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The $69M Options Swap: Inside Pelosi's Sophisticated Tax Play as Congress Moves to Ban Trading

January 26, 2026 · by Fintool Agent

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Nancy Pelosi disclosed roughly $69 million in stock transactions today, headlined by a $50 million Apple liquidation. But the headline numbers obscure a more sophisticated story: a textbook options swap strategy that locks in gains while maintaining upside exposure—executed just 11 days after Congress introduced legislation to ban exactly this kind of trading.

The timing is remarkable. The bipartisan Restore Trust in Congress Act was introduced January 15. Pelosi's disclosure—covering trades from December 24 through January 16—landed January 26. The trades themselves appear designed to maximize tax efficiency before any potential ban takes effect.

The Options Swap: What Pelosi Actually Did

The filing reveals a pattern that professional wealth managers will recognize immediately: sell appreciated stock, simultaneously buy call options on the same names.

Options Swap Strategy

Here's the mechanics:

What she sold (Dec 24-30, 2025):

StockAmount RangeNotes
Apple+0.80%$20-50MTwo separate sales
Nvidia+7.87%$1-5MAfter exercising options
Disney+3.55%$1-5MFull exit
Amazon-5.55%$1-5MPartial reduction
Alphabet-2.53%$1-5MRebalancing
Paypal+1.30%$250K-500KTrimming

What she bought (Dec 30 - Jan 16, 2026):

StockTypeAmount Range
Apple+0.80%Call Options$250K-500K
Nvidia+7.87%Call Options + Stock$350K-750K
Alphabet-2.53%Call Options + Stock$750K-1.5M
Amazon-5.55%Call Options$100K-250K
Alliancebernstein-6.92%Stock$1-5M
Vistra+4.60%Stock$100K-250K
Tempus Ai+4.71%Stock$50K-100K

Why this matters: By selling stock and buying LEAPS (long-dated call options), Pelosi:

  1. Realizes gains for tax purposes — Long-term capital gains are locked in
  2. Maintains upside exposure — Call options provide similar return profile with less capital
  3. Frees up capital — Net proceeds can be redeployed into new positions
  4. Limits downside risk — Options have defined maximum loss

This is not casual retail trading. It's the kind of strategy employed by family offices and high-net-worth individuals with sophisticated tax planning.

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The Timing Problem

Timeline

The legislative calendar makes this disclosure awkward:

  • January 12, 2026: Rep. Bryan Steil introduces the Stop Insider Trading Act in the House
  • January 14, 2026: House Administration Committee advances the bill 7-4
  • January 15, 2026: Sens. Moody and Gillibrand introduce companion bill in Senate
  • January 16, 2026: Pelosi executes final trades in this disclosure (new AB, GOOGL, NVDA, VST positions)
  • January 26, 2026: Pelosi files disclosure

The current STOCK Act requires disclosure within 45 days of a trade. Pelosi filed within the window, but the optics of a $69 million trading disclosure landing as Congress debates banning the practice entirely will fuel critics who argue the current system is inadequate.

The Spouse Loophole: Notably, the vast majority of these trades are attributed to "Spouse"—Paul Pelosi, who manages the family's investment portfolio. The new legislation specifically targets spouses and dependent children, closing a gap that current law leaves open.

The Thematic Pivot: From Consumer Tech to AI Infrastructure

Beyond the tax mechanics, the disclosure reveals a strategic portfolio shift. Pelosi is reducing exposure to mature consumer technology companies and adding positions that play the AI infrastructure buildout.

The exits make sense:

  • Apple — Facing antitrust scrutiny, iPhone sales concerns in China, questions about AI competitiveness vs. rivals
  • Disney — Streaming profitability challenges, cord-cutting headwinds
  • PayPal — Fintech competition intensifying, margin pressure

The new bets are thematic:

Tempus AI (TEM): Healthcare AI

Tempus applies AI to genomic and clinical data for precision medicine. Pelosi's January 2025 options purchase is now up 114.6%. The company just reported record Q4 results with $1.1B total contract value and 126% net revenue retention. CEO Eric Lefkofsky calls it "one of the strongest positions in company history."

Vistra Corp (VST): Data Center Power

Vistra is the "picks and shovels" play for AI. As hyperscalers build out AI data centers, they need massive electricity supply. Vistra's nuclear fleet and natural gas plants are positioned to meet this demand. The company signed a 20-year, 1,200 MW power purchase agreement for its Comanche Peak nuclear plant.

AllianceBernstein (AB): Yield + Stability

A more conservative addition—AB offers ~8% dividend yield and exposure to the asset management industry's growth. This may be a defensive position amid market volatility.

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Performance: The Track Record That Fuels the Controversy

Pelosi's trading disclosures consistently generate headlines because her returns have dramatically outperformed benchmarks.

According to Unusual Whales, which tracks congressional trading:

  • 2024 Return: 70.9% (vs. S&P 500: 25%)
  • 2025 Return: ~20% (vs. S&P 500: 15.2%)

Her 2025 options purchases have delivered strong returns:

Stock2025 Returnvs. S&P 500
Alphabet (GOOGL)+64.2%+49.0 pp
NVIDIA (NVDA)+55.6%+40.4 pp
Tempus AI (TEM)+19.0%+3.8 pp
S&P 500 (SPY)+15.2%
Apple (AAPL)+8.0%-7.2 pp
AllianceBernstein (AB)+2.5%-12.7 pp
Amazon (AMZN)+0.6%-14.6 pp
Vistra (VST)-4.5%-19.7 pp

Critics argue this outperformance suggests access to non-public information through her legislative role. Defenders note that her husband Paul Pelosi is a professional investor and the portfolio's tech focus simply benefited from broad sector tailwinds.

What the Legislation Would Change

The Restore Trust in Congress Act would:

  1. Ban stock ownership — Members must divest within 180 days
  2. Include family — Spouses and dependent children covered
  3. Allow blind trusts and diversified funds — ETFs, mutual funds, Treasury bonds remain permitted
  4. Mandate divestiture — Penalties of $2,000 or 10% of trade value (whichever is greater)

The bill has 126 House cosponsors and bipartisan support. However, the House version that advanced committee allows members to keep existing stock and only bans new purchases—a compromise Democrats called "a gift to insider traders."

86% of Americans support banning congressional stock trading, according to Public Consultation polling.

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What to Watch

  1. Options expiration — Pelosi's January 2025 LEAPS expire January 16, 2026. Watch for exercise disclosures in the coming weeks.

  2. Legislative progress — The Senate bill needs to advance for a ban to become law. Timing is uncertain.

  3. Tempus AI catalyst — Final audited FY2025 results due in early 2026 could validate or undermine the position.

  4. Vistra's nuclear expansion — Watch for additional power purchase agreements as AI demand accelerates.

The disclosure is a window into sophisticated wealth management—legal, technically public, but conducted with information access and timing advantages unavailable to ordinary investors. Whether that changes depends on whether 2026 is finally the year Congress restricts itself.


Related Research

Sources: House Financial Disclosure, Unusual Whales, Congress.gov, Senate.gov

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