Money Stuff: The Podcast
Episode: Relevant Markets
Release Date: July 25, 2025
Hosts: Matt Levine & Katie Greifeld
Content Focus: Kohl's Corporation (KSS), 351 ETFs, Invesco QQQ Trust (QQQ)

1. Introduction

In this episode of Money Stuff: The Podcast, hosts Matt Levine and Katie Greifeld delve into the resurgence of meme stocks, the intricacies of Section 351 (351) ETFs, and provide an in-depth analysis of Invesco's QQQ Trust (QQQ). The conversation seamlessly blends technical financial insights with witty banter, making complex topics accessible and engaging.

2. The Resurgence of Meme Stocks

Levine and Greifeld kick off the discussion by addressing the comeback of meme stocks. Reflecting on the 2021 frenzy, they compare the current landscape, noting a shift in the dynamics that drive these speculative investments.

Matt Levine [06:07]: "Meme stocks are back."

Katie Greifeld [06:10]: "We're back in 2021. The halcyon days."

The hosts explore why the current wave feels less impactful than its predecessor, attributing it to changes in short interest and the influence of artificial intelligence on stock picking.

Matt Levine [07:21]: "I have to say. Yeah, I'm not feeling it. Are other people feeling it? Am I just old?"

They highlight how hedge funds have altered their short positions, making short squeezes less dramatic but more immediate. The conversation also touches on the role of AI tools like ChatGPT in identifying meme stock opportunities, potentially bypassing traditional coordination platforms like Reddit's WallStreetBets.

Matt Levine [11:55]: "If you want to find the next meme that will go up a lot, your instinct might not be to go to Reddit and ask the people there. Your instinct might be to go to ChatGPT and ask ChatGPT."

3. Understanding Section 351 (351) ETFs

The discussion transitions to Exchange-Traded Funds (ETFs), specifically focusing on Section 351 (351) ETFs. Levine explains the tax-efficient mechanisms that make ETFs attractive compared to mutual funds.

Matt Levine [20:18]: "The real way to understand ETFs is that they are tax dodges."

They delve into how ETFs utilize in-kind creations and redemptions to avoid triggering capital gains taxes, contrasting this with mutual funds that distribute annual capital gains to shareholders. This section provides a clear explanation of the operational advantages of ETFs, emphasizing their role in tax deferral.

Matt Levine [20:31]: "With an ETF you don't pay taxes until you sell the ETF shares."

4. Twin Oak Active Opportunities ETF and Market Implications

A significant portion of the episode is dedicated to analyzing the Twin Oak Active Opportunities ETF. Greifeld outlines the challenges Invesco faces in converting this ETF from a Unit Investment Trust (UIT) to an open-ended ETF, highlighting the complexities of gaining shareholder approval.

Katie Greifeld [27:05]: "The Twin Oak Active Opportunities ETF... has nearly $450 million in assets that could theoretically be all one person."

Levine and Greifeld discuss the potential motivations behind such conversions, including tax deferral strategies for large stockholders with concentrated positions. They explore the logistical hurdles involved in rallying shareholders to approve these changes, noting the immense difficulty in achieving the necessary quorum.

Matt Levine [36:29]: "Wait, let me ask you this question. Can they use their enormous marketing budget to send personal mailings to each shareholder and knock on their door and be like, please vote."

The hosts also speculate on the broader impact on the ETF industry, contemplating whether similar strategies will be adopted for other major ETFs like SPY.

Katie Greifeld [40:35]: "I asked Ana Paglia of State Street Investment Management... if we learn something that we like from this proxy, we will think about it."

5. In-Depth Analysis of Invesco QQQ Trust (QQQ)

Levine provides a technical breakdown of the Invesco QQQ Trust, explaining its structure, fee composition, and the implications for investors. The conversation underscores the profitability mechanisms of ETFs and the delicate balance between marketing expenditures and fee revenues.

Katie Greifeld [34:22]: "Here's something that not a lot of people know or care about."

They scrutinize Invesco's fee strategies and marketing expenditures, questioning the sustainability and transparency of such models. The discussion highlights the complexities investors face in understanding ETF fee structures and the hidden costs associated with heavily marketed funds.

Matt Levine [20:31]: "With an ETF you don't pay taxes until you sell the ETF shares."

6. Conclusion and Final Thoughts

As the episode wraps up, Levine and Greifeld reflect on the evolving nature of ETFs and meme stocks. They emphasize the importance of understanding the underlying mechanics and the potential regulatory scrutiny that may arise from aggressive tax deferral strategies.

Matt Levine [24:48]: "I've advocated that eventually everything will be an ETF."

Katie Greifeld [25:22]: "If you subscribe to the next reveal, you might find a similar loophole being closed."

The hosts leave listeners with a nuanced perspective on the financial instruments that continue to shape the investment landscape, encouraging a deeper dive into ETF structures and market behaviors.

Key Takeaways

• Meme Stocks Revival: While meme stocks are making a comeback, the dynamics have shifted due to changes in short interest and the advent of AI-driven stock recommendations.

• 351 ETFs Explained: Section 351 ETFs offer significant tax deferral benefits through in-kind transactions, making them a preferred choice over traditional mutual funds.

• Twin Oak ETF Challenges: Converting specific ETFs from UITs to open-ended structures involves complex shareholder approvals, highlighting potential bottlenecks in ETF evolution.

• Invesco QQQ Trust Insights: The profitability and fee structures of major ETFs like QQQ reveal underlying economic strategies that benefit issuers while posing questions about transparency and fairness for investors.

For more detailed analyses and engaging financial discussions, tune into the next episode of Money Stuff: The Podcast.