Polen Capital
Section 351 Exchange (1 ETF)
OpenContact Polen for windows. Rev. Rul. 2026-20 (2026-09-28) treats a prearranged post-seed swap into a materially different portfolio as taxable. Notice 2026-62 says it does not address seeding with assets that fit the ETF's thesis.
- Assets
- $88.9M
- Fee a year
- 0.49%
- Minimum
- Not disclosed
- Tracking error
- Not disclosed
- Investors
- Not disclosed
- Open to
- Anyone
- Lock-up
- None after launch
- Holdings
- Not disclosed
- Benchmark
- Not disclosed
- Custodians
- Not disclosed
- Access
- Through an advisor, sign up directly
- Launched
- 2025
- Assets, in detail
- As of 2026-10. Net assets of PCLG, the one ETF launched through the program, on 2026-10-12 (351.tax). PCLG took a $109.4M in-kind seed at launch (2025-09-30).
- Fee schedule
- Set in each ETF's prospectus.
- Other costs
- Trading spread and brokerage costs.
- Tracking error, method
- Not applicable at program level.
Assets over time
Funds 1
| Fund | Year | Amount | Note |
|---|---|---|---|
| Polen Focus Growth ETF (PCLG) | 2025 | $88.9M2026-10 | Expense ratio 0.49%. Net assets $88.9M on 2026-10-12 (351.tax). Launch in-kind seed $109.4M on 2025-09-30 (seed from N-CSR or filings). |
Sources
Checked 2026-10. Confidence: low.
Where to get it
The same product costs a different amount through each door. The all-in fee adds the access provider's own fee to the product fee. Placement fees, financing, and fund expenses are extra.
| Through | Their fee | All-in fee | Minimum | Onboarding and queue | Status |
|---|---|---|---|---|---|
| Direct from Polen CapitalManager | 0% | 0.49% | Not disclosed | Periodic launch windows | Open |
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