Institutional ETF Constituent Overlap Engine

Phase 4 Weights

Dual-Fund Constituent Intersection · Capital Duplication Risk · Blended True Look-Through

MR-007 Statutory Observations

Popular Institutional Pairings

Primary Fund (A)ETF

Expense Ratio15 bps

30D Spread1.0 bps

Holdings120 stocks

Secondary Fund (B)UIT

Expense Ratio9.45 bps

30D Spread1.0 bps

Holdings503 stocks

Weighted Portfolio Overlap

0.0%

Constituent-weighted capital intersection: Σ min(w_A, w_B)

Shared Constituent Names

503stocks

100% of QUAL · 100% of SPY

Unique Capital in QUAL

100.0%

Holdings exclusive to QUAL not tracked by SPY

Unique Capital in SPY

100.0%

Holdings exclusive to SPY not tracked by QUAL

Adjust portfolio weighting between QUAL and SPY to simulate effective expense drag and capital look-through.

QUAL: 70%Portfolio SplitSPY: 30%

Blended Expense Ratio

13.3 bps

0.133% annual asset-weighted drag

Annual Cost per $10k Invested

$13.34 / year

Baseline statutory dollar drag

Look-Through Holdings

25 tracked

Constituent look-through aggregate

Ticker & Company	QUAL Weight	SPY Weight	Overlap Contribution	Blended Weight (70/30)

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