CNBC recently highlighted the woes of Greenlight Capital hedge fund manager David Einhorn, a noted value investor, who has investors fleeing his fund after posting an 18.7 percent loss year-to-date and a 7.7 percent loss in the month of June alone. Nonetheless, it could present an opportunity for value-focused ETFs to shine when value investing falls back into favor with investors.

The latest bull market since February has been largely attributed to returns seen in stocks featuring high-growth and momentum, according to Robert Buckland of Citi Research.

“This usually favors growth and momentum trades and has produced bubbles in the past,” said Buckland. “These can be career-threatening for value managers.”

Related: Value ETFs Lag Growth, Momentum Counterparts

The Russell 2000, which tracks growth-oriented small-cap stocks, has been on a fortuitous path since February, gaining 16.45 percent since reaching a low in February.

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