A Forensic Analysis of Single-Stock Leveraged ETFs: Investigating Structural Asymmetries, Counterparty Risk, and Allegations of Market Manipulation

Executive Summary

This report provides a forensic analysis of single-stock leveraged and inverse (L/I) exchange-traded funds (ETFs). It focuses specifically on the T-REX Daily Target ETF lineup.

The analysis addresses several key concerns. These include the asymmetrical offering of these products, the potential for market manipulation, and the hypothesis that their structure poses a hidden systemic risk. To investigate these issues, this report deconstructs the mechanics of L/I ETFs. It also maps the ecosystem of financial entities involved and evaluates specific allegations against the underlying companies.

Key Findings

• Market Structure Is Not Manipulation. The analysis concludes that the observed market structure is not indicative of a coordinated manipulation scheme. The prevalence of long-leveraged ETFs over their inverse counterparts is a rational outcome. It is driven by economic factors, market demand, and prudent risk management by issuers and their financial counterparties.
• Systemic Risk Hypothesis is Flawed. The central hypothesis regarding systemic risk rests on a misapplication of risk principles. The fear is that undisclosed swap counterparties create a vulnerability similar to the failures of Silicon Valley Bank (SVB) and Silvergate Bank. However, the risk in L/I ETFs is counterparty credit risk. This risk is rigorously mitigated through daily mark-to-market valuation and collateralization. This mechanism is fundamentally different from the unhedged duration risk that caused the bank collapses.
• Corporate Allegations Are Unconnected. A review of the specific allegations against the underlying companies reveals disparate, company-specific issues. While many concerns are rooted in documented events, there is no evidence connecting them to a broader conspiracy orchestrated through the ETF structure. For example, trading restrictions on “meme stocks” were a function of clearinghouse capital requirements, not a plot against retail investors.⁶¹

Final Assessment

Single-stock L/I ETFs are high-risk, speculative instruments. They are designed for sophisticated, active traders. The primary danger they pose is not a hidden systemic collapse. Instead, it is the significant potential for uninformed investors to suffer substantial losses. These losses can occur due to the inherent complexities of daily compounding and leverage, a concern repeatedly highlighted by securities regulators.¹², ¹³, ¹⁴

Part I: The Architecture of Amplified Conviction: Mechanics of Single-Stock L/I ETFs

This section deconstructs the fundamental architecture of single-stock leveraged and inverse ETFs. It examines the derivative-based mechanisms they use to achieve their daily investment objectives. The analysis also covers the mathematical principles that govern their performance and the economic rationale behind their product offerings.

Engineering Daily Returns: The Role of Derivatives

Single-stock L/I ETFs are engineered financial products. They aim to deliver a specific multiple of the daily performance of a single underlying stock.¹, ² This multiple can be leveraged (e.g., 2X) or inverse (e.g., -1X or -2X).

These funds do not achieve this objective by holding the stock directly with borrowed funds. Instead, they gain synthetic exposure through financial derivatives.³, ⁴

The primary instrument used is a swap agreement. The most common type is a Total Return Swap (TRS).

Total Return Swap (TRS): A contract where one party exchanges the total return of an asset for fixed or floating payments.⁵

These swaps are executed with major global financial institutions that act as counterparties.⁵, ⁶, ⁷ For a 2X long ETF, the fund enters a contract with a bank. The fund agrees to pay a financing rate. In return, the bank agrees to pay the fund 200% of the daily price return of the underlying stock.⁵, ⁸ For an inverse fund, the swap is structured to pay the fund the opposite of the stock’s daily return.⁹

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Visualizing the Swap Mechanism (for a 2X Long ETF)

+-----------------+            <-- Enters into Swap Agreement -->           +---------------------+

| L/I ETF Fund | | Swap Counterparty |
| (e.g., T-REX) |-------------------------------------------------------->| (e.g., Major Bank) |
| | Pays financing rate (e.g., SOFR + spread) | |
| | | Hedges its position |
| | | by buying the |
| |<--------------------------------------------------------| underlying stock |
| | Receives 200% of the underlying stock's daily return | |
+-----------------+                                                         +---------------------+

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While swaps are the core engine, these funds may also use other derivatives like futures and options.³, ¹⁰, ¹¹ These instruments introduce additional complexities, such as “roll yield” from futures or “time decay” from options.¹⁰, ¹¹

Given this complexity, regulators like the SEC and FINRA have issued numerous warnings. They consistently characterize these products as high-risk instruments. They are suitable only for sophisticated investors who understand leverage and intend to monitor their positions daily.¹¹, ¹², ¹³ SEC Commissioner Caroline Crenshaw stated that single-stock ETFs “pose yet another, perhaps greater, risk for investors and the markets” due to their concentrated nature.², ¹⁴

The Hidden Costs of Time: Volatility Decay and Path Dependence

The most critical characteristic of L/I ETFs is the “daily reset”.³, ¹¹, ¹² At the end of each trading day, the fund’s managers rebalance its portfolio of derivatives. This rebalancing adjusts the fund’s exposure. It ensures the fund begins the next day with the correct leverage ratio relative to its new net asset value (NAV).⁴, ¹⁰

This daily reset means the fund’s performance over any period longer than a single day is a compound of its individual daily leveraged returns. Consequently, the performance becomes path dependent.

Path Dependence: A term meaning the specific sequence of daily gains and losses dictates the ETF’s return, not merely the stock’s net change over the period.⁷, ¹⁵

A direct mathematical consequence of this daily compounding is volatility decay, also known as “beta slippage”.¹⁶ In a volatile market, this mechanism causes the ETF’s value to erode over time. This erosion can occur even if the underlying stock finishes the period at the same price it started. This decay is a persistent drag on performance in choppy markets. It is magnified by both higher leverage and higher volatility.¹⁶, ¹⁷

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Visualizing Volatility Decay

This example shows how a 2X leveraged ETF performs when the underlying stock is volatile but ultimately ends flat.

Day	Stock Start Price	Stock Daily Return	Stock End Price	2X ETF Start Value	2X ETF Daily Return (2x Stock Return)	2X ETF End Value
1	$100.00	+10.00%	$110.00	$100.00	+20.00%	$120.00
2	$110.00	-9.09%	$100.00	$120.00	-18.18%	$98.18
Result	Net Change: 0%			Net Change: -1.82%

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This effect can cause the ETF’s performance over weeks or months to diverge significantly from the simple multiple of the underlying stock’s performance.¹¹, ¹³, ¹⁸ The prospectus for the T-REX 2X Long Tesla Daily Target ETF (TSLT) explicitly models this. It shows that if TSLA stock has a 0% return over one year with 50% volatility, the 2X ETF is projected to lose 22.1% of its value.¹⁹ This is not a product flaw but an unavoidable mathematical property. It underscores why these products are intended for short-term trading, not long-term investment.

The Rationale for Asymmetry in ETF Offerings

The observation that stocks like Apple, Microsoft, and Google have 2X long T-REX ETFs but no corresponding inverse ETFs is central to the suspicion of market manipulation. However, this asymmetry is a rational feature of the market. It is driven by a combination of economic incentives and critical risk management considerations.

Economic and Market-Driven Factors

• Structural Market Bias: Equity markets historically exhibit a long-term upward trend. This creates more persistent demand for long-leveraged products compared to inverse products.²⁰, ²¹, ²²
• Cost and Complexity of Shorting: Maintaining a synthetic short position is inherently more complex and often more costly than a long position. Swap counterparties must hedge their own risk, which may involve short-selling the stock and incurring stock borrowing fees. These costs are passed on to the inverse ETF.²², ²³
• Volatility Decay as a Demand Suppressant: The effect of volatility decay is particularly punitive for inverse ETFs. In a market that is volatile but trends upward, an inverse ETF is doubly disadvantaged. It loses value from the stock’s upward movement and simultaneously erodes from volatility.¹⁶, ²²

Risk Management Imperatives

The most compelling reason for the scarcity of highly leveraged inverse single-stock ETFs is risk. Specifically, they present an asymmetrical and potentially catastrophic risk profile. This risk affects issuers, counterparties, and the entire market ecosystem.

• Asymmetrical Loss Potential: A long position in a stock has a maximum potential loss of 100%. A short position, however, has a theoretically unlimited loss potential.
• Magnification of Tail Risk: Leverage dramatically magnifies this asymmetry. A -2X inverse ETF faces a total loss of principal if the underlying stock rises by 50% in a single day. If the stock were to gap up by more than 50% on unexpected news, the ETF’s value would become negative. This “gap risk” is a critical concern for single stocks.²⁴, ²⁵, ²⁶
• Industry-Wide Risk Aversion (The Direxion Case Study): The product strategy of Direxion, a major competitor, confirms this risk aversion. Direxion offers a comprehensive suite of single-stock ETFs. While their “Bull” funds offer 2X leverage, every single one of their “Bear” funds provides only -1X inverse exposure.²⁷, ²⁸, ²⁹ This consistent decision by a market leader indicates that the risk of offering -2X inverse exposure on individual stocks is widely considered unacceptable.

T-REX’s decision to offer -2X inverse ETFs on a select few volatile names like Bitcoin (BTCZ) is an outlier. Their avoidance of this leverage on mega-cap stocks like Apple is not suspicious. It is in line with industry best practices for managing tail risk.

Part II: The Ecosystem of Interdependence: Mapping the Key Financial Actors

The operation of single-stock L/I ETFs relies on a complex ecosystem of specialized financial entities. This section identifies the key players—issuers, swap counterparties, authorized participants, and market makers—and analyzes their interactions to demystify how these funds function.

The Issuers – REX Shares and Direxion

The issuers are the entities that create, manage, and market the ETFs. They are responsible for the fund’s legal structure, regulatory compliance, and tracking its stated objective.

• REX Shares / Tuttle Capital Management (T-REX): The T-REX lineup is a collaboration between REX Shares and Tuttle Capital Management.²⁴, ³⁰, ³¹ Their stated strategy is to be “first-to-market” with leveraged exposures on “high-conviction, sector-defining names”.³⁰, ³² This approach explains the inclusion of many volatile and crypto-related stocks.
• Direxion: As a larger, more established provider, Direxion is known for its broad suite of leveraged index funds.³³, ³⁴, ³⁵ Their approach to the single-stock market appears more conservative on the inverse side. By exclusively offering -1X leverage for their bear funds, Direxion demonstrates a more cautious strategy for managing tail risk.²⁷, ²⁸, ²⁹

Both T-REX and Direxion ETFs are legally structured under a trust framework. They are registered with the SEC under the Investment Company Act of 1940.³, ³⁶, ³⁷ The T-REX funds fall under the ETF Opportunities Trust (CIK: 0001771146), while Direxion’s funds are part of the Direxion Shares ETF Trust (CIK: 0001424958).³⁸, ³⁹, ⁴⁰, ⁴¹, ⁴², ⁴³

The Unseen Engine: Swap Counterparties and Systemic Risk

A core concern is the perceived systemic risk posed by the undisclosed nature of the swap counterparties. The fear is that this creates a hidden vulnerability analogous to the failures of Silicon Valley Bank (SVB) and Silvergate Bank. This analogy, however, is fundamentally flawed.

Swap counterparties are typically major global investment banks like JPMorgan Chase or Goldman Sachs.⁵, ⁴⁴ The risk to the ETF is counterparty credit risk: the risk that the bank will default on its obligation to pay the fund.⁵, ⁴⁵, ⁴⁶

This is different from the risk that caused the collapse of SVB. SVB’s failure was due to an asset-liability mismatch and unhedged interest rate risk.⁴⁷, ⁴⁸ SVB invested its short-term customer deposits into long-duration bonds. When interest rates rose, the market value of these bonds plummeted. A bank run forced SVB to sell these bonds at massive losses, rendering it insolvent.⁴⁹

The risk with ETF swap counterparties is mitigated through a robust, industry-standard mechanism: collateralization. These swaps are governed by an International Swaps and Derivatives Association (ISDA) Master Agreement. This legal framework mandates that the net exposure between the two parties is calculated daily. The party that is “out of the money” must post high-quality collateral, typically cash or government securities, to cover this exposure.⁵, ⁵³, ⁵⁴ This process prevents the accumulation of large, uncollateralized liabilities.

The following table clarifies the critical distinctions between these two risk scenarios.

Feature	Silicon Valley Bank (SVB) Failure	Leveraged ETF Swap Counterparty Risk
Primary Risk Type	Asset-Liability Mismatch; Interest Rate / Duration Risk ⁴⁷, ⁴⁸	Counterparty Credit Risk ⁵, ⁴⁵, ⁴⁶
Source of Risk	Internal balance sheet: Long-duration assets (bonds) funded by short-duration liabilities (deposits).	External relationship: Default of the swap counterparty on its payment obligation.
Trigger Event	Rapid rise in interest rates caused unrealized losses on bond portfolio; a bank run forced realization of those losses.	Financial failure/insolvency of the counterparty bank.
Primary Mitigation	Hedging interest rate risk (which SVB failed to do adequately).	Daily mark-to-market and posting of collateral to cover the net exposure.⁵, ⁵³, ⁵⁴
Failure Scenario	Insufficient liquid assets to meet depositor withdrawals, forcing sale of assets at a loss, wiping out equity.	Counterparty defaults, and the value of the posted collateral is insufficient to cover the swap’s mark-to-market value at the time of default.
Systemic Implication	Contagion risk to other banks with similar unhedged duration risk on their balance sheets.	Systemic risk would require a “Lehman-style” failure of a major, globally systemic bank and a simultaneous failure of the collateralization process.

The true systemic risk associated with these derivatives is of a different nature. It would involve a “black swan” event causing a major investment bank to fail so rapidly that collateral could not be collected in time.⁵⁵

The Arbitrageurs: Authorized Participants and Market Makers

The final set of key actors are the Authorized Participants (APs) and Market Makers (MMs). They ensure the ETF shares trade efficiently on the secondary market.

• Authorized Participants (APs) are large financial institutions with a contractual agreement with the ETF issuer. They are the only entities permitted to create or redeem shares directly with the fund in large blocks known as “Creation Units”.⁴³, ⁴⁴, ⁵⁶
• Market Makers (MMs) are trading firms that provide liquidity on the stock exchange by continuously posting bid and ask prices for the ETF’s shares.⁵⁷, ⁵⁸

These two roles function through an arbitrage mechanism that keeps the ETF’s market price closely aligned with its NAV.²³, ⁴⁴ If the ETF’s share price rises to a premium above its NAV, an AP can create new shares at NAV and sell them on the open market at the higher price, capturing a risk-free profit. Conversely, if the ETF trades at a discount, the AP can buy the cheaper shares on the market and redeem them with the fund at the higher NAV.

This arbitrage process is the fundamental engine of the ETF structure. The incentives are purely economic. This is not a “rug pull” scheme but a continuous, high-volume business. The risk of a “rug pull” for an investor comes from the inherent volatility of the product itself.²⁴, ⁵⁹, ⁶⁰

Part III: A Forensic Review of Specific Allegations

This section systematically examines the specific claims and suspicions raised against the individual companies whose stocks underlie the T-REX ETF lineup. By evaluating each allegation against publicly available information, we can provide a factual assessment of each concern.

The following table provides a high-level summary of the findings.

Company	User Allegation(s)	Summary of Factual Findings
GameStop (GME)	“Not to be trusted” due to trading action under Biden.	The trading restrictions in January 2021 were a result of clearinghouses imposing massive collateral requirements on brokerages like Robinhood due to extreme volatility, not a conspiracy against retail investors. This was confirmed in congressional hearings.
Robinhood (HOOD)	Shut down trading on certain stocks like Nokia.	Same as GameStop; the trading halts were driven by unprecedented deposit requirements from the National Securities Clearing Corporation (NSCC) to mitigate systemic risk, a fact detailed in testimony to Congress.
Kratos (KTOS)	“Scandal with Kratos I know for sure.”	Publicly filed insider sales were executed under pre-arranged 10b5-1 trading plans. This is a standard, legal practice for corporate executives to sell shares over time without being accused of trading on non-public information.
Snowflake (SNOW)	“Popped up out of nowhere.”	Snowflake was founded in 2012 and incubated for years by venture capital firm Sutter Hill Ventures. It had a well-documented history of multiple funding rounds from prominent VCs before its record-breaking 2020 IPO.
Webull (BULL)	“Popped up out of nowhere.”	Webull was founded in 2016 by a former Alibaba employee with initial backing from Chinese investors. While its ties to China have drawn regulatory scrutiny in the U.S., its origins are not mysterious.
TheTradeDesk (TTD)	Trades at a “phantom high P/E,” implying a scandal.	TTD has historically commanded a very high Price-to-Earnings (P/E) ratio, which is common for high-growth technology platform companies. This reflects strong market expectations for future earnings growth, not an accounting “phantom.”
Affirm (AFRM)	Problems with profitability.	This is a valid concern. The “Buy Now, Pay Later” (BNPL) business model is exposed to significant credit risk, and Affirm’s profitability is challenged by rising loan delinquencies, a known risk factor for the company and the sector.
Upexi (UPXI)	User does not know what it is.	Upexi is a former consumer brands company that has pivoted to a cryptocurrency treasury strategy, aiming to acquire and stake Solana (SOL) tokens. It is a high-risk, speculative business model.
Galaxy Digital (GLXY)	Tied to cryptocurrency, considered a “Ponzi scheme.”	Galaxy Digital is a large, publicly traded financial services firm specializing in digital assets. Recent financial reports show a swing to profitability and significant institutional business, indicating it is a substantial operating company, albeit one exposed to the volatility of the crypto market.
Bitmine Immersion (BMNR)	Connected to “greenwashing” and cryptocurrency.	BMNR is a crypto mining company that claims its immersion cooling technology is more energy-efficient. The term “greenwashing” reflects a broader debate on whether any energy-intensive mining can be considered “green.” The company has also been the target of a short-seller report questioning its business model.
Arm Holdings (ARM)	Connected to the CCP and Islam.	Arm’s significant business exposure to China, through an entity (Arm China) that it does not control, is a major and well-documented risk disclosed in its IPO filings. The claim regarding a connection to Islam via its UK base is unsubstantiated conjecture.
Booking Holdings (BKNG)	“Papering over losses for tons of smaller entities.”	The company faced a major regulatory action and paid a $9.5 million settlement for deceptive “junk fee” pricing practices, not for “papering over losses.” Financial statements indicate profitability. The user’s claim mischaracterizes the nature of the scandal.
Axon Enterprise (AXON)	Gets contracts when other competitors don’t; poor P/E ratio.	Axon has faced antitrust scrutiny from the FTC and openly justifies its frequent use of “sole-source” government contracts by claiming its integrated ecosystem is unique. This practice is a core part of its business strategy and a source of public controversy.

Meme Stocks & Trading Restrictions (GameStop, Robinhood)

The assertion that GameStop (GME) and Robinhood (HOOD) are untrustworthy stems from the trading restrictions imposed during the “meme stock” frenzy of January 2021. However, extensive documentation, including congressional testimony, points to a mechanical, risk-management-driven cause.⁶¹

The GameStop short squeeze generated unprecedented trading volume and volatility.⁶², ⁶³ U.S. securities trading involves a two-day settlement period, during which clearinghouses like the National Securities Clearing Corporation (NSCC) guarantee trades. To manage risk, the NSCC requires brokerage firms to post collateral.⁶¹

On January 28, 2021, due to the massive volume in GME, the NSCC informed Robinhood it had a deposit deficit of approximately $3 billion.⁶¹ Unable to meet this collateral call instantly, Robinhood had no choice but to restrict the opening of new positions in the most volatile securities, including GME and Nokia.⁶⁴ This action was not a discretionary decision to aid hedge funds but a mandatory step to comply with the capital requirements of the market’s central plumbing.

Insider Trading Allegations (Kratos Defense & Security Solutions)

The claim of a “scandal” at Kratos Defense & Security Solutions (KTOS) appears based on observations of insider selling. SEC Form 4 filings from October 2025 do show share sales by company executives.⁶⁵, ⁶⁶

However, these filings contain a crucial detail: the transactions were made pursuant to a Rule 10b5-1 trading plan. A 10b5-1 plan is a legal instrument that allows corporate insiders to set up a pre-arranged plan to sell a predetermined number of shares at a predetermined time.⁶⁵, ⁶⁶ The key requirement is that the plan must be established when the insider is not in possession of material non-public information. By using such a plan, executives can diversify their holdings without facing accusations of insider trading. The Kratos filings show the plans were adopted months before the sales took place, indicating these were scheduled, compliant transactions.⁶⁵, ⁶⁶

“Out of Nowhere” Companies (Snowflake, Webull, Coreweave, Circle)

The suspicion that certain companies “popped up out of nowhere” is factually incorrect for the publicly traded firms mentioned.

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Snowflake (SNOW) Timeline

• 2012: Founded by Oracle engineers; incubated by Sutter Hill Ventures (SHV), which leads a $5M Series A.⁶⁸, ⁶⁹
• 2014: Comes out of stealth mode; raises $26M Series B led by Redpoint Ventures.⁷⁰, ⁷¹
• 2015: Launches first product; raises $45M Series C led by Altimeter Capital.⁷⁰, ⁷¹
• 2017: Raises $100M Series D led by ICONIQ Capital.⁷⁰, ⁷¹
• 2018: Expands to Microsoft Azure; raises $450M Series F led by Sequoia Capital.⁷⁰, ⁷¹
• Sept. 2020: Goes public in the largest software IPO ever, with Berkshire Hathaway as a notable investor.⁷², ⁷³, ⁷⁴

Webull (BULL) Timeline

• 2016: Founded by Wang Anquan under Hunan Fumi Information Technology, a Chinese holding company.⁷⁵
• 2017: Webull Financial LLC established in the U.S.⁷⁶
• 2018: Becomes a licensed securities company in the U.S. (SEC and FINRA).⁷⁵, ⁷⁷
• 2022: Restructures to move Hunan Fumi Information Technology outside the Webull group.⁷⁵
• Apr. 2025: Completes merger and lists on Nasdaq via a SPAC merger.⁷⁸, ⁷⁹, ⁸⁰

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• Coreweave and Circle: These are private companies in the AI and crypto sectors. Their lower public profile is expected. Coreweave is a specialized cloud provider offering large-scale access to NVIDIA GPUs.⁸¹ Circle is the issuer of USD Coin (USDC), one of the world’s largest stablecoins.

Business Model and Valuation Concerns (TheTradeDesk, Affirm, Upexi)

• TheTradeDesk (TTD): The claim of a “phantom high P/E” reflects skepticism toward growth stock valuations. TTD has historically traded at very high P/E multiples, at times exceeding 400x.⁸², ⁸³ This is characteristic of companies in high-growth sectors where investors pay a premium based on expectations of future earnings. A high P/E ratio is a measure of market sentiment, not evidence of a “scandal.”⁸⁴
• Affirm (AFRM): The concern about Affirm’s profitability is well-founded. The BNPL business model involves assuming credit risk for consumer loans.⁸⁵, ⁸⁶ The company’s delinquency rates are a key metric for investors, and rising rates can negatively impact profitability, a risk acknowledged by the company.⁸⁷, ⁸⁸, ⁸⁹
• Upexi (UPXI): This company has pivoted from consumer products to a cryptocurrency treasury company focused on Solana (SOL).⁹⁰, ⁹¹, ⁹², ⁹³ Its strategy is to acquire large amounts of SOL and stake those tokens to earn a yield.⁹¹, ⁹⁴, ⁹⁵, ⁹⁶

Crypto, Geopolitical, and Regulatory Scrutiny

• Cryptocurrency-Related Companies:
  • Galaxy Digital (GLXY): This is a large, diversified digital asset financial services firm. Its recent financial results show a swing to significant profitability, surging revenue, and a strong balance sheet with substantial cash and stablecoin holdings.⁹⁷, ⁹⁸, ⁹⁹ It is a substantial, operating business with significant institutional backing.¹⁰⁰
  • Bitmine Immersion Technologies (BMNR): BMNR is a crypto mining company that also provides hosting services.¹⁰¹, ¹⁰² It claims its proprietary immersion cooling technology reduces energy consumption, forming the basis of its “green” marketing.¹⁰³ This “greenwashing” claim is part of a broader debate over the environmental impact of proof-of-work mining.¹⁰⁴, ¹⁰⁵, ¹⁰⁶ The company has also been the target of a short-seller report questioning its business model.¹⁰⁷
• Arm Holdings (ARM): The claim of a connection to the CCP is an exaggeration but points to a real risk. Arm’s IPO filings detail its exposure to China, which accounts for 20-25% of its revenue.¹⁰⁸, ¹⁰⁹ This revenue is channeled through Arm China, a separate entity in which Arm holds only a minority, non-controlling stake, creating substantial risks related to IP protection and geopolitical tensions.¹¹⁰, ¹¹¹ The claim about a connection to Islam is unsubstantiated conjecture.
• Booking Holdings (BKNG): The allegation of “papering over losses” is inaccurate. The company’s legal troubles centered on deceptive pricing. In August 2025, Booking Holdings paid a $9.5 million settlement over allegations of advertising artificially low hotel rates and then hiding mandatory “junk fees”.¹¹² The company’s financial statements report significant profits.¹¹³
• Axon Enterprise (AXON): The observation that Axon “somehow gets contracts when other competitors don’t” is accurate. Axon has been investigated by the FTC for anticompetitive practices.¹¹⁴, ¹¹⁵ The company frequently engages in “sole-source” procurement with law enforcement agencies, justifying this by arguing that its integrated ecosystem of TASERs, body cameras, and digital evidence management is a unique, proprietary system with no direct equivalent.¹¹⁶, ¹¹⁷, ¹¹⁸, ¹¹⁹ This practice is central to its market dominance but also fuels criticism.¹²⁰

Part IV: The Options Market Nexus

This section delves into the critical role of the options market. It serves as a nexus for both risk management and speculation in the L/I ETF ecosystem. The derivatives that power these ETFs are often hedged by counterparties using listed options. This creates a complex interplay between the ETF, its underlying stock, and the options market. This connection is essential for understanding the full scope of potential market dynamics.

The Derivative of a Derivative: Options on L/I ETFs

The introduction of options trading on the L/I ETFs themselves, such as on T-REX’s BMNU, CRCD, and CORD, is a significant development.¹²¹ This creates a “derivative of a derivative,” allowing for leverage on an already leveraged instrument. For example, a trader could buy a call option on a 2X long ETF, creating an extremely high degree of effective leverage. This provides sophisticated traders with powerful new tools. However, it also dramatically increases the risk for retail investors who may not fully comprehend the exponential nature of the risk they are assuming.

Investigating Unusual Options Activity

An analysis of unusual options activity in the underlying stocks is necessary to assess the possibility of informed or manipulative trading. Unusual activity is often defined as a significant spike in trading volume relative to open interest in specific contracts.

A review of options flow data for GameStop (GME) shows consistently high activity. Volume-to-open-interest ratios frequently exceed 2.0 or 3.0 for near-term options.¹²² This is characteristic of a “meme stock” and is not, in itself, unusual for GME. Similarly, data shows significant block and sweep trades in GME options, but this is also a regular feature of its trading.¹²³ The high level of background noise in GME’s options market makes it challenging to isolate a signal related to the ETF launch using publicly available data alone.

Unconventional Structures and Potential for Manipulation

The specific design choices for certain ETFs have also raised questions. The T-REX 2X Inverse MSTR Daily Target ETF (MSTZ) offers -2X leverage, whereas many other inverse single-stock ETFs are capped at -1X.¹²⁴ This choice is consistent with T-REX’s higher risk tolerance for a subset of extremely volatile assets. MicroStrategy (MSTR) is known for its high volatility and its strong correlation to the price of Bitcoin. Offering a -2X product caters directly to traders seeking to make large, short-term bets on this volatility.

The query regarding which funds are “unconventional” because they “go into the options market” points to a slight confusion. All L/I ETFs are unconventional because they use derivatives (primarily swaps) rather than holding the underlying stock.³, ³⁶ This is distinct from actively managed ETFs that use options-based strategies to generate income, such as covered call ETFs like the JPMorgan Equity Premium Income ETF (JEPI).¹²⁵, ¹²⁶

Conclusion: A Framework for the Skeptical Researcher

This forensic analysis has systematically investigated the structure of single-stock L/I ETFs, the ecosystem in which they operate, and a series of specific allegations. The evidence leads to a series of nuanced conclusions that both validate the need for skepticism while refuting the central hypotheses of a coordinated conspiracy and an impending systemic collapse.

Synthesis of Findings

• Structural Asymmetry is Rational. The prevalence of long-leveraged ETFs over their inverse counterparts is not evidence of a “pump” scheme. It is a logical market outcome driven by historical market bias, the higher costs of shorting, and the prudent management of the extreme, uncapped tail risk inherent in highly leveraged short positions. The more conservative strategy of competitors like Direxion confirms this as an industry-wide risk management feature. Therefore, the absence of certain inverse ETFs is a feature of prudent risk management, not evidence of a conspiracy.
• Systemic Risk Analogy is Flawed. The comparison of hidden counterparty risk in ETFs to the failures of SVB and Silvergate is inaccurate. The banks failed due to unhedged asset-liability mismatches. The primary risk in the ETF structure is counterparty credit risk, which is actively mitigated through daily mark-to-market valuations and collateralization. Consequently, the systemic risk from these products is of a “Lehman-style” nature, not an “SVB-style” balance sheet implosion.
• Company-Specific Issues are Disparate. The numerous allegations against the underlying companies, while often rooted in fact, do not form a coherent narrative of a conspiracy. They are a collection of disparate issues reflecting the specific risks of each business, from the clearinghouse requirements that halted GameStop trading to the legal, pre-arranged insider selling plans at Kratos. These individual issues do not connect to a broader scheme orchestrated via the T-REX ETFs.

Final Assessment

The T-REX single-stock L/I ETFs are highly speculative instruments. They are designed as tactical tools for sophisticated traders.

The primary and most immediate danger they present is not a hidden systemic threat. It is the significant risk that retail investors will misunderstand their complex mechanics. The corrosive effects of volatility decay and the violent nature of daily leveraged returns make these products exceptionally unsuitable for buy-and-hold investors.

An investor could lose their entire principal in a single day. The “positive reinforcement loop” feared by the user is, for an uninformed long-term holder, more likely to be a wealth-destroying “volatility trap.” The persistent warnings from the SEC and FINRA underscore that the paramount issue is one of investor protection.

A Recommended Framework for Future Investigation

A skeptical approach is a valuable asset for any market participant. To be effective, however, it must be channeled through a rigorous and evidence-based framework. The following methodology is recommended for future research:

1. Deconstruct the Instrument: Always begin by reading the fund’s official regulatory documents—the Prospectus and the Statement of Additional Information (SAI). These documents are legally required to disclose the product’s mechanics, strategies, and principal risks.
2. Differentiate Risk Types: Learn to precisely distinguish between different categories of financial risk: market risk, credit risk, counterparty risk, interest rate/duration risk, and operational risk. Each requires a different analytical approach.
3. Verify with Primary Sources: Use the SEC’s EDGAR database as the primary source for verifying claims. Annual (10-K) and quarterly (10-Q) reports provide audited financial data and risk factor disclosures. Form 4 filings detail insider transactions.
4. Contextualize Information: A single data point is rarely conclusive. A high P/E ratio is normal for a high-growth company. Insider selling is a routine part of executive compensation. A short-seller report is an allegation made by a party with a financial interest in the stock’s decline.
5. Follow the Collateral: When assessing systemic risk in the derivatives market, the critical question is not simply “who is the counterparty?” but “how is the exposure collateralized?” Understanding the mechanics of ISDA agreements and daily collateral posting is fundamental to evaluating counterparty risk.

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