Summary The index for CEFL/YYY was last rebalanced in December 2014, and changes to the index were made public a few days before the event. Last year, heavy buying or selling pressure in particular index components forced CEFL/YYY to buy-high and sell-low, causing significant losses to CEFL/YYY unitholders. How will CEFL’s rebalancing be handled this year? Introduction The ETRACS Monthly Pay 2xLeveraged Closed-End Fund ETN (NYSEARCA: CEFL ) is a 2x leveraged ETN that tracks twice the monthly performance of the ISE High Income Index [symbol YLDA]. The YieldShares High Income ETF (NYSEARCA: YYY ) is an unleveraged version of CEFL. CEFL is popular among retail investors for its high income, which is paid out monthly. (Source: Pro Spring Team ) YLDA holds 30 closed-end funds [CEFs], and is rebalanced at the end of every calendar year. The changes were publicly announced on the ISE website on Dec. 24, 2014, or about five days prior to the rebalancing event. According to YYY’s prospectus (emphasis mine): Index constituents are reviewed for eligibility and the Index is reconstituted and rebalanced on an annual basis. The review is conducted in December of each year and constituent changes are made after the close of the last trading day in December and effective at the opening of the next trading day . As CEFL is an ETN, it is not forced to buy or sell the constituent ETFs, but one would imagine that the note issuer, UBS (NYSE: UBS ), would be inclined to do so to hedge its exposure of the note. Rebalancing shenanigans Unfortunately, CEFL/YYY unitholders were hurt by the rebalancing mechanism last year. I first noticed that something was wrong when CEFL fell -2.96% (and YYY -1.25%) on Jan. 2nd, 2015, a day where both stocks and bonds held relatively steady, and where the comparable PowerShares CEF Income Composite Portfolio ETF (NYSEARCA: PCEF ), an ETF-of-CEFs that tracks a different index, rose +0.21%. A bit of detective work on my part revealed that the CEFs that were to be added to the index received heavy buying pressure in the days between the index change announcement and rebalancing day, while the CEFs that were to be removed came under tremendous selling pressure. This caused the prices of the added CEFs to rise significantly during that period, which was topped off by an upwards price spike on rebalancing day, while the prices of the CEFs to be removed declined markedly in price, culminating in a downwards spike on rebalancing day. As a consequence, the index and hence YYY were forced to “buy high and sell low” on rebalancing day, causing about 1.3% of the net asset value [NAV] of YYY to be vaporized in an instant. This findings were presented in my Jan. 4th article ” Frontrunning Yield Shares High Income ETF YYY And ETRACS Monthly Pay 2xLeveraged Closed-End Fund ETN CEFL: Could You Have Profited ?” However, the pain was not over for CEFL/YYY holders. The upwards price spike of the CEFs to be added on rebalancing day occurred on top of the artificially-inflated prices caused by the buying pressure days before the actual event. After rebalancing, the added CEFs possessed premium/discount values dangerously above their historical averages, as I warned in ” Beware Reversion In YieldShares High Income ETF And ETRACS 2x Closed-End Fund ETN ,” leading to further losses as the premium/discount of those CEFs reverted back to their original levels. How much were CEFL/YYY investors hurt? How much were CEFL/YYY holders hurt by last year’s rebalancing mechanism? It is impossible to provide an exact number, but here is my estimate. The 10 added CEFs with the largest increases in allocation rose by 2.96% in one week, while the 10 with the largest decreases in allocation declined by -3.38% in one week (as presented in my Jan. 4th article). Assuming that CEFL is equally-weighted*, these events would have caused an overall 2.11% decline in asset value. Up to a further 1.25% was lost on rebalancing day due to price spikes. Moreover, the 10 CEFs that were added to the index declined by 1.26% two weeks after rebalancing as mean reversion possibly took place (as discussed in ” 2 Weeks Later: Did Mean Reversion Of CEFs Take Place? “), contributing a further 0.42% decline of the index, again assuming equal-weight. This sums to a 3.8% loss for YYY holders, or about a 7.6% loss for CEFL holders, not an insignificant amount. Note that this number is likely to be an underestimate because only the top 10 CEFs undergoing the highest increases and decreases in allocation were considered. In actuality, 19 funds were added, and 17 were removed. *(CEFL is actually not equal-weighted, but it is not entirely top-heavy either. See my Jan. 4th article linked above for details to the index weighting methodology). An alternative methodology for calculating the underperformance of CEFL/YYY is to simply compare the performance of YYY to PCEF, as both are ETFs-of-CEFs, but track different indexes. As analyzed in ” Has CEFL Done As Badly As It Looks? ” YYY underperformed PCEF by a total of 5.3% in the months of December and January, i.e. the months surrounding the rebalancing date. Although this approach is only approximate (as the exact composition of the two funds differ), it does produce a number that is on a similar order of magntitude as the 3.8% loss calculated with the first approach. Either way you cut it, a 4% or higher loss for the index/YYY (double that for CEFL, due to leverage) because of factors outside of “normal” market behavior hurts. Moreover, the fact that the index was forced to buy high and sell low necessarily results in a lower income for the fund going forward, as the fund would not have been able to purchase as many shares of the new CEFs than it “should” have been entitled to. Indeed, each share of CEFL paid out a total of only $4.03 in 2015, down from $4.40 in 2014, representing a 8.5% decrease in income paid for the year. I lost…so who won? So if CEFL/YYY unitholders were hurt during rebalancing, who profited? Most likely, it was the savvy investors who purchased the CEFs to be added to the index and shorted the CEFs to be removed as soon as the index changes became public. This could, in fact, include UBS themselves, who are free to adjust their hedges for CEFL anytime they like (because CEFL is an ETN rather than an ETF), and not only on rebalancing day. This creates an ironic situation in which the act of UBS adjusting their hedges at more favorable prices before rebalancing could have actually and directly hurt investors in their very fund. Why is this a problem for CEFL and not other funds? The main problem appears to be the lack of liquidity for CEFs, as well as the fact that arbitraging price differences for CEFs can be risky as they often trade at premium or discount values around their intrinsic NAV, meaning that it would be difficult for arbitrageurs to determine the “true” value of a CEF. An insightful comment from a reader in my previous article reveal that this has happened to other funds as well, and also illustrates a possible solution to this problem: [We] also had a FTSE 100 tracking fund run externally by a well known global indexing house. I recall at one index rebalance, said fund had a MOC order to buy one of the new index constituents, and ended up paying about 25% MORE than the prevailing market price was 1 minute before. All index tracking funds got completely shafted as guess what, the next day the stock was back down to the price it was before its index inclusion. … Some index managers get friendly brokers to ‘warehouse’ stocks (take them onto their own book) for a few days, buying them up ahead of inclusion in a particular index, the fund then takes an average price, and doesn’t get the shaft with a MOC order. It can lead to a bit of ‘tracking error’ mind you. This time it’s…different? As a CEFL unitholder and with the end of the year rolling around, I thought I would refresh myself on the rebalancing mechanism of the index YLDA to confirm exactly when the CEF changes would be announced, so that I could…uh…you know…get in on the frontrunning action and profit at the expense of fellow CEFL/YYY holders. Just kidding, I would have definitely shared this information with all my loyal readers! (Please do click the “follow” button next to my name if you haven’t done so already if you enjoy my ETF analysis.) So I fired up the YLDA methodology guide and looked for the rebalancing date… and looked, and looked…only it wasn’t there! I then checked the date of issue of the methodology guide: December 4th, 2015. So this couldn’t have been the guide I was reading when I was writing my earlier CEFL articles this year. Luckily, I had a version of the guide stashed in my downloads folder, and the relevant section (4.3) is dutifully reproduced below (emphasis mine): 4.3. Scheduled component changes and review ( OLD v1.2 ) The ISE High IncomeTM Index has an annual review in December of each year conducted by the index provider. Component changes are made after the close on the last trading day in December , and become effective at the opening on the next trading day. Changes are announced on ISE’s publicly available website at least five trading days prior to the effective date . How does this compare with the current version of the methodology (emphasis mine)? 4.3. Scheduled component changes and review ( NEW v1.3 ) The ISE High IncomeTM Index has an annual review in December of each year conducted by the index provider. The index employs a “rolling” rebalance schedule in that one third of component changes are implemented at the close of trading on each of the first, second and third trading days in January of the following year and each change becomes effective at the opening on the second, third and fourth trading day of the new year, respectively. No prizes for spotting the difference! Not only has the statement about the announcement of changes been removed, the rebalancing is now not performed all at once at the close of the last trading day in December, but is now equally spread through the first, second and third trading days of the following year. I then used the free PDF comparison tool ( DiffPDF ) to scan for any additional changes to the methodology between last and this year’s. Besides being nearly foiled by the addition of two blank pages in this year’s edition, the software showed that, besides the aforementioned change in Section 4.3, a similar statement to the above had been removed from the index description in Chapter 2: Chapter 2. Index Description ( bold sentence in OLD guide only ) Companies are added or removed by the ISE based on the methodology described herein. Whenever possible, ISE will publicly announce changes to the index on its website at least five trading days in advance of the actual change . No changes were made to the constitution or weighting mechanisms of the fund. Appendix B of the current document lists the entirety of the changes as “Rebalance revision (4.3).” What does this mean for investors? Analysis of the old and new methodology guide reveals two major changes: The changes to the index will not be public beforehand. Instead of rebalancing the components all at once, the rebalancing will be conducted in three equal parts spread across three days. What does this mean for investors? I believe that the first change is well-intended, but may ultimately prove fruitless. The methodology for index inclusion and weighting is relatively complex, but is publicly available (it’s found in the methodology document), and I have no doubt that professional investors will be able to determine the changes even before they happen. In fact they may be doing this right now as I am writing this, and also later, when you are reading this. The second change is, I believe, a positive one, but only if it means one of two possible ways that one could construe “one-third.” The guide states that ” one-third of component changes are implemented… on each of the first, second and third trading days in January .” So if 10 CEFs have to be added to the index, does it mean that 33.3% of the total dollar value of the 10 CEFs will be purchased on each of the three days? In this case, the liquidity situation will be improved because each CEF will be purchased over three days. This would decrease the likelihood of a price spike occurring upon rebalancing (presumably by YYY, the ETF), which ameliorates the buy-high sell-low situation faced by the index last year. If instead, it means that 4 CEFs will be 100% purchased on the first day, 3 on the second, and 3 on the third, then unfortunately I don’t think that the liquidity situation will improve, as the trading in each CEF is still going to be concentrated in a single day, despite the fact that different CEFs may be spread out on different days. What do readers think about how this sentence should be interpreted? So, it appears that this time may actually be different. However, personally, I’m not waiting around to find out. I’ve recently sold all but a single share of CEFL to keep my interest in the fund, and replaced it with several better-performing CEFs (such as the PIMCO Dynamic Income Fund (NYSE: PDI )), as recommended in Left Banker’s article here .