take / Timing: The Trump administration has been vocal in pushing its efforts to lower prescription drug prices. It now appears they have a partner in Nancy Pelosi and incoming House Democrats. Lowering prescription drug prices is very politically popular. Potential changes may relate to drug rebates (see below) or how Medicare pays for prescription drugs. In our view, the headline risk increases materially for pharma companies.

  

 

Drug Rebates

 

  • Impacted Companies
    • Pharmacy Benefits Managers (-) CI, CVS, UNH

 

  • Market Impact: Health and Human Services (HHS) submitted a proposed rule entitled “Removal Of Safe Harbor Protection for Rebates to Plans or PBMs Involving Prescription Pharmaceuticals and Creation of New Safe Harbor Protection” to OMB for regulatory review. The proposal appears to follow through on HHS Secretary Azar's comments around removing the prescription drug rebate safe harbor under the Federal Anti-Kickback Statute.

 

  • Our Take / Timing: This policy is related to a 1992 safe harbor of drug discounts under the Anti-Kickback Statute. In our view, this is an example of a leading negative indicator for the PBMs. The business model is opaque, which only creates more legislative and regulatory questions. In our view, progress toward the policy will take a significant time. We believe the earliest this policy could change is 2020, but its more likely the change will not occur until 2021 or later.

 

 

 

  

Healthcare


 

Affordable Care Act & Value Based Reimbursement

 

  • Impacted Companies
    • Hospitals (+ / -) HCA, UHS, EHC, ENSG
    • Health Insurers (+) MOH, CNC, WCG, HUM, ANTM, EHTH, UNH
    • Value Based Reimbursement (+) CERN, TDOC, ASGN, MDRX, OMCL, VCRA, EVH, TRHC, MASI

 

  • Market Impact: A Texas judge recently ruled the Affordable Care Act (ACA) is unconstitutional, which has introduced uncertainty into the health insurance industry and increased the likelihood of a multi-year appeals process up to the Supreme Court. The judge elected to keep the insurance exchanges and law in place while the issue is appealed. Medicaid and Medicare expansion under the ACA may generate increased revenues as the insured population grows. The Trump administration and Republican governors are beginning to look at expending Medicaid/ Medicare, which may increase the insured populations in those government health insurance programs. Healthcare tech firms focused on increasing efficiency by improving patient outcomes and lowering costs may increase revenue as the healthcare sector works to modernize its services, lower costs, and move to a value based reimbursement system.

 

  • Our Take / Timing: The ACA continues to be a significant policy priority. Since its passage in 2010, the ACA has been the subject of both legislative and regulatory changes. In our view, the volatility presents trading opportunities. As a result, we believe investors may being overreacting to the recent Texas court ruling. In the hospital industry, the big story is the move from fee for service to value based reimbursement. This will likely pressure hospital margins in the short-term, with the question being how long the transition will take. To transition to value based reimbursement, hospitals will need to track their patient populations and wide variety of quality measures (e.g. 30 day readmissions, patient outcomes). This will require increased investment in healthcare technology to efficiently monitor quality.

 

 

 

Opioid Crisis

 

  • Impacted Companies
    • Opioid Drug Manufacturers (-) MNK, INSY, JNJ, MYL, ENDP, TEVA
    • Drug Distributors (-) MCK, CAH, ABC

 

  • Market Impact: The House Committee on Energy & Commerce released a report during December 2018 finding that "drug distributors did not conduct proper oversight of their customers and failed to recognize potential red flags". The report also faulted the DEA for not putting in place policies and procedures to prevent the overdistribution of opioids. If the drug distributors are found to have willfully ignored red flags or drug manufacturers are found to have withheld important information about opioid addiction, we believe the companies may experience depress valuation multiples or distract management teams from expanding the businesses.

 

  • Our Take / Timing: Congress held multiple opioid related hearings during 2018 due to the size and volume of opioid related issues in the U.S. The drug manufacturers have been questioned about what they knew and disclosed about opioid dangers, while drug distributors have been questioned about their role in distributing the drugs. In our view, both industries will continue to be subject to headline risk and lawsuits, which may create trading opportunities.

 

 

 

Home Health Reimbursement

 

  • Impacted Companies
    • Home Health (-) LHCG, AMED, CHE, ADUS

 

  • Market Impact: The Centers for Medicare and Medicaid Services (CMS) finalized a proposed rule during October 2018 that changes the way post-acute care (e.g. home health) is reimbursed under the Patient Driven Groupings Model. The rule was a result of the Bipartisan Budget Act of 2018 and focuses on moving toward a values based payment system. The new rule finalized a controversial methodology for calculating reimbursement rates. The new payment rates and methodologies are expected to be in place for fiscal year 2020.

 

  • Our Take / Timing: This is a tough development for the home health industry, which had lobbied CMS aggressively to back off the -6.42% behavioral adjustment. However, CMS feels emboldened by Congress directing the agency to implement the new payment model. We expect the home health industry to continue pushing back against the new rule but are not confident they will be able to successfully lobby for its repeal.

 

 

 

E-Cigarette Ban

 

  • Impacted Companies
    • Tobacco Companies (-) MO, PM, BTI, TPB, VGR

 

  • Market Impact: The Food and Drug Administration (FDA) unveiled its "Comprehensive Plan for Tobacco and Nicotine Regulation" in July 2017. Under the plan, the FDA has launched numerous education campaigns, including "The Real Cost", "This Is Our Watch", and "Every Try Counts". The FDA took additional steps in March 2018 by publishing three Notices of Proposed Rulemaking that would regulate flavored tobacco products and the nicotine level in combustible cigarettes. In the second half of 2018, the FDA sent warnings letters to retailers who illegally sold JUUL pods and requested plans from tobacco companies about how to curb underage usage.

 

  • Our Take / Timing: Flavored e-cigarettes continue to grow in popularity, and the FDA is clearly concerned about underage usage. The FDA issued proposed regulations in 2018 that may impact flavored tobacco and has increased enforcement for convenience stores selling flavored cigarettes and tobacco. The possibility of regulation is frightening for any industry, much less the tobacco industry which has a significant past regulatory overhang. Investors didn't wait to ask questions, and each company's stock significantly underperformed during 2018. Our question is: Did investors overshoot as they sold off tobacco stocks?

 

 

 

LEARN MORE: This research is a byproduct of our active ETF. 

 

  

 

Cannabis


 

Cannabis Legalization

 

  • Impacted Companies
    • Cannabis Companies (+ / -) CGC, CRON, GWPH, TLRY, ACB

 

  • Market Impact: Despite being illegal at the federal level, more and more states are legalizing medical and recreational marijuana. While this trend likely continues, it’s important to note there are significant policy implications that come with legalizing marijuana, which could slow down federal legalization.

 

  • Our Take / Timing: There are significant policy implications that come along with legalizing marijuana. Those include taxing and regulating the product, responding to employer concerns about liability and drug testing, monitoring for driving under the influence, and addressing the marijuana industry’s inability to use federally insured banks. We also question the attractiveness of investing in marijuana. If marijuana is legalized, what is defensible about a grower’s business? Does marijuana simply become another commodity with unattractive grower economics? Questions like these and marijuana stock volatility leave us cautious.

 

 

 

 

 

Aerospace & Defense


 

Appropriations - Defense Spending

 

  • Impacted Companies
    • Defense Primes (+) LMT, RTN, NOC, BA, HII, BWXT
    • Defense Industry Suppliers (+) AVAV, FLIR, AJRD, KTOS, OSIS
    • Aircraft Parts (+) UTX, TDG, HXL, HON, TXT, MOG.A
    • Outsourced IT & Consulting (+) BAH, LDOS, CACI, ICFI, SAIC

 

  • Market Impact: Companies with products that advance the technological capability of the U.S. military may see new revenue growth as the Pentagon and defense hawks push to modernize the military after years of lower defense budgets in the Obama administration. Additionally the Trump administration has previously issued an executive order to speed up and deregulate the process of defense industry sales to foreign allies.

 

  • Our Take / Timing: This is a long tail policy. It starts with Treasury disbursing the money to fund defense contracts, which allows prime contractors to start projects and suppliers to prime contractors to support the primes. The process can take years from start to finish, which makes it important to not get caught up in year-to-year funding battles. With that being said, its all about the budget for FY2020 and FY2021 right now.

 

 

 

Space Force

 

  • Impacted Companies
    • Space Related Defense Contractors (+) NOC, AJRD, LMT, BA

 

  • Market Impact: The Trump administration requested funding for a new military branch during its most recent budget request. The new branch, called "Space Force", would perform space related operations that include missile warning and defense, space situational awareness and reconnaissance with imaging satellites.

 

  • Our Take / Timing: Congressional approval is needed to create a new branch of the military, and Congress must also approve an appropriate budget. It is not clear which way they will go, and both Democrats and Republicans are expressing skepticism towards the idea. This story is unfolding day by day and should be watched closely in the coming months and years. For comparison, the creation of the U.S. Cyber Command – the center for DoD cyberspace activities – took ten years to reach full independent status from its first official proposal. Space Force is even more complex endeavor, so it is reasonable to expect an even longer time frame.

 

 

 

 

 

Trade


 

NAFTA

 

  • Impacted Companies
    • Significant Mexico Operations (+ / -) KSU, UNP, BWA, STZ
    • Significant Canada Operations (+ / -) TAP, COST, PWR, FLR, MGA
    • U.S. Based Auto Suppliers (+ / -) ALSN, AXL, APTV

 

  • Market Impact: Due to the uncertainty around NAFTA negotiations, investors previously sold off companies with significant Mexico and Canada revenue. Now that the negotiations are wrapping up, investors may reinvest in these securities. "Auto Rules of Origin" and the push to source more auto content from high wage paying firms, such as U.S. auto parts suppliers, may increase revenues for the auto parts industry.

 

  • Our Take / Timing: During the G20 Summit in Argentina, U.S., Canada, and Mexico leaders signed the new North American trade pact that is meant to replace the prior NAFTA agreement. However, the trade pact must still be approved by Congress. Incoming House Democratic lawmakers have previously described the agreement as a "work-in-progress", while pushing for more environmental and labor protections. If Democrats push back against approving the agreement, we expect President Trump to return to threats of pulling out of NAFTA. In our view, investors are overlooking NAFTA negotiations because of the China trade headlines. There is still headline risk associated with NAFTA, even though it has been ceremonially signed.

 

 

 

China Trade & Alleged I.P. Theft

 

  • Impacted Companies
    • Asia-Pacific Trade (+ / -) EXPD, MATX, AAWW
    • Agriculture Machinery (+ / -) CAT, DE, AGOC, CNHI
    • Significant Chinese Operations (+ / -) SWKS, QCOM, QRVO, AVGO, MU, WYNN, LVS
    • I.T. & Comm. Equipment (+ / -) INTC, QCOM, NVDA, MU, IBM, AMD, TXN

 

  • Market Impact: Companies involved in the U.S.-Asia Pacific trade corridor may see revenues decrease if trades flow decrease between the U.S. and Asia-Pacific region. Chinese tariffs levied on U.S. agriculture exports (e.g. soybeans) may result in decreased demand for agricultural machinery. Additionally, the U.S. has accused Chinese companies of stealing technology and intellectual property from U.S. companies. If either the U.S. or China determine a merger or joint venture will result in a national security risk, the transaction may not go through. If China implements a policy preventing large cap U.S. companies from accessing the growing Chinese market, those companies may have a competitive disadvantage against foreign companies.

 

  • Our Take / Timing: President Trump and Xi Jinping agreed to a 90-day truce at the November 2018 G20 Summit in Argentina. The truce offers the two sides an opportunity to restart negotiations. While we are encouraged by recent developments, we remain realistic of what can be accomplished during the 90-day truce period. An extension of the truce period appears most likely in our view, and would be a positive catalyst for markets.

 

 

 

 

Industrials


 

Infrastructure

 

  • Impacted Companies
    • Project Management (+) FLR, KBR, GVA, ACM, PRIM, TPC
    • Construction Materials (+) MLM, VMC, EXP, SUM, USCR
    • Construction Equipment (+) CAT, DE, URI, ASTE, HRI

 

  • Market Impact: Companies involved in the privatization of infrastructure assets, such as managing toll roads, may see increased revenues. In addition, companies managing and performing the construction work may see increased opportunities to grow their revenues. Construction material companies, such as asphalt, rock, and steel, may see increased demand under an infrastructure build out.

 

  • Our Take / Timing: Indecision by Congress and the Federal government is pushing state governments and local voters to take matters into their own hands. Consider the 2 points below:
    • 27 other states have increased or adjusted their state gas taxes since 2013. We expect states to continue increasing their transportation budgets via gas tax increases and registration fees.
    • Management teams, such as Granite Construction and U.S. Concrete, are already mentioning state funding as a growth catalyst on their earnings calls..

 

 

 

 

About EventShares

 

EventShares is an investment management firm dedicated to translating legislation and regulation coming out of Washington D.C. into real world investment solutions. The firm's goal is to provide its clients with attractive, long-term results by following a disciplined and differentiated approach to investing.

Headquartered in Newport Beach, CA EventShares serves individuals, financial advisors, as well as institutions and offers its sophisticated investment strategies through active ETFs and separately managed accounts (SMAs).

 

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