Ten Cap Alpha Plus Complex ETF Announces 0.34% MPI Tracking Error for Q2 2026

7 min read | July 01, 2026 07:34 PM BST | By Aakashdeep

Ten Cap Investment Management Pty Ltd has published its quarterly portfolio correlation report for the Ten Cap Alpha Plus Complex ETF (ASX:TCAP), revealing a daily tracking error of 0.34% between the Material Portfolio Information (MPI) and the full portfolio holdings for the quarter ending 30 June 2026. This disclosure complies with ASX conditions of Quotation applicable to complex Exchange-traded funds and serves as an essential transparency measure for TCAP unit holders. The Responsible Entity, Ironbark Asset Management (Fund Services) Limited, calculated this figure by comparing daily percentage changes in net asset value from both the MPI and the complete portfolio. Investors in complex ETFs use low tracking error figures to evaluate how accurately the publicly disclosed portfolio proxy represents the fund's actual holdings.

Key Points

  • Fund name and ASX code: Ten Cap Alpha Plus Complex ETF (TCAP)
  • Quarterly MPI-to-full-portfolio tracking error for Q2 2026 (1 April – 30 June 2026) reported at 0.34%
  • Disclosure made under ASX quotation conditions for complex ETFs
  • Responsible Entity: Ironbark Asset Management (Fund Services) Limited; Investment Manager: Ten Cap Investment Management Pty Ltd
  • Investors should monitor upcoming quarterly disclosures and any trends in tracking error over time

Implications of the 0.34% Quarterly Tracking Error for TCAP Investors

The Ten Cap Alpha Plus Complex ETF reported a daily tracking error of 0.34% between its Material Portfolio Information and its full portfolio holdings during the April to June 2026 quarter. This tracking error quantifies the extent to which the publicly disclosed MPI—a proxy allowed for complex ETFs instead of full daily portfolio transparency—deviates from the actual net asset value movements of the entire fund portfolio.

For investors evaluating the accuracy of TCAP's MPI as a representation of the fund’s true value, the 0.34% figure reflects the daily divergence experienced throughout the quarter. The announcement did not include a benchmark target or historical comparison, so investors seeking to determine whether this figure marks an improvement or decline compared to prior periods will need to consult previous quarterly disclosures. The immediate effect on the share price was not evident from public information.

Calculation Methodology Employed by Ironbark Asset Management

Ironbark Asset Management (Fund Services) Limited, as the Responsible Entity and issuer of the Ten Cap Alpha Plus Complex ETF, calculated the tracking error. The company stated that Ironbark compared the daily percentage changes in net asset value derived from the MPI against those from the full portfolio holdings over the relevant period.

This approach—measuring daily NAV percentage changes rather than absolute dollar amounts—is a standard method for assessing the alignment between a publicly disclosed portfolio proxy and the underlying full portfolio. The resulting daily tracking error of 0.34% represents the aggregate comparison across all trading days from 1 April 2026 to 30 June 2026. The announcement did not specify the number of trading days included or provide a monthly breakdown of tracking error within the quarter.

ASX Quotation Conditions Mandating MPI Disclosures for Complex ETFs

Unlike standard or transparent ETFs that disclose their full portfolio holdings daily, complex ETFs listed on the ASX operate under specific quotation conditions allowing them to use Material Portfolio Information as a proxy. The MPI is a subset or representation of the full portfolio designed to provide Market Participants with sufficient information to price the ETF while protecting proprietary trading strategies and full position details from real-time disclosure.

In return for this flexibility, ASX requires complex ETFs to periodically disclose the correlation—expressed as tracking error—between their MPI and full portfolio holdings. The quarterly disclosure for TCAP is therefore a regulatory compliance measure rather than a voluntary announcement. It aims to assist investors, market makers, and regulators in evaluating whether the MPI effectively proxies the fund’s true value over time.

Roles of Ten Cap Investment Management and Ironbark in Managing TCAP

The Ten Cap Alpha Plus Complex ETF follows a dual-entity structure common among Australian ETFs. Ironbark Asset Management (Fund Services) Limited, holding Australian Financial Services Licence 298626 and ABN 63 116 232 154, acts as the Responsible Entity and issuer of the fund. Ironbark bears legal and regulatory responsibility for the fund’s compliance, including preparing and lodging the quarterly MPI tracking error disclosure.

Ten Cap Investment Management Pty Ltd, holding AFSL 565368 and ABN 29 682 019 987, serves as the investment manager, overseeing day-to-day investment decisions and portfolio construction. The company update was authorized by Ten Cap Investment Management Pty Ltd and released on 2 July 2026. Investors seeking fund documentation such as the Target Market Determination, Product Disclosure Statement, or offer documents are directed to www.ironbarkfg.com.au or to contact MUFG at 1800 883 072.

Significance of MPI Transparency for Market Participants

The MPI framework balances investor protection with Fund Manager flexibility. Market makers providing liquidity in TCAP units on-exchange rely on the MPI to evaluate intraday pricing and manage hedging. Significant divergence between the MPI and the full portfolio may cause market makers to widen bid-ask spreads or reduce liquidity provision, negatively affecting trading conditions for retail and institutional investors.

For TCAP investors, understanding the tracking error between MPI and full portfolio helps assess whether daily trading prices fairly reflect the fund’s true NAV. A consistently low tracking error suggests the MPI is an effective proxy, whereas increasing tracking error over time could raise concerns about the accuracy of the disclosed information. The company did not comment on fund performance, portfolio composition, or investment strategy in this update.

Quarter Covered and Disclosure Timing

The disclosure pertains to the three-month period from 1 April 2026 to 30 June 2026, corresponding to the second quarter of 2026. This aligns with the typical quarterly reporting schedule for ASX-listed funds. The update was dated and released on 2 July 2026, shortly after the quarter’s end, consistent with ASX timely disclosure requirements.

Future quarterly disclosures will cover periods ending 30 September 2026, 31 December 2026, and subsequent quarters on a rolling basis. Investors may find it informative to track whether the tracking error remains stable, improves, or widens in coming quarters as an indicator of MPI reliability. No forward guidance on expected tracking error for the current quarter was provided.

Clarifying What the Tracking Error Disclosure Indicates About Fund Performance

Investors should recognize the scope and limitations of the quarterly MPI tracking error disclosure. The 0.34% figure specifically measures divergence between the MPI and full portfolio holdings; it is not an indicator of investment performance, benchmark returns, or the effectiveness of the Ten Cap Alpha Plus investment strategy. No performance data or benchmark comparisons were included or implied in this announcement.

For information on TCAP’s investment performance, fees, risk profile, or portfolio positioning, investors should consult the fund’s current Product Disclosure Statement and Target Market Determination, available via Ironbark’s website or by contacting MUFG. This disclosure is strictly a regulatory transparency requirement and should not be interpreted as a performance commentary. Drawing broader conclusions about fund quality or manager skill from this data alone is not supported.

Contextualizing TCAP’s Tracking Error Within the Complex ETF Landscape

The ASX complex ETF segment is a niche area of the Australian ETF market. Quarterly MPI tracking error disclosures provide a specific but limited data point for market analysis. The company did not disclose a target tracking error range, peer comparisons, or historical tracking error data in this update, so the 0.34% figure stands alone.

Investors and analysts wishing to contextualize TCAP’s 0.34% tracking error should review prior quarterly disclosures by Ten Cap or Ironbark or compare with similar disclosures from other complex ETFs under ASX quotation conditions. The announcement does not offer conclusions on whether 0.34% is within expected norms. Monitoring this figure across multiple quarters may help gauge MPI reliability over time.

Upcoming Disclosures and Ongoing Compliance for TCAP

The next quarterly MPI tracking error disclosure for TCAP is anticipated to cover 1 July 2026 to 30 September 2026, with lodgement expected soon after that period ends. Investors tracking TCAP should watch for this update as an additional data point on the consistency of the fund’s MPI framework. Significant changes in tracking error between quarters could prompt further scrutiny from investors and market participants.

Beyond tracking error disclosures, investors should remain alert to any regulatory filings, product updates, or changes to the fund’s responsible entity or investment manager that may be announced separately. The company did not indicate any forthcoming changes to the fund’s structure, strategy, or disclosure practices in this release. The immediate impact on the share price was not evident from public information. Investors are advised to conduct their own Due Diligence and seek professional financial advice before making investment decisions related to TCAP.


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