Defiance China Memory ETF

The Defiance China Memory ETF (Nasdaq: CRAM) seeks to track the BITA China Memory Index and provides targeted exposure to companies listed on exchanges in mainland China and Hong Kong that are principally engaged in the China memory and storage semiconductor value chain.

Memory is the foundational layer of the AI economy, and 2026 is the year China’s memory industry arrived on the public markets. In July, China’s largest DRAM maker completed the largest semiconductor IPO in mainland China’s history, raising approximately $8.6 billion on Shanghai’s STAR Market and closing its first session as the most valuable company listed on a mainland exchange. In August, China’s leading NAND flash maker filed for a Shanghai listing of its own, seeking approximately $4.9 billion. Across the chain, several Chinese memory companies have forecast first-half 2026 profit growth in the hundreds or thousands of percent in their exchange filings, as AI demand tightened global memory supply and lifted prices.

In short, CRAM targets the part of the global memory trade U.S. investors could not previously own in one fund: China’s own memory supply base.

Why CRAM?

China’s memory champions are going public. The largest semiconductor IPO in mainland history listed in July, the country’s leading NAND maker filed in August, and the Index methodology allows qualifying IPOs with proven thematic exposure to be added on an accelerated basis.

A value chain, not a single stock. The Index spans eleven memory and storage activities, from DRAM and NAND design and fabrication to modules, controllers, interface chips, packaging and testing, distribution, and the equipment, materials, and IP dedicated to memory production.

Rules based, China only. Only ordinary shares listed in mainland China and Hong Kong are eligible. Constituents must meet revenue, size, and liquidity screens, are weighted by free-float market capitalization with a 25% cap, and are reconstituted and rebalanced quarterly.

Investment Objective

The Defiance China Memory ETF (the “Fund”) seeks to track the performance, before fees and expenses, of the BITA China Memory Index (the “Index”).

The Index

The BITA China Memory Index is owned, calculated, administered, and disseminated by BITA GmbH, a Germany-based index provider. The Index is rules based and designed to track the performance of companies listed on exchanges in mainland China and Hong Kong that are principally engaged in the China memory and storage semiconductor value chain.

To be eligible, a company must derive at least 50% of its total revenue from at least one of eleven memory and storage activities, or at least 25% of its total revenue from five or more of those activities while ranking within the top five companies by absolute revenue from them. The activities are DRAM; NAND flash; NOR flash and specialty non-volatile memory; SRAM and niche memory; memory modules and solid-state storage; memory interface and buffer chips; storage and flash controllers; memory foundry; memory packaging and testing; memory branding and distribution; and enabling equipment, materials, and intellectual property dedicated to memory and storage production.

The Index includes only ordinary shares of companies listed on exchanges in mainland China and Hong Kong. To qualify for initial inclusion, a company generally must have a free float of at least 10%, a market capitalization of at least $100 million, and a three-month average daily trading value of at least $1.0 million, with modified eligibility rules for recent IPOs. Companies that satisfy the eligibility criteria are included; as of July 2026 the Index included 12 constituents, and the number is expected to vary. Constituents are weighted by free-float adjusted market capitalization, subject to a 25% cap per constituent, with excess weight redistributed proportionally. The Index is reconstituted and rebalanced quarterly in January, April, July, and October.

Under normal circumstances, the Fund invests at least 80% of its net assets in investments that provide exposure to the component securities of the Index, including the securities themselves, depositary receipts, and derivative instruments such as total return swaps and listed options. The Fund generally uses a replication strategy and may also invest up to 15% of its net assets in private companies engaged in China memory and storage semiconductor value chain activities.

BITA China Memory Index Holdings