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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

 

FORM N-CSR

 

CERTIFIED SHAREHOLDER REPORT OF REGISTERED
MANAGEMENT INVESTMENT COMPANIES

 

 

Investment Company Act file number: 811-23439
Exact name of registrant as specified in charter: ETF Opportunities Trust
Address of principal executive offices: 8730 Stony Point Parkway, 
Suite 205
Richmond, VA 23235
Name and address of agent for service The Corporation Trust Co.,
Corporation Trust Center,
1209 Orange St.,
Wilmington, DE 19801

 
With Copy to:
 
Practus, LLP
11300 Tomahawk Creek Parkway,
Suite 310
Leawood, KS  66211
Registrant’s telephone number, including area code: (804) 267-7400
Date of fiscal year end: December 31
Date of reporting period: June 30, 2025
   
   
  SMI 3Fourteen Full-Cycle Trend ETF

 

 

 

 

 

ITEM 1.(a).  Reports to Stockholders.

 

SMI 3Fourteen Full-Cycle Trend ETF Tailored Shareholder Report

SMI 3Fourteen Full-Cycle Trend ETF Tailored Shareholder Report

semi-annual Shareholder Report June 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

ticker: FCTE (Listed on the NASDAQ Stock Market®)

This semi-annual shareholder report contains important information about the SMI 3Fourteen Full-Cycle Trend ETF for the period of January 1, 2025 to June 30, 2025. You can find additional information about the Fund at www.3fourteensmi.com/fcte. You can also contact us at (844) 328-3383.

What were the Fund costs for the period?

(based on a hypothetical $10,000 investment)

Class Name
Costs of a $10,000 investment
Costs paid as a percentage of a $10,000 investment
SMI 3Fourteen Full-Cycle Trend ETF
$43
0.85
¹Annualized.

 

Sector Breakdown

Sector
%
Consumer Discretionary
0.1003
Consumer Staples
0.1003
Financials
0.2997
Health Care
0.0998
Industrials
0.3007
Information Technology
0.0992
bar

 

Top Ten Holdings
Copart, Inc.
5.04%
Walmart, Inc.
5.03%
Snap-on, Inc.
5.03%
Autozone, Inc.
5.02%
Automatic Data Processing, Inc.
5.02%
O'Reilly Automotive, Inc.
5.01%
Brown & Brown, Inc.
5.01%
Paychex, Inc.
5.01%
Costco Wholesale Corp.
5.01%
Mastercard, Inc. Class A
5.01%

 

For additional information about the Fund; including its prospectus, financial information, holdings and proxy information, visit www.3fourteensmi.com/fcte.

Key Fund Statistics

(as of June 30, 2025)

 

 

Fund Net Assets
$425,548,947
Number of Holdings
20
Total Advisory Fee Paid
$1,819,685
Portfolio Turnover Rate
177.22%

What did the Fund invest in?

(% of Net Assets as of June 30, 2025)

SMI 3Fourteen Full-Cycle Trend ETF Tailored Shareholder Report

 

 

 

ITEM 1.(b).  

 

Not applicable.

 

ITEM 2.CODE OF ETHICS.

 

Not applicable when filing a semi-annual report to shareholders.

 

ITEM 3.AUDIT COMMITTEE FINANCIAL EXPERT.

 

Not applicable when filing a semi-annual report to shareholders.

 

ITEM 4.PRINCIPAL ACCOUNTANT FEES AND SERVICES.

 

Not applicable when filing a semi-annual report to shareholders.

 

ITEM 5.AUDIT COMMITTEE OF LISTED REGISTRANTS.

 

Not applicable when filing a semi-annual report to shareholders.

 

ITEM 6.INVESTMENTS.

 

(a)The Registrant’s Schedule of Investments is included as part of the Financial Statements and Financial Highlights filed under Item 7 of this Form.

 

(b)Not applicable.

 

 

 

 

ITEM 7.FINANCIAL STATEMENTS AND FINANCIAL HIGHLIGHTS FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES.

 

SMI 3Fourteen Full-Cycle Trend ETF

FINANCIAL STATEMENTS

AND OTHER INFORMATION

Six Months Ended June 30, 2025 (unaudited)

SMI 3Fourteen Full-Cycle Trend ETF

Schedule of InvestmentsJune 30, 2025 (unaudited)

See Notes to Financial Statements

1

FINANCIAL STATEMENTS | JUNE 30, 2025

 

Shares

 

Value

100.00%

COMMON STOCKS

 

10.03%

CONSUMER DISCRETIONARY

 

Autozone, Inc.(A)

5,753

$21,356,459

 

O’Reilly Automotive, Inc.(A)

236,570

21,322,054

 

42,678,513

 

10.03%

CONSUMER STAPLES

 

Costco Wholesale Corp.

21,517

21,300,539

 

Walmart, Inc.

218,791

21,393,384

 

42,693,923

 

29.97%

FINANCIALS

 

Aon plc

59,399

21,191,187

 

Brown & Brown, Inc.

192,313

21,321,742

 

Corpay, Inc.(A)

63,928

21,212,589

 

Marsh & McLennan Cos, Inc.

97,405

21,296,629

 

Mastercard, Inc. Class A

37,905

21,300,336

 

Visa, Inc. Class A

59,763

21,218,853

 

127,541,336

9.98%

HEALTH CARE

 

ICON plc(A)

60,761

21,208,019

 

McKesson Corp.

29,021

21,266,008

 

42,474,027

 

30.07%

INDUSTRIALS

 

3M Co.

139,449

21,229,716

 

Automatic Data Processing, Inc.

69,244

21,354,851

 

Copart, Inc.(A)

436,724

21,430,048

 

Paychex, Inc.

146,542

21,315,999

 

Republic Services, Inc.

86,097

21,232,381

 

Snap-on, Inc.

68,721

21,384,601

 

127,947,596

 

9.92%

INFORMATION TECHNOLOGY

 

F5, Inc.(A)

71,320

20,990,902

 

Motorola Solutions, Inc.

50,427

21,202,536

 

42,193,438

 

100.00%

TOTAL COMMON STOCKS

 

(Cost: $425,149,828)

$425,528,833

 

100.00%

TOTAL INVESTMENTS

425,528,833

 

(Cost: $425,149,828)

0.00%

Other assets, net of liabilities

20,114

100.00%

NET ASSETS

$425,548,947

(A)Non-income producing

SMI 3Fourteen Full-Cycle Trend ETF

Statement of Assets and LiabilitiesJune 30, 2025 (unaudited)

See Notes to Financial Statements

2

FINANCIAL STATEMENTS | JUNE 30, 2025

ASSETS

Investments at value (cost of $425,149,828) (Note 1)

$425,528,833

Cash

395,477

Receivable for securities sold

205,270,599

Receivable for capital stock sold

57,378,730

Dividends receivable

55,610

TOTAL ASSETS

688,629,249

 

LIABILITIES

Accrued advisory fees

303,246

Payable for securities purchased

200,559,965

Payable for capital stock redeemed

62,217,091

TOTAL LIABILITIES

263,080,302

NET ASSETS

$425,548,947

 

Net Assets Consist of:

Paid-in capital

$463,097,475

Distributable earnings (accumulated deficits)

(37,548,528

)

Net Assets

$425,548,947

 

NET ASSET VALUE PER SHARE

Net Assets

$425,548,947

Shares Outstanding (unlimited number of shares of beneficial interest authorized without par value)

16,005,000

Net Asset Value and Offering Price Per Share

$26.59

See Notes to Financial Statements

3

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Statement of OperationsPeriod Ended June 30, 2025 (unaudited)

INVESTMENT INCOME

Dividend Income

$2,178,021

Total investment income

2,178,021

 

EXPENSES

Investment advisory fees (Note 2)

1,905,317

Total expenses

1,905,317

Investment Advisory fees waived (Note 2)

(85,632

)

Net expenses

1,819,685

Net investment income (loss)

358,336

 

REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS

Net realized gain (loss) on investments(1)

(6,773,752

)

Net change in unrealized appreciation (depreciation) of investments

16,319,440

Net realized and unrealized gain (loss) on investments

9,545,688

 

INCREASE (DECREASE) IN NET ASSETS FROM OPERATIONS

$9,904,024

(1)Includes realized gains (losses) as a result of in-kind transactions (Note 3).

See Notes to Financial Statements

4

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Statement of Changes in Net Assets)

Six Months Ended June 30, 2025 (unaudited)

 

Period Ended December 31, 2024*

INCREASE (DECREASE) IN NET ASSETS FROM

 

OPERATIONS

Net investment income (loss)

$358,336

$789,919

Net realized gain (loss) on investments

(6,773,752

)

11,586,663

Net change in unrealized appreciation (depreciation) of investments

16,319,440

(15,940,435

)

Increase (decrease) in net assets from operations

9,904,024

(3,563,853

)

 

DISTRIBUTIONS TO SHAREHOLDERS

Distributions from earnings

(387,032

)

(779,990

)

Decrease in net assets from distributions

(387,032

)

(779,990

)

 

CAPITAL STOCK TRANSACTIONS (NOTE 5)

Shares sold

436,836,916

1,102,807,907

Shares redeemed

(467,220,716

)

(652,048,309

)

Increase (decrease) in net assets from capital stock transactions

(30,383,800

)

450,759,598

 

NET ASSETS

Increase (decrease) during period

(20,866,808

)

446,415,755

Beginning of period

446,415,755

End of period

$425,548,947

$446,415,755

*The Fund commenced operations on July 2, 2024.

SMI 3Fourteen Full-Cycle Trend ETF

Financial HighlightsSelected Per Share Data Throughout Each Period

See Notes to Financial Statements

5

FINANCIAL STATEMENTS | JUNE 30, 2025

Six Months Ended
June 30, 2025 (unaudited) 

Period Ended December 31, 2024*

Net asset value, beginning of period

$25.95

$24.57

Investment activities

Net investment income (loss)(1)

0.02

0.05

Net realized and unrealized gain (loss) on investments(2)

0.64

1.38

Total from investment activities

0.66

1.43

Distributions

Net investment income

(0.02

)

(0.05

)

Total distributions

(0.02

)

(0.05

)

Net asset value, end of period

$26.59

$25.95

 

Total Return(3)

2.54

%

5.83

%

Ratios/Supplemental Data

Ratios to average net assets(4)

Expenses, gross

0.89

%

0.89

%

Expenses, net of waiver (Note 2)

0.85

%

0.85

%

Net investment income (loss)

0.17

%

0.40

%

Portfolio turnover rate(5)

177.22

%

180.24

%

Net assets, end of period (000’s)

$425,549

$446,416

(1)Per share amounts calculated using the average shares outstanding during the period.

(2)Realized and unrealized gains and losses per share in this caption are balancing amounts necessary to reconcile the change in net asset value per share for the period, and may not reconcile with the aggregate gains and losses in the Statement of Operations due to share transactions for the period.

(3)Total return is for the period indicated and has not been annualized.

(4)Ratios to average net assets have been annualized.

(5)Portfolio turnover rate is for the period indicated, excludes the effect of securities received or delivered from processing in-kind creations or redemptions, and has not been annualized.

*The Fund commenced operations on July 2, 2024.

6

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Notes to Financial StatementsJune 30, 2025 (unaudited)

NOTE 1 – ORGANIZATION AND SIGNIFICANT ACCOUNTING POLICIES

The SMI 3Fourteen Full-Cycle Trend ETF (the “Fund”) is a non-diversified series of ETF Opportunities Trust, a Delaware statutory trust (the “Trust”) which was organized on March 18, 2019 and is registered under the Investment Company Act of 1940, as amended (the “1940 Act”), as an open-end management investment company. The offering of the Fund’s shares is registered under the Securities Act of 1933, as amended. The Fund commenced operations on July 2, 2024.

The Fund’s investment objective is to seek long-term capital appreciation.

The Fund is deemed to be an individual reporting segment and is not part of a consolidated reporting entity. The objective and strategy of the Fund is used by 3Fourteen & SMI Advisory Services, LLC (the “Advisor”) to make investment decisions, and the results of the Fund’s operations, as shown in its Statement of Operations and Financial Highlights, is the information utilized for the day-today management of the Fund. Due to the significance of oversight and its role in the Fund’s management, the Advisor’s portfolio manager is deemed to be the Chief Operating Decision Maker.

The following is a summary of significant accounting policies consistently followed by the Fund. The policies are in conformity with accounting principles generally accepted in the United States of America (“GAAP”). The Fund follows the investment company accounting and reporting guidance of the Financial Accounting Standards Board (“FASB”) Accounting Standards Codification Topic 946 “Financial Services – Investment Companies”.

Security Valuation

The Fund records investments at fair value. Generally, the Fund’s domestic securities (including underlying ETFs which hold portfolio securities primarily listed on foreign (non-U.S.) exchanges) are valued each day at the last quoted sales price on each security’s primary exchange. Securities traded or dealt in upon one or more securities exchanges for which market quotations are readily available and not subject to restrictions against resale are valued at the last quoted sales price on the primary exchange or, in the absence of a sale on the primary exchange, at the mean between the current bid and ask prices on such exchange. If market quotations are not readily available, securities will be valued at their fair market value as determined in good faith under procedures approved by the Trust’s Board of Trustees (the “Board”). Although the Board is ultimately responsible for fair value determinations under Rule 2a-5 of the

7

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Notes to Financial Statements - continuedJune 30, 2025 (unaudited)

1940 Act, the Board has delegated day-to-day responsibility for oversight of the valuation of the Fund’s assets to the Advisor as the Valuation Designee pursuant to the Fund’s policies and procedures. Securities that are not traded or dealt in any securities exchange (whether domestic or foreign) and for which over-the-counter market quotations are readily available generally are valued at the last sale price or, in the absence of a sale, at the mean between the current bid and ask price on such over-the-counter market.

The Fund has a policy that contemplates the use of fair value pricing to determine the net asset value (“NAV”) per share of the Fund when market prices are unavailable as well as under special circumstances, such as: (i) if the primary market for a portfolio security suspends or limits trading or price movements of the security; and (ii) when an event occurs after the close of the exchange on which a portfolio security is principally traded, but prior to the time as of which the Fund’s NAV is calculated, that is likely to have changed the value of the security.

When the Fund uses fair value pricing to determine the NAV per share of the Fund, securities will not be priced on the basis of quotations from the primary market in which they are traded, but rather may be priced by another method that the Valuation Designee believes accurately reflects fair value. Any method used will be approved by the Board and results will be monitored to evaluate accuracy. The Fund’s policy is intended to result in a calculation of the Fund’s NAV that fairly reflects security values as of the time of pricing.

Accounting standards establish an authoritative definition of fair value and set out a hierarchy for measuring fair value. These standards require additional disclosures about the various inputs used to develop the measurements of fair value, which are summarized in the three broad levels listed below.

Various inputs are used in determining the value of the Fund’s investments. GAAP established a three-tier hierarchy of inputs to establish a classification of fair value measurements for disclosure purposes. Level 1 includes quoted prices in active markets for identical securities. Level 2 includes other significant observable market-based inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.). Level 3 includes significant unobservable inputs (including the Fund’s own assumptions in determining fair value of investments).

The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities.

8

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Notes to Financial Statements - continuedJune 30, 2025 (unaudited)

The following is a summary of the level of inputs used to value the Fund’s investments as of June 30, 2025:

 

Level 1
Quoted Prices

 

Level 2
Other Significant Observable Inputs

 

Level 3
Significant Unobservable Inputs

 

Total

Assets

Common Stocks

$425,528,833

$

$

$425,528,833

 

$425,528,833

$

$

$425,528,833

Refer to the Fund’s Schedule of Investments for a listing of the securities by type and sector. The Fund held no Level 3 securities at any time during the six months ended June 30, 2025.

Security Transactions and Income

Security transactions are accounted for on the trade date. The cost of securities sold is determined generally on specific identification basis. Realized gains and losses from security transactions are determined on the basis of identified cost for book and tax purposes. Dividends are recorded on the ex-dividend date. Interest income is recorded on an accrual basis.

Accounting Estimates

In preparing financial statements in conformity with GAAP, management makes estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures of contingent assets and liabilities at the date of the financial statements, as well as the reported amounts of investment income and expenses during the reporting period. Actual results could differ from those estimates.

Federal Income Taxes

The Fund has complied and intends to continue to comply with the requirements of the Internal Revenue Code applicable to regulated investment companies and to distribute all of its taxable income to its shareholders. The Fund also intends to distribute sufficient net investment income and net capital gains, if any, so that it will not be subject to excise tax on undistributed income and gains. Therefore, no federal income tax or excise provision is required.

9

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Notes to Financial Statements - continuedJune 30, 2025 (unaudited)

Management has concluded that no liability for unrecognized tax benefits should be recorded related to uncertain tax positions taken in the Fund’s tax returns. The Fund has no examinations in progress and management is not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly change in the next twelve months. Interest and penalties, if any, associated with any federal or state income tax obligations are recorded as income tax expense as incurred.

Reclassification of Capital Accounts

GAAP requires that certain components of net assets relating to permanent differences be reclassified between financial and tax reporting. For the six months ended June 30, 2025, there were no such reclassifications.

Dividends and Distributions

Dividends from net investment income, if any, are declared and paid at least quarterly by the Fund. The Fund distributes its net realized capital gains, if any, to shareholders annually. The Fund may also pay a special distribution at the end of a calendar year to comply with federal tax requirements. All distributions are recorded on the ex-dividend date.

Creation Units

The Fund issues and redeems shares to certain institutional investors (typically market makers or other broker-dealers) only in large blocks of at least 5,000 shares known as “Creation Units.” Purchasers of Creation Units (“Authorized Participants”) will be required to pay to Citibank, N.A. (the “Custodian”) a fixed transaction fee (“Creation Transaction Fee”) in connection with creation orders that is intended to offset the transfer and other transaction costs associated with the issuance of Creation Units. The standard Creation Transaction Fee will be the same regardless of the number of Creation Units purchased by an investor on the applicable Business Day. The Creation Transaction Fee charged by the Custodian for each creation order is $250. Authorized Participants wishing to redeem shares will be required to pay to the Custodian a fixed transaction fee (“Redemption Transaction Fee”) to offset the transfer and other transaction costs associated with the redemption of Creation Units. The standard Redemption Transaction Fee will be the same regardless of the number of Creation Units redeemed by an investor on the applicable Business Day. The Redemption Transaction Fee charged by the Custodian for each redemption order is $250.

10

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Notes to Financial Statements - continuedJune 30, 2025 (unaudited)

Except when aggregated in Creation Units, shares are not redeemable securities. Shares of the Fund may only be purchased or redeemed by Authorized Participants. An Authorized Participant is either (i) a broker-dealer or other participant in the clearing process through the Continuous Net Settlement System of the National Securities Clearing Corporation or (ii) a Depository Trust Company (“DTC”) participant and, in each case, must have executed an agreement with the Fund’s principal underwriter (the “Distributor”) with respect to creations and redemptions of Creation Units (“Participation Agreement”). Most retail investors will not qualify as Authorized Participants or have the resources to buy and sell whole Creation Units. Therefore, they will be unable to purchase or redeem the shares directly from the Fund. Rather, most retail investors will purchase shares in the secondary market with the assistance of a broker and will be subject to customary brokerage commissions or fees. The following table discloses the Creation Unit breakdown based on the NAV as of June 30, 2025:

Creation Unit Shares

 

Creation Transaction Fee

 

Value

SMI 3Fourteen Full-Cycle Trend ETF

5,000

$250

$139,250

To the extent contemplated by a participant agreement, in the event an Authorized Participant has submitted a redemption request in proper form but is unable to transfer all or part of the shares comprising a Creation Unit to be redeemed to the Distributor, on behalf of the Fund, by the time as set forth in a participant agreement, the Distributor may nonetheless accept the redemption request in reliance on the undertaking by the Authorized Participant to deliver the missing shares as soon as possible, which undertaking shall be secured by the Authorized Participant’s delivery and maintenance of collateral equal to a percentage of the value of the missing shares as specified in the participant agreement. A participant agreement may permit the Fund to use such collateral to purchase the missing shares, and could subject an Authorized Participant to liability for any shortfall between the cost of the Fund acquiring such shares and the value of the collateral. Amounts are disclosed as Segregated Cash Balance from Authorized Participants for Deposit Securities and Collateral Payable upon Return of Deposit Securities on the Statement of Assets and Liabilities, when applicable.

Officers and Trustees Indemnification

Under the Trust’s organizational documents, its officers and trustees are indemnified against certain liabilities arising out of the performance of their duties to the Fund. In addition, in the normal course of business, the Fund enters into

11

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Notes to Financial Statements - continuedJune 30, 2025 (unaudited)

contracts with its vendors and others that provide for general indemnifications. The Fund’s maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Fund. However, based on experience, the Fund expects that risk of loss to be remote.

NOTE 2 – INVESTMENT ADVISORY AND DISTRIBUTION AGREEMENTS AND OTHER TRANSACTIONS WITH AFFILIATES

The Advisor currently provides investment advisory services pursuant to an investment advisory agreement (the “Advisory Agreement”). Under the terms of the Advisory Agreement, the Advisor manages the investment portfolio of the Fund, subject to the policies adopted by the Board. In addition, the Advisor also: (i) furnishes office space and all necessary office facilities, equipment and executive personnel necessary for managing the assets of the Fund; and (ii) provides guidance and policy direction in connection with its daily management of the Fund’s assets, subject to the authority of the Board. Under the Advisory Agreement, the Advisor assumes and pays, at its own expense and without reimbursement from the Trust, all ordinary expenses of the Fund, except the fee paid to the Advisor pursuant to the Advisory Agreement, distribution fees or expenses under a Rule 12b-1 plan (if any), interest expenses, taxes, acquired fund fees and expenses, brokerage commissions and any other portfolio transaction related expenses and fees arising out of transactions effected on behalf of the Fund, credit facility fees and expenses, including interest expenses, and litigation and indemnification expenses and other extraordinary expenses not incurred in the ordinary course of the Fund’s business.

For its services with respect to the Fund, the Advisor is entitled to receive an annual advisory fee of 0.89%, calculated daily and payable monthly as a percentage of the Fund’s average daily net assets. The Advisor has contractually agreed to waive its advisory fee to an annual rate of 0.85% of the daily net assets of the Fund until April 20, 2026, and the Advisor may not terminate this arrangement prior to that date. The Advisor is not entitled to recover any previously waived fees.

The Advisor has retained Tidal Investments LLC (the “Sub-Advisor”), to serve as sub-advisor for the Fund. Pursuant to an Investment Sub-Advisory Agreement between the Advisor and the Sub-Advisor (the “Sub-Advisory Agreement”), the Sub-Advisor assists the Advisor in providing day-to-day management of the Fund’s portfolios.

For its services, the Sub-Advisor is paid a fee by the Advisor, which is calculated daily and payable monthly as a percentage of the Fund’s average daily

12

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Notes to Financial Statements - continuedJune 30, 2025 (unaudited)

net assets, at the following annual rate: 0.035% on the first $250 million in assets, and 0.030% on assets over $250 million, subject to a $20,000 annual minimum fee.

Fund Administrator

Commonwealth Fund Services, Inc. (“CFS”) acts as the Fund’s administrator. As administrator, CFS supervises all aspects of the operations of the Fund except those performed by the Advisor and the Sub-Advisor. For its services, fees to CFS are computed daily and paid monthly based on the average daily net assets of the Fund. Advisor pays these fees monthly.

Custodian

Citibank, N.A. serves as the Fund’s Custodian pursuant to a Global Custodial and Agency Services Agreement. For its services, Citibank, N.A. is entitled to a fee. The Advisor pays these fees monthly.

Fund Accountant and Transfer Agent

Citi Fund Services, Ohio, Inc. serves as the Fund’s Fund Accountant and Transfer Agent pursuant to a Services Agreement. For its services, Citi Fund Services, Ohio, Inc. is entitled to a fee. The Advisor pays these fees monthly.

Distributor

Foreside Fund Services, LLC serves as the Fund’s principal underwriter pursuant to an ETF Distribution Agreement. For its services, Foreside Fund Services, LLC is entitled to a fee. Advisor pays these fees monthly.

Trustees and Officers

Each Trustee who is not an “interested person” of the Trust receives compensation for their services to the Fund. Each Trustee receives an annual retainer fee, paid quarterly. Trustees are reimbursed for any out-of-pocket expenses incurred in connection with attendance at meetings. Advisor pays these costs.

Certain officers of the Trust are also officers and/or directors of CFS. Additionally, Practus, LLP serves as legal counsel to the Trust. John H. Lively, Secretary of the Trust, is Managing Partner of Practus, LLP. J. Stephen King, Jr., Assistant Secretary of the Trust, is a partner of Practus, LLP. Neither the officers and/or directors of CFS, Mr. Lively or Mr. King receive any special compensation from the Trust or the Fund for serving as officers of the Trust.

13

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Notes to Financial Statements - continuedJune 30, 2025 (unaudited)

The Fund’s Chief Compliance Officer and Assistant Chief Compliance Officer are not compensated directly by the Fund for their service. However, the Assistant Chief Compliance Officer is the Managing Member of Watermark Solutions, LLC (“Watermark”), which provides certain compliance services to the Fund, including the provision of the Chief Compliance Officer and the Assistant Chief Compliance Officer. The Chief Compliance Officer is the Managing Member of Fit Compliance, LLC, which has been retained by Watermark to provide the Chief Compliance Officer’s services. The Advisor pays these fees monthly.

NOTE 3 – INVESTMENTS

The costs of purchases and proceeds from the sales of securities other than in-kind transactions and short-term investments for the six months ended June 30, 2025 were as follows:

Purchases

 

Sales

$ 857,982,651

$841,459,985

The costs of purchases and proceeds from the sales of in-kind transactions associated with creations and redemptions for the six months ended June 30, 2025, were as follows:

Purchases

 

Sales

 

Realized Gain (Loss)

$414,798,927

$461,942,105

$(44,611,166)

NOTE 4 – DISTRIBUTIONS TO SHAREHOLDERS AND TAX COMPONENTS OF CAPITAL

Distributions are determined on a tax basis and may differ from net investment income and realized capital gains for financial reporting purposes. Differences may be permanent or temporary. Permanent differences are reclassified among capital accounts in the financial statements to reflect their tax character. Temporary differences arise when certain items of income, expense, gain or loss are recognized in different periods for financial statement and tax purposes; these differences will reverse at some time in the future. Differences in classification may also result from the treatment of short-term gains as ordinary income for tax purposes. The tax character of distributions paid during the six months ended June 30, 2025 and the period ended December 31, 2024, were as follows:

Distributions paid from:

Six Months Ended
June 30, 2025

 

Period Ended
December 31, 2024

Ordinary income

$387,032

$779,990

14

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Notes to Financial Statements - continuedJune 30, 2025 (unaudited)

As of June 30, 2025, the components of distributable earnings (accumulated deficits) on a tax basis were as follows:

Accumulated undistributed net investment income (loss)

$(18,767

)

Accumulated net realized gain (loss) on investments

(37,908,766

)

Net unrealized appreciation (depreciation) on investments

379,005

 

$(37,548,528

)

Cost of securities for Federal Income tax purpose and the related tax-based net unrealized appreciation (depreciation) consists of:

Cost

 

Gross Unrealized Appreciation

 

Gross Unrealized Depreciation

 

Total Unrealized Appreciation (Depreciation)

$425,149,828

$3,175,766

$(2,796,761)

$379,005

NOTE 5 – TRANSACTIONS IN SHARES OF BENEFICIAL INTEREST

Shares of the Fund are listed for trading on the NASDAQ Stock Market® and trade at market prices rather than at NAV. Shares of the Fund may trade at a price that is greater than, at, or less than NAV. The Fund will issue and redeem shares at NAV only in large blocks of 5,000 shares (each block of shares is called a “Creation Unit”). Creation Units are issued and redeemed for cash and/or in-kind for securities. Individual shares may only be purchased and sold in secondary market transactions through brokers. Except when aggregated in Creation Units, the shares are not redeemable securities of the Fund.

All orders to create Creation Units must be placed with the Fund’s distributor or transfer agent either (1) through the Continuous Net Settlement System of the NSCC (“Clearing Process”), a clearing agency that is registered with the Securities and Exchange Commission (“SEC”), by a “Participating Party,” i.e., a broker-dealer or other participant in the Clearing Process; or (2) outside the Clearing Process by a DTC Participant. In each case, the Participating Party or the DTC Participant must have executed an agreement with the Distributor with respect to creations and redemptions of Creation Units (“Participation Agreement”); such parties are collectively referred to as “APs” or “Authorized Participants.” Investors should contact the Distributor for the names of Authorized Participants. All Fund shares, whether created through or outside the Clearing Process, will be entered on the records of DTC for the account of a DTC Participant.

15

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Notes to Financial Statements - continuedJune 30, 2025 (unaudited)

Shares of beneficial interest transactions for the Fund were:

 

Six Months Ended
June 30, 2025

 

Period ended
December 31, 2024

Shares sold

16,570,000

41,470,000

Shares redeemed

(17,765,000

(24,270,000)

Net increase (decrease)

(1,195,000

)

17,200,000

NOTE 6 – RISKS OF INVESTING IN THE FUND

It is important that you closely review and understand the risks of investing in the Fund. The Fund’s NAV and investment return will fluctuate based upon changes in the value of its portfolio securities. You could lose money on your investment in the Fund, and the Fund could underperform other investments. There is no guarantee that the Fund will meet its investment objective. An investment in the Fund is not a deposit of a bank and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. A complete description of the principal risks is included in the Fund’s prospectus under the heading “Principal Risks.”

NOTE 7 – SECTOR RISK

If the Fund has significant investments in the securities of issuers in industries within a particular sector, any development affecting that sector will have a greater impact on the value of the net assets of the Fund than would be the case if the Fund did not have significant investments in that sector. In addition, this may increase the risk of loss of an investment in the Fund and increase the volatility of the Fund’s NAV per share. From time to time, circumstances may affect a particular sector and the companies within such sector. For instance, economic or market factors, regulation or deregulation, and technological or other developments may negatively impact all companies in a particular sector and therefore the value of a Fund’s portfolio will be adversely affected. As of June 30, 2025, 30.02% and 29.97% of the value of the net assets of the Fund were invested in securities within the Industrials and Financials sectors, respectively.

NOTE 8 – SUBSEQUENT EVENTS

Management has evaluated all transactions and events subsequent to the date of the Statement of Assets and Liabilities through the date on which these financial statements were issued. Except as already included in the notes to these financial statements, no additional items require disclosure.

16

FINANCIAL STATEMENTS | JUNE 30, 2025

SMI 3Fourteen Full-Cycle Trend ETF

Supplemental Information (unaudited)

Changes in and disagreements with accountants for open-end management investment companies.

Not applicable.

Proxy disclosures for open-end management investment companies.

Not applicable.

Remuneration paid to Trustees, Officers, and others of open-end management investment companies.

Because 3Fourteen & SMI Advisory Services, LLC (the “Advisor”) has agreed in the Investment Advisory Agreement to cover all operating expenses of the Fund, subject to certain exclusions as provided for therein, the Advisor pays the compensation to each Independent Trustee and the Chief Compliance Officer for services to the Fund from the Advisor’s management fees.

Statement Regarding Basis for Approval of Investment Advisory Contract.

Not applicable.

 

 

 

 

ITEM 8.CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES.

 

Not applicable.

 

ITEM 9. PROXY DISCLOSURES FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES.

 

Not applicable.

 

ITEM 10. REMUNERATION PAID TO DIRECTORS, OFFICERS, AND OTHERS OF OPEN-END MANAGEMENT INVESTMENT COMPANIES.

 

Reference Item 7 which includes remuneration paid to the Trustees and Officers in the Supplemental Information.

 

 

 

 

ITEM 11.STATEMENT REGARDING BASIS FOR APPROVAL OF INVESTMENT ADVISORY CONTRACT.

 

Not applicable.

 

ITEM 12.DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

 

Not applicable to this Registrant because it is not a closed-end management investment company.

 

ITEM 13.PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

 

Not applicable to this Registrant because it is not a closed-end management investment company.

 

ITEM 14.PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS.

 

Not applicable to this Registrant because it is not a closed-end management investment company.

 

ITEM 15.SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS.

 

There have been no material changes to the procedures by which shareholders may recommend nominees to the registrant’s board of trustees.

 

ITEM 16.  CONTROLS AND PROCEDURES.

 

(a) The registrant’s principal executive and principal financial officers, or persons performing similar functions, have concluded that the registrant’s disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940, as amended (the “1940 Act”) (17 CFR 270.30a-3(c))) are effective, as of a date within 90 days of the filing date of the report that includes the disclosure required by this paragraph, based on their evaluation of these controls and procedures required by Rule 30a-3(b) under the 1940 Act (17 CFR 270.30a-3(b)) and Rules 13a-15(b) or 15d-15(b) under the Securities Exchange Act of 1934, as amended (17 CFR 240.13a-15(b) or 240.15d- 15(b)).

 

(b) There were no changes in the registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act (17 CFR 270.30a-3(d)) that occurred during the period covered by this report that have materially affected, or are reasonably likely to materially affect, the registrant’s internal control over financial reporting.

 

ITEM 17.DISCLOSURE OF SECURITIES LENDING ACTIVITIES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

 

Not applicable to this Registrant because it is not a closed-end management investment company.

 

ITEM 18.RECOVERY OF ERRONEOUSLY AWARDED COMPENSATION.

 

Not applicable.

 

 

 

 

ITEM 19.EXHIBITS.

 

(a)(1)Code of Ethics in response to Item 2 of this Form N-CSR - Not applicable.

 

(a)(2)Any policy required by the listing standards adopted pursuant to Rule 10D-1 under the Exchange Act of 1934 - Not applicable.

 

(a)(3)Certifications pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto.

 

(a)(3)(1)Any written solicitation to purchase securities under Rule 23c-1 under the Investment Company Act of 1940 – Not applicable.

 

(a)(3)(2)Change in the registrant’s independent public accountant – Not applicable.

 

(b)Certifications pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 are attached hereto.

 

 

 

 

SIGNATURES

 

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

 

Registrant:   ETF Opportunities Trust

 

By (Signature and Title)*: /s/  Karen Shupe
  Karen Shupe
Principal Executive Officer
Date: September 4, 2025  

 

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

 

By (Signature and Title)*: /s/  Karen Shupe
  Karen Shupe
Principal Executive Officer
Date: September 4, 2025  
   
By (Signature and Title)*: /s/ Ann MacDonald
  Ann MacDonald
Principal Financial Officer
Date:  September 4, 2025  

* Print the name and title of each signing officer under his or her signature.

 

 


ATTACHMENTS / EXHIBITS

ATTACHMENTS / EXHIBITS

SECTION 302 CERTIFICATION

SECTION 906 CERTIFICATION

XBRL SCHEMA FILE

XBRL DEFINITION FILE

XBRL LABEL FILE

XBRL PRESENTATION FILE

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