Roundhill Memory ETF's Unconventional Portfolio Raises Questions

A new memory fund called Roundhill Memory ETF (DRAM) has been trading on Cboe BZX since April 2, 2026. The actively managed fund holds companies that make DRAM, NAND flash, high bandwidth memory, and hard drives. Phemex lists a DRAM-USDT perpetual futures contract against it.

The fund's portfolio is unusual, with Treasury bills making up 21.39% of its net assets on June 30. The largest equity lines are in SK hynix (15.89%), Samsung Electronics (14.37%), and SanDisk (5.21%). However, the majority of Micron Technology exposure comes from four total return swaps, which carry a notional value of $11.03 billion.

The swaps allow the fund to hold more than 80% of its net assets in companies making memory products without breaking diversification tests. The other half of the answer is tax law, as using total return swaps helps the fund stay inside the regulations. The issuer's fund page explains that weight calculation combines stock positions with swap positions and lists collateral separately.