Interested in starting an ETF? Simply want to learn more about the process of launching an ETF? This piece is an introduction to ETF white label services, which is the industry term for a firm that helps an “ETF-prenuer” bring an idea to the public market. We will map out the typical use-cases for an ETF, the basic process to launch an ETF, the high-level costs of launching an ETF, and the niche group of specialized providers who can help you bring an ETF to market.

Before we dive in on ETF white label services, we’ll share our story of how we ended up in the ETF business.

Not many people know the history of Alpha Architect. I’ll spare you the details, because it involves 3 failed attempts in the asset management business, to include the launch of a small value quant hedge fund in September 2008. Great timing, eh? Building a solid investment strategy is one thing. Building a solid investment business adds an additional set of challenges.

After getting punched in the face several times, we finally caught a lucky break. Alpha Architect was formed in July 2010 and was eventually seeded by a huge family office in 2012. Several years later, we launched an ETF business via angel funding from an SMA client in late 2014. We essentially took the investment strategies from separately managed accounts (private) to the world via ETFs (public) as we believe ETFs were a superior structure.

Fast forward to 2020. We’ve managed to spend a decade strategically minimizing the chance that we ever have to get a real job and I’ve managed to lose 95% of my hair. Some may not consider this success, but hey, we are living our own adventure and we don’t have to file TPS reports, so not all is lost!

All joking aside, why bore you with our history? We want to make the point that we strongly empathize with entrepreneurs and the challenges they face to get a financial services business off the ground. We’ve been there. But now that we’ve survived for a decade in a cutthroat business, we sometimes forget just how challenging the world can be for new business owners who seek to bring their ideas to the financial marketplace.

Case in point: Perth Tolle.

I originally ran into Perth at an ETF.com conference in Florida. Perth pitched me on her passion for ETFs, her passion for freedom, and her desire to combine the two concepts. I was 50% sold. Freedom sounded great. ¹ However, I was a bit sour on the other 50% — the whole “launching an ETF” aspect of the deal. After bearing witness to the insane competition in the ETF industry, along with the high fixed costs of launching an ETF, the prospects of launching someone else’s ETF idea wasn’t exciting. I politely told Perth, “No thanks.”

Fast forward to 2018. Perth continued to express her passion to launch an ETF. I kept providing obstacles: “Where’s your funding?” “Where are your investors?” “Do you know how terrible the ETF business is these days?”

And then I provided excuses: “We don’t want to open our ETF platform. We don’t have the bandwidth to deal with this right now.” The back and forth continued. Perth was the hungry entrepreneur, I was Mr. No.

But to Perth’s credit, she addressed every obstacle we put in front of her: she raised operating capital and identified some heavy-hitting investors. She convinced us we could open our ETF operating platform and help ETF-prenuers enter the game. We were sold. Alpha Architect was going to enter the so-called “ETF white-label business” and offer our infrastructure and know-how to help ETF-preneurs fulfill their dreams.

Why Launch an ETF?

The ETF structure is certainly not a panacea and every investment delivery vehicle has different strengths and weaknesses.

Here are some basic costs and benefits of the ETF wrapper versus other investment vehicles:

• Potential costs
  • High fixed costs (i.e., a magnitude more expensive than launching an LP or SMA)
  • High transparency (i.e., the world will know what you own)
  • Distribution transparency challenges (i.e., hard to identify who sold what)
• Potential benefits
  • Transparency (i.e., the world will know what you own). This can be positive or negative depending on the audience.
  • Tax-efficiency (i.e., the potential to defer capital gains on equity, bond, and options instruments via in-kind transactions)
  • Market access (i.e., type in a ticker and the buyer is now a proud owner of your investment strategy)
  • Operational efficiency (i.e., one can manage a tactical strategy via one ETF versus 1,000 SMA accounts)

Here are the typical use cases we have seen:

• Asset manager (e.g. hedge fund manager or mutual fund manager) with an active stock selection strategy looking to gain operational efficiency and the tax advantages of the ETF
• RIA looking to simplify their trading operations and improve tax-efficiency
• Research and development firms with unique intellectual property and a broad audience that seek to monetize their IP via asset management

What are the Basic Requirements for Launching an ETF?

The process for launching an ETF can be broken into 4 phases:

1. Planning
2. Pre-launch
3. Launch
4. Ongoing management.

We include some generic timelines on each phase, but these vary wildly depending on the situation. On one extreme, if you are squared away and we have some luck on the responsiveness of regulators, we can get an ETF launched in 3-4 months. On the other hand, if you require more coaching, are trying to do something extremely innovative, and we have bad luck on the regulator front, it might take 12-months + to launch an ETF.

Below, I outline each of these phases and how we would tackle them. Other parties likely follow a similar path.

1. ETF Planning Phase (0 to 6 months)

• Implementation timeline
• Regulatory workplan
• Distribution workplan
• Economics, pro forma finalization
• Contracting, licensing as needed
• Competitor analysis

2. ETF Pre-Launch Phase (2 to 6 months)

Pre-launch is the second phase of bringing an ETF to market. This phase is fairly work-intensive for our side and your side. Be prepared to put the time in so your ETF launch is a success. A few of the items we’ll take care of in this phase are as follows:

• Index creation / data construction
• Registration / prospectus drafting
• Iteration with regulatory agencies (i.e., SEC)
• Data controls established
• Vendor management
• Board approval, Trustee engagement

3. ETF Launch Phase (1 month)

Launch is the third phase of bringing an ETF to market. At this point, the plan is in motion and it is time to execute. A few of the items we’ll take care of in this phase are as follows:

• Basket creation
• Exchange listing completion
• Marketing coordination
• Capital markets management
• Seed capital deployment
• Index coordination (as required)

4. ETF Management Phase (Ongoing)

Ongoing management of the ETF is the final phase of the ETF process. We are officially live and it is now time to share your wonderful idea with the investing public. A few of the items we’ll take care of in this phase are as follows:

• Vendor management
• Printing/filing
• Regulatory disclosures
• Liquidity assessments and filings
• Ongoing marketing
• Invoicing/vendor payments
• Dedicated compliance team, supported with external counsel

How Much Does it Cost to Launch an ETF via an ETF White Label Platform?

Launching an ETF is a highly complex operation with a lot of moving pieces, which means the precise cost estimate will be highly dependent on the situation. However, the items below will give the aspiring ETF entrepreneur the ballpark all-in costs for a standard US-equity-only, quarterly-rebalanced, in-kind ETF.

We break our cost estimates into 4 components:

1. Start-up costs
2. Fixed costs
3. Initial variable costs
4. Scale variable costs

1. Start-Up ETF Costs:

Start-up costs cover all the costs of the initial consultations during the planning and pre-launch phase and the costs to get the legal and compliance documentation prepared and finalized. The all-in costs for a no-frills fairly generic fund are typically around $50,000, but this figure can vary wildly depending on a number of factors. The costs for ETF start-up can easily range from $30k to $150k+.

2. Fixed ETF Costs:

We have tried to make the pricing on ETF white label as transparent as possible. In our own experience, the pricing typically involves some sort of fixed element, with a million footnotes highlighting random “nickel and dime” costs. Well, when you add up the nickels and dimes they end up being material costs. So, our fixed costs estimate internalizes and underwrites everything into one simple figure.

All-in, you are looking at around $225k/year (But this can range from $190k to $300k+). If you are looking to trade in international markets, where custody costs are presumably higher, the costs will increase. Also, if the ETF is unable to be traded “in-kind” there will likely be additional costs. Of course, there are other circumstances where the fixed costs could be lower. Again, this is merely a high-level estimate and a starting point for a discussion.

3. Initial Variable ETF Costs:

In addition to the fixed costs, there are several variable costs that we pass through to ETF servicing clients. These include marketing material review costs from our broker/dealer partner and FINRA as well as pass-through costs from the SEC (24f-2 fees). We typically advise that these costs will be around $25k/year, but can vary considerably depending on the volume of marketing materials required.

4. Scale Variable ETF Costs:

In the beginning, an ETF operation is dominated by fixed costs, however, the marginal costs of operating an ETF are not zero. As part of our pricing schedule, at scale, we pass through variable costs that cover the costs we incur from our service providers and the costs we expect to incur as an ETF grows in size.

The scale variable costs are additional costs on top of the fixed costs mentioned above:

• 6-10+ bps on AUM above $100M and below $250M
• 4-8+ bps on AUM above $250M and below $500M 
• 2-6+ bps on AUM above $500M 

A Quick Example

Let’s say you launch an ETF and the fund scales to $400mm and you charge 50bps (an incredible smashing success). We will also assume you are in the mid-range on the estimates above.

Here is the generic profit/loss breakdown:

• Revenue = 50bps* 400mm = $2mm
• Servicing costs: $225k fixed costs + 8bps(250mm-100mm)+6bps*(400mm-250mm) = 225k +120k + 90k = 435k
• Variable costs: $400 * (129.80) + 15k marketing materials ² = 67k
• Gross profits = $2mm – 435k – 67k = ~1.5mm

Again, the discussion above is meant to get the aspiring ETF-prenuer oriented on the ballpark costs they can expect to face when launching an ETF.

The key takeaway is that launching an ETF is not a simple or cheap operation. Before tackling this endeavor, you’ll want to have the operating capital necessary to manage operations for at least 3 years and have a reasonable ability to attract new investors over time.

Conclusion

We believe the tax-efficiency, transparency, and low-cost nature of the ETF structure will ensure that the investment vehicle remains a favorite for investors in the future. Setting up an ETF is a serious endeavor that requires a full commitment. We encourage asset managers and financial advisors to explore the vehicle as a potential way to enhance their client experience and to fine-tune their value proposition in a highly competitive market.