Tuttle Capital Thematic ETF
(Ticker: GANZ)
Tuttle Capital AI Inference ETF
(Ticker: INFE)
Tuttle Capital AI TokenMax ETF
(Ticker: TOKM)
Tuttle Capital AI Substrate ETF
(Ticker: SUBA)
Tuttle Capital AI Test Equipment ETF
(Ticker: ATEQ)
Tuttle Capital AI Capacitor ETF
(Ticker: CAPQ)
Tuttle Capital Robotic Perception ETF
(Ticker: SEEU)
Tuttle Capital AI Thermal Management ETF
(Ticker: TEMP)
Tuttle Capital AI Memory Wall ETF
(Ticker: MWAL)
Tuttle Capital On-Device AI ETF
(Ticker: DVAI)
Tuttle Capital AI DC Power Architecture ETF
(Ticker: JUCE)
Tuttle Capital AI Network Fabric ETF
(Ticker: NWRK)
Tuttle Capital AI Drug Discovery ETF
(Ticker: AIHC)
Tuttle Capital Space Data Centers ETF
(Ticker: SEX)
Tuttle Capital Owned Intelligence ETF
(Ticker: MYNE)
Each Series listed on Cboe BZX Exchange, Inc.
Series of Managed Portfolio Series
Statement of Additional Information
October 7, 2026
This Statement of Additional Information (the “SAI”) provides general information about the Tuttle Capital Thematic ETF, Tuttle
Capital AI Inference ETF, Tuttle Capital AI TokenMax ETF, Tuttle Capital AI Substrate ETF, Tuttle Capital AI Test Equipment ETF,
Tuttle Capital AI Capacitor ETF, Tuttle Capital Robotic Perception ETF, Tuttle Capital AI Thermal Management ETF, Tuttle Capital
AI Memory Wall ETF, Tuttle Capital On-Device AI ETF, Tuttle Capital AI DC Power Architecture ETF, Tuttle Capital AI Network
Fabric ETF, Tuttle Capital AI Drug Discovery ETF, Tuttle Capital Space Data Centers ETF, and Tuttle Capital Owned Intelligence
ETF (each a “Fund” and, collectively, the “Funds”), each a series of Managed Portfolio Series (the “Trust”). This SAI is not a
prospectus and should be read in conjunction with the Funds’ current prospectus dated October 7, 2026 (the “Prospectus”), as
supplemented and amended from time to time. You can obtain a free copy of the Prospectus, SAI and annual and semi-annual
reports (once available), by calling the Funds at (833) 759-6110 (toll-free) or by email at opps@tuttlecapital.com. The Funds’
Prospectus, SAI and annual and semi-annual reports (once available), are available for viewing/downloading at https://
www.tuttlecap.com/etfs. General inquiries regarding the Funds may also be directed to the above telephone number or the
following address.
Investment Adviser:
Tuttle Capital Management, LLC
155 Lockwood Road
Riverside, Connecticut 06878
www.tuttlecapital.com
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION
TABLE OF CONTENTS
Board of Trustees
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        1
The Trust and the Funds
The Trust is a Delaware statutory trust organized on January 27, 2011, and is registered with the U.S. Securities and
Exchange Commission (“SEC”) as an open-end management investment company under the Investment Company Act
of 1940, as amended (the “1940 Act”) and the offering of each Fund’s shares is registered under the Securities Act of
1933, as amended (the “Securities Act”).
Shares of other series of the Trust are offered in separate prospectuses and SAIs, which may include from time to time
other funds managed by the Funds’ investment adviser, Tuttle Capital Management, LLC (“TCM” or the “Adviser”). 
Other than these other series managed by the Adviser, the Funds do not hold themselves out as related to any other
series within the Trust for purposes of investment and investor services, nor do they share the same investment adviser
with any other series of the Trust. The Funds’ Prospectus and this SAI are a part of the Trust’s Registration Statement
filed with the SEC.  Copies of the Trust’s complete Registration Statement may be obtained from the SEC upon
payment of the prescribed fee or may be accessed free of charge at the SEC’s website at https://www.sec.gov.  As
permitted by Delaware law, the Trust’s Board of Trustees (the “Board”) may create additional classes of the Funds and
may create additional series (and classes thereof) of the Trust and offer shares of these series and classes under the
Trust at any time without the vote of shareholders.
All shares of a series shall represent an equal proportionate interest in the assets held with respect to that series
(subject to the liabilities held with respect to that series and such rights and preferences as may have been established
and designated with respect to classes of shares of such series), and each share of a series shall be equal to each
other share of that series.
Shares are voted in the aggregate and not by series or class, except in matters where a separate vote is required by the
1940 Act, or when the matters affect only the interest of a particular series or class.  When matters are submitted to
shareholders for a vote, each shareholder is entitled to one vote for each full share owned and fractional votes for
fractional shares owned.
The Trust is not required to hold annual meetings of shareholders, and does not normally do so. Meetings of the
shareholders shall be called by any member of the Board upon written request of shareholders holding, in the
aggregate, not less than 10% of the shares, with such request specifying the purpose or purposes for which such
meeting is to be called.
Interests in the Funds are represented by shares of beneficial interest, each with no par value per share. Each share of
a Fund represents an equal proportionate interest in the assets and liabilities belonging to a Fund and is entitled to such
distributions out of the income belonging to the Fund as may be declared by the Board.
The Board has the authority from time to time to divide or combine the shares of any series into a greater or lesser
number of shares of that series without materially changing the proportionate beneficial interest of the shares of that
series in the assets belonging to that series or materially affecting the rights of shares of any other series.  In case of the
liquidation of a series, the holders of shares of the series being liquidated are entitled to receive a distribution out of the
assets, net of the liabilities, belonging to that series.  Expenses attributable to any series (or class thereof) are borne by
that series (or class).  Any general expenses of the Trust not readily identifiable as belonging to a particular series are
allocated by, or under the direction of, the Board to all applicable series (and classes thereof) in such manner and on
such basis as the Board in its sole discretion deems fair and equitable.  No shareholder is liable to further calls for the
payment of any sum of money or assessment whatsoever with respect to the Trust or any series of the Trust without his
or her express consent.
All consideration received by the Trust for the issue or sale of a Fund’s shares, together with all assets in which such
consideration is invested or reinvested, and all income, earnings, profits and proceeds thereof, including any proceeds
derived from the sale, exchange or liquidation of such assets, and any fund or payments derived from any reinvestment
of such proceeds, subject only to the rights of creditors, shall constitute the underlying assets of the Funds.
The Funds offer and issue shares at their net asset value per share (“NAV”) only in aggregations of a specified number
of shares (each a “Creation Unit”). Each Fund generally offers and issues shares in exchange for a basket of securities,
assets or other positions included in its portfolio (“Deposit Securities”) together with the deposit of a specified cash
payment (“Cash Component”).  The Trust reserves the right to permit or require the substitution of a “cash in lieu”
amount (“Deposit Cash”) to be added to the Cash Component to replace any Deposit Security.  Shares of the Funds are
listed on the Cboe BZX Exchange, Inc. (the “Exchange”) and trade on the Exchange at market prices that may differ
from the NAVs of the Funds’ shares. The Funds’ shares are also redeemable only in Creation Unit aggregations, and
generally in exchange for portfolio securities and a specified cash payment. 
Shares may be issued in advance of receipt of Deposit Securities subject to various conditions including a requirement
to maintain on deposit with the Trust cash at least equal to a specified percentage of the market value of the missing
Deposit Securities as set forth in the Participant Agreement (as defined below).  The Trust may impose a transaction fee
for each creation or redemption (the “Transaction Fee”).  In all cases, such fees will be limited in accordance with the
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        2
requirements of the SEC applicable to management investment companies offering redeemable securities. The Funds
may charge, either in lieu or in addition to the fixed creation or redemption Transaction Fee, a variable fee for creations
and redemptions in order to cover certain brokerage, tax, foreign exchange, execution, market impact and other costs
and expenses related to the execution of trades resulting from such transaction, up to a maximum of 2.00% of the NAV
per Creation Unit, inclusive of any Transaction Fees charged (if applicable).
Additional Information About Investment Objectives and Policies
The following discussion supplements the description of each Fund’s investment objective and principal investment
strategies and principal risks set forth in the Prospectus. Unless an investment strategy or policy described below is
specifically prohibited by the investment restrictions listed in the Prospectus, under the “Fundamental and Non-
Fundamental Investment Limitations” in this SAI, or by applicable law, the Funds may hold securities and engage in
various strategies as described hereafter, but are not obligated to do so. The Funds might not invest in all of these types
of securities or use all of these techniques at any one time. The Funds’ transactions in a particular type of security or
use of a particular technique are subject to limitations imposed by each Fund’s investment objective, policies and
restrictions described in the Funds’ Prospectus and/or this SAI, as well as by applicable laws.
Investment Objective
The investment objective of each Fund is set forth under the “Summary Section” in the Funds’ Prospectus. Each Fund is
“non-diversified” as that term is defined in the 1940 Act. As a non-diversified fund, each Fund is permitted to invest in
fewer securities at any one time than a diversified fund. The following information supplements, and should be read in
conjunction with, the prospectus. For a description of certain permitted investments discussed below, see “Description
of Permitted Investments” in this SAI.
Percentage Limitations
Each Fund’s compliance with its investment policies and limitations will be determined immediately after and as a result
of a Fund’s acquisition of such security or other asset. Accordingly, except with respect to borrowing or illiquid
investments, any subsequent change in values, net assets or other circumstances will not be considered when
determining whether an investment complies with a Fund’s investment policies and limitations. In addition, if a
bankruptcy or other extraordinary event occurs concerning a particular investment by a Fund, the Fund may receive
stock, real estate, or other investments that the Fund would not, or could not, buy. If this happens, the Fund will sell
such investments as soon as practicable while trying to maximize the return to its shareholders.
Market Volatility
U.S. and international markets have from time to time experienced significant volatility. Certain social, political,
economic, environmental and other conditions and events (such as natural disasters and weather-related phenomena
generally, epidemics and pandemics, terrorism, conflicts and social unrest) may adversely interrupt the global economy
and result in prolonged periods of significant market volatility. During certain volatile periods, the fixed income markets
have experienced substantially lower valuations, reduced liquidity, price volatility, credit downgrades, increased
likelihood of default and valuation difficulties. At times, concerns have spread to domestic and international equity
markets. In some cases, the stock prices of individual companies have been negatively impacted even though there
may be little or no apparent degradation in the financial conditions or prospects of that company. Continued volatility
may have adverse effects on the Funds, thus the risks discussed below and in the Prospectus may increase.
Equity Securities
An equity security represents a proportionate share of the ownership of a company. Its value is based on the success of
the company’s business, any income paid to stockholders, the value of its assets and general market conditions. The
value of equity securities will be affected by changes in the stock markets, which may be the result of domestic or
international political or economic news, changes in interest rates or changing investor sentiment. At times, stock
markets can be volatile and stock prices can change substantially. Equity securities risk affects a Fund’s NAV, which will
fluctuate as the value of the securities it holds changes. Not all stock prices change uniformly or at the same time, and
not all stock markets move in the same direction at the same time. Other factors affect a particular stock’s prices, such
as poor earnings reports by an issuer, loss of major customers, major litigation against an issuer, or changes in
governmental regulations affecting an industry. Adverse news affecting one company can sometimes depress the stock
prices of all companies in the same industry. Not all factors can be predicted. Common stocks and preferred stocks are
examples of equity securities. The fundamental risk of investing in common and preferred stock is the risk that the value
of the stock might decrease.
Exchange-Traded Funds
The Funds may invest in a range of exchange-traded funds (“ETFs”). ETFs may include, but are not limited to, Standard
& Poor’s Depositary Receipts (“SPDRs”), DIAMONDS, SM Nasdaq-100 Index Tracking Stock (“QQQs”), iShares,
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        3
HOLDRs, Fidelity Select Portfolios, Select Sector SPDRs, Fortune e-50 and Fortune 50. Additionally, the Funds may
invest in new exchange traded shares as they become available.
SPDRs represent ownership in the SPDR Trust, a unit investment trust that holds a portfolio of common stocks
designed to closely track the price performance and dividend yield of the Standard & Poor’s 500 Composite Stock Price
IndexTM (“S&P 500 Index”). SPDRs trade on the NYSE Arca under the symbol SPY. The value of SPDRs fluctuates in
relation to changes in the value of the underlying portfolio of common stocks. A MidCap SPDR is similar to a SPDR
except that it tracks the performance of the S&P MidCap 400 Index and trades on the NYSE Arca under the symbol
MDY. DIAMONDS represent an investment in the DIAMONDS Trust, a unit investment trust that serves as an index to
the Dow Jones Industrial Average (the “Dow”) in that its holding consists of the 30 component stocks of the Dow. The
DIAMONDS Trust is structured so that its shares trade at approximately 1/100 (one one-hundredth) of the value of the
Dow Index. The DIAMONDS Trust’s shares trade on the NYSE Arca under the symbol DIA. QQQs represent ownership
in the Nasdaq-100 Trust, a unit investment trust that holds a portfolio of common stocks designed to track the price
performance and dividend yield of the Nasdaq 100 Index by holding shares of all the companies on the Index. Shares
trade on the NYSE Arca under the symbol QQQ. The iShares are managed by BlackRock (“BlackRock”). They track 80
different indexes, including sector/industry indexes (such as the S&P Financial Sector Index), bond indexes (such as the
Barclay’s Capital U.S. Aggregate Index and the Barclay’s Capital 1-3 Year Treasury Bond Index) and international
indexes (such as the S&P Europe 500 Index). Each iShares international ETF represents a broad portfolio of publicly
traded stocks in a selected country. Each iShares international ETF seeks to generate investment results that generally
correspond to the market yield performance of a given Morgan Stanley Capital International (“MSCI”) Index. BlackRock
offers six iShares fixed income ETFs that track a particular Barclay’s Capital bond index. ETFs (both stock and fixed
income) are subject to all of the common stock risks, and the international iShares are subject to all of the foreign
securities risks described above. Investments in SPDRs, DIAMONDS, QQQs and iShares are considered to be
investments in investment companies, see “Investments in Other Investment Companies” below.
When the Funds invest in sector ETFs, there is a risk that securities within the same group of industries will decline in
price due to sector-specific market or economic developments. If a Fund invests more heavily in a particular sector, the
value of its shares may be especially sensitive to factors and economic risks that specifically affect that sector. As a
result, a Fund’s share price may fluctuate more widely than the value of shares of a mutual fund that invests in a
broader range of industries. Additionally, some sectors could be subject to greater government regulation than other
sectors. Therefore, changes in regulatory policies for those sectors may have a material effect on the value of securities
issued by companies in those sectors. The sectors in which each Fund may be more heavily invested will vary.
The shares of an ETF may be assembled in a block known as a creation unit and redeemed in-kind for a portfolio of the
underlying securities (based on the ETF’s NAV) together with a cash payment generally equal to accumulated dividends
as of the date of redemption. Conversely, a creation unit may be purchased from the ETF by depositing a specified
portfolio of the ETF’s underlying securities, as well as a cash payment generally equal to accumulated dividends of the
securities (net of expenses) up to the time of deposit. A Fund may redeem creation units for the underlying securities
(and any applicable cash), and may assemble a portfolio of the underlying securities and use it (and any required cash)
to purchase creation units, if a fund’s manager believes it is in the relevant Fund’s interest to do so. A fund’s ability to
redeem creation units may be limited by the 1940 Act, which provides that the ETFs will not be obligated to redeem
shares held by a fund in an amount exceeding one percent of their total outstanding securities during any period of less
than 30 days.
There is a risk that the underlying ETFs in which the Funds invest may terminate due to extraordinary events that may
cause any of the service providers to the ETFs, such as the trustee or sponsor, to close or otherwise fail to perform their
obligations to the ETF. Also, because the ETFs in which the Funds intend to invest may be granted licenses by
agreement to use the indices as a basis for determining their compositions and/or otherwise to use certain trade names,
the ETFs may terminate if such license agreements are terminated. In addition, an ETF may terminate if its entire NAV
falls below a certain amount. Although the Funds believe that, in the event of the termination of an underlying ETF a
Fund will be able to invest instead in shares of an alternate ETF tracking the same market index or another market
index with the same general market, there is no guarantee that shares of an alternate ETF would be available for
investment at that time. To the extent a Fund invests in a sector product, such Fund will be subject to the risks
associated with that sector.
Futures Contracts
Futures contracts provide for the future sale by one party and purchase by another party of a specified amount of a
specific security, class of securities, commodity, or an index at a specified future time and at a specified price. Futures
contracts may be issued with respect to fixed-income securities, foreign currencies, single stocks or financial indices,
including indices of U.S. government securities, foreign government securities, and equity or fixed-income securities as
well as commodities. U.S. futures contracts are traded on exchanges that have been designated “contract markets” by
the Commodity Futures Trading Commission (the “CFTC”) and must be executed through a futures commission
merchant (“FCM”), or brokerage firm, which is a member of the relevant contract market. Through their clearing
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        4
corporations, the exchanges guarantee performance of the contracts between the clearing members of the exchange.
The Funds may invest in futures traded on a foreign exchange, which may be subject to fewer regulations and investors
protections.
Each Fund may at times engage in futures transactions for hedging purposes, to gain exposure to a particular asset or
asset class or to enhance returns. This means that a purpose in entering into futures contracts is to protect a Fund from
fluctuations in the value of securities or interest rates without actually buying or selling the underlying debt or equity
security or other reference asset; or to seek outright returns. For example, if a Fund anticipates an increase in the price
of stocks, and intends to purchase stocks at a later time, the Fund could enter into a futures contract to purchase a
stock index as a temporary substitute for stock purchases. If an increase in the market occurs that influences the stock
index as anticipated, the value of the futures contracts will increase, thereby serving as a hedge against the Fund not
participating in a market advance. This technique is sometimes known as an anticipatory hedge. Conversely, if a Fund
holds stocks and seeks to protect itself from a decrease in stock prices, the Fund might sell stock index futures
contracts, thereby hoping to offset the potential decline in the value of its portfolio securities by a corresponding
increase in the value of the futures contract position. The Fund could protect against a decline in stock prices by selling
portfolio securities and investing in money market instruments, but the use of futures contracts enables it to maintain a
defensive position without having to sell portfolio securities.
If a Fund owns Treasury bonds and the portfolio manager expects interest rates to increase, such Fund may take a
short position in interest rate futures contracts. Taking such a position would have much the same effect as the Fund
selling Treasury bonds in its portfolio. If interest rates increase as anticipated, the value of the Treasury bonds would
decline, but the value of the Fund’s interest rate futures contract will increase, thereby keeping the NAV of the Fund
from declining as much as it may have otherwise. If, on the other hand, a portfolio manager expects interest rates to
decline, the Fund may take a long position in interest rate futures contracts in anticipation of later closing out the futures
position and purchasing the bonds. Although the Fund can accomplish similar results by buying securities with long
maturities and selling securities with short maturities, given the greater liquidity of the futures market than the cash
market, it may be possible to accomplish the same result more easily and more quickly by using futures contracts as an
investment tool to reduce risk.
Risk Factors in Futures Transactions
Liquidity Risk. Because futures contracts are generally settled within a day from the date they are closed out,
compared with a settlement period of two days for some types of securities, the futures markets can provide
superior liquidity to the securities markets. Nevertheless, there is no assurance that a liquid secondary market
will exist for any particular futures contract at any particular time. In addition, futures exchanges may establish
daily price fluctuation limits for futures contracts and may halt trading if a contract’s price moves upward or
downward more than the limit in a given day. On volatile trading days when the price fluctuation limit is reached,
it may be impossible for the Funds to enter into new positions or close out existing positions. If the secondary
market for a futures contract is not liquid because of price fluctuation limits or otherwise, the Funds may not be
able to promptly liquidate unfavorable futures positions and potentially could be required to continue to hold a
futures position until the delivery date, regardless of changes in its value. As a result, the Funds’ access to
other assets held to cover its futures positions also could be impaired.
Risk of Loss. Although the Funds may believe that the use of such contracts will benefit the Funds, the Funds’
overall performance could be worse than if the Funds had not entered into futures contracts if the Adviser’s
investment judgment proves incorrect. For example, if a Fund has hedged against the effects of a possible
decrease in prices of securities held in its portfolio and prices increase instead, the Fund will lose part or all of
the benefit of the increased value of these securities because of offsetting losses in its futures positions. In
addition, if a Fund has insufficient cash, it may have to sell securities from its portfolio to meet daily variation
margin requirements. Those sales may be, but will not necessarily be, at increased prices that reflect the rising
market and may occur at a time when the sales are disadvantageous to the Fund.
The risk of loss in trading futures contracts in some strategies can be substantial, due both to the low margin
deposits required, and the extremely high degree of leverage involved in futures pricing. Because the deposit
requirements in the futures markets are less onerous than margin requirements in the securities market, there
may be increased participation by speculators in the futures market that may also cause temporary price
distortions. A relatively small price movement in a futures contract may result in immediate and substantial loss
(as well as gain) to the investor. For example, if at the time of purchase, 10% of the value of the futures contract
is deposited as margin, a subsequent 10% decrease in the value of the futures contract would result in a total
loss of the margin deposit, before any deduction for the transaction costs, if the account were then closed out.
Thus, a purchase or sale of a futures contract may result in losses in excess of the amount invested in the
contract. The Funds will only engage in futures transactions when it is believed these risks are justified and will
engage in futures transactions primarily for risk management purposes and to seek returns.
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        5
Correlation Risk. The prices of futures contracts depend primarily on the value of their underlying instruments
or reference asset, such as a commodity. Because there are a limited number of types of futures contracts, it is
possible that the standardized futures contracts available to the Fund will not match exactly a Fund’s current or
potential investments. The Funds may buy and sell futures contracts based on underlying instruments with
different characteristics from the securities in which it typically invests for example, by hedging investments in
portfolio securities with a futures contract based on a broad index of securities, which involves a risk that the
futures position will not correlate precisely with the performance of a Fund’s investments.
Futures prices can also diverge from the prices of their underlying instruments or reference asset, even if the
underlying instruments closely correlate with the Funds’ investments. Futures prices are affected by factors
such as current and anticipated short-term interest rates, changes in volatility of the underlying instruments or
reference asset and the time remaining until expiration of the contract. Those factors may affect securities or
commodity prices differently from futures prices. Imperfect correlations between a Fund’s investments and its
futures positions also may result from differing levels of demand in the futures markets and the securities
markets, from structural differences in how futures and securities or commodities are traded, and from
imposition of daily price fluctuation limits for futures contracts. A Fund may buy or sell futures contracts with a
greater or lesser value than the securities it wishes to hedge or is considering purchasing in order to attempt to
compensate for differences in historical volatility between the futures contract and the securities, although this
may not be successful in all cases. If price changes in a Fund’s futures positions are poorly correlated with its
other investments, its futures positions may fail to produce desired gains or result in losses that are not offset
by the gains in the Fund’s other investments.
Margin Requirements:
The buyer or seller of a futures contract is not required to deliver or pay for the underlying instrument unless the
contract is held until the delivery date. However, both the buyer and seller are required to deposit “initial margin”
for the benefit of the FCM when the contract is entered into. Initial margin deposits:
•Are equal to a percentage of the contract’s value, as set by the exchange on which the contract is
traded; and
•Are similar to good faith deposits or performance bonds.
Unlike margin extended by a securities broker, initial margin payments do not constitute purchasing securities
on margin for purposes of a Fund’s investment limitations. If the value of either party’s position declines, that
party will be required to make additional “variation margin” payments for the benefit of the FCM to settle the
change in value on a daily basis. The party that has a gain may be entitled to receive all or a portion of this
amount. In the event of the bankruptcy of the FCM that holds margin on behalf of a Fund, the Fund may be
entitled to return of margin owed to that Fund only in proportion to the amount received by the FCM’s other
customers.
Forward Contracts
The Funds may use forward contracts to achieve substantially similar strategies as those executed using futures
contracts. A forward contract is an obligation to purchase or sell an asset at a future date at a price agreed upon by the
parties. The Funds may either accept or make delivery of the asset at the maturity of the contract or, prior to maturity,
enter into a closing transaction involving the purchase or sale of an offsetting contract. The Funds may engage in
forward contracts for hedging or investment purposes. Forward contracts are not traded on regulated exchanges and
incur the risk of default by the counter party to the transaction.
Swap Agreements
The Funds may enter into swap agreements for purposes of attempting to gain exposure to equity, debt, commodities or
other asset markets without actually purchasing those assets, or to hedge a position. Swap agreements are two-party
contracts entered into primarily by institutional investors for periods ranging from a day to more than one year. In a
standard “swap” transaction, two parties agree to exchange the returns (or differentials in rates of return) earned or
realized on particular predetermined investments or instruments. The gross returns to be exchanged or “swapped”
between the parties are calculated with respect to a “notional amount,” i.e., the return on or increase in value of a
particular dollar amount invested in a “basket” of securities representing a particular index.
Most swap agreements entered into by the Funds calculate the obligations of the parties to the agreement on a “net
basis.” Consequently, a Fund’s current obligations (or rights) under a swap agreement will generally be equal only to the
net amount to be paid or received under the agreement based on the relative values of the positions held by each party
to the agreement (the “net amount”). Payments may be made at the conclusion of a swap agreement or periodically
during its term.
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        6
Swap agreements do not involve the delivery of securities or other underlying assets. Accordingly, if a swap is entered
into on a net basis, if the other party to a swap agreement defaults, a Fund’s risk of loss consists of the net amount of
payments that the Fund is contractually entitled to receive, if any.
The net amount of the excess, if any, of a Fund’s obligations over its entitlements with respect to a swap agreement
entered into on a net basis will be accrued daily and an amount of cash or liquid asset having an aggregate NAV value
at least equal to the accrued excess will be maintained in an account with the Custodian. The Fund will also establish
and maintain such accounts with respect to its total obligations under any swaps that are not entered into on a net
basis.
Because they are two-party contracts and because they may have terms of greater than seven days, swap agreements
may be considered to be illiquid for the Funds’ illiquid investment limitations. A Funds will not enter into any swap
agreements unless the Adviser believes that the other party to the transaction is creditworthy. A Fund bears the risk of
loss of the amount expected to be received under a swap agreement in the event of the default or bankruptcy of a swap
agreement counterparty.
The Funds may enter into a swap agreement in circumstances where the Adviser believes that it may be more cost
effective or practical than buying the securities represented by such index or a futures contract or an option on such
index. The counterparty to any swap agreement will typically be a bank, investment banking firm or broker/dealer. The
counter-party will generally agree to pay a Fund the amount, if any, by which the notional amount of the swap
agreement would have increased in value had it been invested in the particular stocks represented in the index, plus the
dividends that would have been received on those stocks. The Fund will agree to pay to the counter-party a floating rate
of interest on the notional amount of the swap agreement plus the amount, if any, by which the notional amount would
have decreased in value had it been invested in such stocks. Therefore, the return to the Fund on any swap agreement
should be the gain or loss on the notional amount plus dividends on the stocks less the interest paid by the Fund on the
notional amount.
The swap market has grown substantially in recent years with a large number of banks and investment banking firms
acting both as principals and as agents utilizing standardized swap documentation. As a result, the swap market has
become relatively liquid in comparison with the markets for other similar instruments that are traded in the OTC market.
Options
The Funds may utilize call and put options, on securities and/or futures, to attempt to protect against possible changes
in the market value of securities held in or to be purchased for a Fund’s portfolio and to generate income or gain for the
Fund. The ability of the Funds to successfully utilize options will depend on the Adviser’s ability to predict pertinent
market movements, which cannot be assured. The Funds will comply with applicable regulatory requirements when
implementing these techniques and instruments. The Funds may write (sell) covered call options and covered put
options and purchase call and put options. The purpose of engaging in options transactions is to reduce the effect of
price fluctuations of the securities owned by a Fund (and involved in the options) on the Fund’s NAV per share and to
generate additional revenues. A covered call option is an option sold on a security owned by the seller of the option in
exchange for a premium. A call option gives the purchaser of the option the right to buy the underlying securities at the
exercise price during the option period. If the option is exercised by the purchaser during the option period, the seller is
required to deliver the underlying security against payment of the exercise price. The seller’s obligation terminates upon
expiration of the option period or when the seller executes a closing purchase transaction with respect to such option.
When the Funds write a covered call option, they profit from the premium paid by the buyer but give up the opportunity
to profit from an increase in the value of the underlying security above the exercise price. At the same time, the seller
retains the risk of loss from a decline in the value of the underlying security during the option period. Although the seller
may terminate its obligation by executing a closing purchase transaction, the cost of effecting such a transaction may be
greater than the premium received upon its sale, resulting in a loss to the seller if such an option expires unexercised,
the seller realizes a gain equal to the premium received. Such a gain may be offset or exceeded by a decline in the
market value of the underlying security during the option period. If an option is exercised, the exercise price, the
premium received and the market value of the underlying security determine the gain or loss realized by the seller.
When a Fund sells a covered put option, it has the obligation to buy, and the purchaser of the put the right to sell, the
underlying security at the exercise price during the option period. The obligation of the Fund is terminated when the
purchaser exercises the put option, when the option expires or when a closing purchase transaction is effected by the
Fund. The Fund’s gain on the sale of a put option is limited to the premium received. The Fund’s potential loss on a put
option is determined by taking into consideration the exercise price of the option, the market price of the underlying
security when the put is exercised and the premium received. Although the Funds risk a substantial loss if the price of
the security on which they have sold a put option drops suddenly, they can protect themselves against serious loss by
entering into a closing purchase transaction. The degree of loss will depend upon the Funds’ ability to detect the
movement in the security’s price and to execute a closing transaction at the appropriate time. The Funds will write
options on such portion of its portfolio as management determines is appropriate in seeking to attain each relevant
Fund’s objective. The Funds will write options when management believes that a liquid secondary market will exist on a
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        7
national securities exchange for options of the same series so that the Funds can effect a closing purchase transaction
if it desires to close out its position. Consistent with the investment policies of each Fund, a closing purchase transaction
will ordinarily be effected to realize a profit on an outstanding option, to prevent an underlying security from being called
or to permit the sale of the underlying security. Effecting a closing purchase transaction will permit the Fund to write
another option on the underlying security with either a different exercise price or expiration date or both. The Funds may
purchase put options to protect against declines in the market value of portfolio securities or to attempt to retain
unrealized gains in the value of portfolio securities. Put options might also be purchased to facilitate the sale of portfolio
securities. The Funds may purchase call options as a temporary substitute for the purchase of individual securities,
which then could be purchased in orderly fashion. Upon the purchase of the securities, a Fund would normally terminate
the call position. The purchase of both put and call options involves the risk of loss of all or part of the premium paid. If
the price of the underlying security does not rise (in the case of a call) or drop (in the case of a put) by an amount at
least equal to the premium paid for the option contract, the Fund will experience a loss on the option contract equal to
the deficiency.
Regulation as a Commodity Pool Operator
To the extent a Fund invests in “commodity interests” as defined under the Commodity Exchange Act (the “CEA”), the
Adviser, with respect to such Fund, intends to file with the National Futures Association, a notice claiming an exclusion
from the definition of the term “commodity pool operator” under the CEA, as amended, and Rule 4.5 of the Commodity
Futures Trading Commission promulgated thereunder, with respect to such Fund’s operations. Accordingly, neither the
Funds, nor the Adviser are subject to registration or regulation as a commodity pool operator or commodity trading
advisor.
Borrowing
While the Funds have no present intention to do so, they may engage in borrowing. Borrowing creates an opportunity
for increased return, but, at the same time, creates special risks. Furthermore, if the Funds were to engage in
borrowing, an increase in interest rates could reduce the value of a Fund’s shares by increasing such Fund’s interest
expense. Subject to the limitations described under “Investment Limitations” below, the Funds may be permitted to
borrow for temporary purposes and/or for investment purposes. Such a practice will result in leveraging of a Fund’s
assets and may cause such Fund to liquidate portfolio positions when it would not be advantageous to do so. This
borrowing may be secured or unsecured. Provisions of the 1940 Act require the Funds to maintain continuous asset
coverage (that is, total assets including borrowings, less liabilities exclusive of borrowings) of 300% of the amount
borrowed, with an exception for borrowings not in excess of 5% of a Fund’s total assets made for temporary purposes.
Any borrowings for temporary purposes in excess of 5% of a Fund’s total assets will count against this asset coverage
requirement. If the 300% asset coverage should decline as a result of market fluctuations or other reasons, a Fund may
be required to sell some of its portfolio holdings within three days to reduce the debt and restore the 300% asset
coverage, even though it may be disadvantageous from an investment standpoint if a Fund sells securities at that time.
Borrowing will tend to exaggerate the effect on NAV of any increase or decrease in the market value of a Fund’s
portfolio. Money borrowed will be subject to interest costs which may or may not be recovered by appreciation of the
securities purchased, if any. The Funds also may be required to maintain minimum average balances in connection with
such borrowings or to pay a commitment or other fee to maintain a line of credit; either of these requirements would
increase the cost of borrowing over the stated interest rate.
Illiquid Investments
While the Funds have no present intention to do so, the Funds may be invested in securities that become illiquid
investments, which may include securities that are not readily marketable and securities that are not registered under
the Securities Act. A Fund may not acquire any illiquid investments if, immediately after the acquisition, each Fund
would have invested more than 15% of its net assets in illiquid investments that are assets. The term “illiquid
investments” for this purpose means any investment that a fund reasonably expects cannot be sold or disposed of in
current market conditions in seven calendar days or less without the sale or disposition significantly changing the
market value of the investment, as determined pursuant to the provisions of Rule 22e-4 under the 1940 Act. The Fund
may not be able to sell illiquid investments when the Adviser considers it desirable to do so or may have to sell such
investments at a price that is lower than the price that could be obtained if the investments were more liquid. In addition,
the sale of illiquid investments also may require more time and may result in higher dealer discounts and other selling
expenses than does the sale of investments that are more liquid. Illiquid investments also may be more difficult to value
due to the unavailability of reliable market quotations for such investments, and investments in illiquid investments may
have an adverse impact on NAV.
Institutional markets for restricted securities have developed as a result of the promulgation of Rule 144A under the
Securities Act, which provides a safe harbor from Securities Act registration requirements for qualifying sales to
institutional investors. When Rule 144A restricted securities present an attractive investment opportunity and otherwise
meet selection criteria, the Funds may make such investments. Whether or not such investments are illiquid depends on
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        8
the market that exists for the particular investment. It is not possible to predict with assurance exactly how the market
for Rule 144A restricted securities or any other security will develop. An investment which when purchased enjoyed a
fair degree of marketability may subsequently become illiquid. In such event, appropriate remedies are considered to
minimize the effect on a Fund’s liquidity.
Indexed Securities
The Funds may purchase indexed securities consistent with its investment objectives. Indexed securities are those, the
value of which varies positively or negatively in relation to the value of other securities, securities indices or other
financial indicators. Indexed securities may be debt securities or deposits whose value at maturity or coupon rate is
determined by reference to a specific instrument or statistic. Issuers of indexed securities have included banks,
corporations and certain U.S. Government agencies.
The performance of indexed securities depends to a great extent on the performance of the security or other instrument
to which they are indexed and also may be influenced by interest rate changes in the U.S. and abroad. Indexed
securities are subject to the credit risks associated with the issuer of the security, and their values may decline
substantially if the issuer’s creditworthiness deteriorates. Indexed securities may be more volatile than the underlying
instruments. Certain indexed securities that are not traded on an established market may be deemed illiquid.
Insured Bank Obligations
The Funds may invest in insured bank obligations. The Federal Deposit Insurance Corporation (“FDIC”) insures the
deposits of federally insured banks and savings and loan associations (collectively referred to as “banks”) up to
$250,000. The Funds may purchase bank obligations which are fully insured as to principal by the FDIC. Currently, to
remain fully insured as to principal, these investments must be limited to $250,000 per bank, if the principal amount and
accrued interest together exceed $250,000, the excess principal and accrued interest will not be insured. Insured bank
obligations may have limited marketability.
Investment Company Securities
A Fund may invest in the securities of other investment companies to the extent that such an investment would be
consistent with the requirements of the 1940 Act, and the Fund’s investment objectives. Investments in the securities of
other investment companies may involve duplication of advisory fees and certain other expenses. By investing in
another investment company, the Fund becomes a shareholder of that investment company. As a result, the Fund’s
shareholders indirectly will bear the Fund’s proportionate share of the fees and expenses paid by shareholders of the
other investment company, in addition to the fees and expenses the Fund’s shareholders directly bear in connection
with the Fund’s own operations.
Generally, under Section 12(d)(1) of the 1940 Act, a Fund may invest only up to 5% of its total assets in the securities of
any one investment company (ETF or other mutual funds), but may not own more than 3% of the outstanding voting
stock of any one investment company (the “3% Limitation”) or invest more than 10% of its total assets in the securities
of other investment companies. However, Section 12(d)(1)(F) of the 1940 Act allows a Fund to exceed the 5% limitation
and the 10% limitation described above. Section 12(d)(1)(F) of the 1940 Act, provides that the provisions of paragraph
12(d)(1) shall not apply to securities purchased or otherwise acquired by the Fund if (i) immediately after such purchase
or acquisition not more than 3% of the total outstanding stock of such registered investment company is owned by the
Fund and all affiliated persons of the Fund; and (ii) the Fund has not offered or sold after January 1, 1971, and is not
proposing to offer or sell any security issued by it through a principal underwriter or otherwise at a public or offering
price which includes a sales load of more than 1½% percent. An investment company that issues shares to the Fund
pursuant to paragraph 12(d)(1)(F) shall not be required to redeem its shares in an amount exceeding 1% of such
investment company’s total outstanding shares in any period of less than thirty days. A Fund (or the Adviser acting on
behalf of the Fund) must comply with the following voting restrictions: when the Fund exercises voting rights, by proxy or
otherwise, with respect to investment companies owned by the Fund, the Fund will either seek instruction from the
Fund’s shareholders with regard to the voting of all proxies and vote in accordance with such instructions, or vote the
shares held by the Fund in the same proportion as the vote of all other holders of such security. Because other
investment companies employ an investment adviser, such investments by the Fund may cause shareholders to bear
duplicate fees. In addition, Rule 12d1-4 of the 1940 Act permits the Fund to invest in other investment companies (or
other investment companies to invest in a Fund) beyond the statutory limits of Section 12(d)(1), subject to certain
conditions. Each Fund reserves the right to rely on Rule 12d1-4 as well as other available exceptions to the provisions
of Section 12(d)(1), including Section 12(d)(1)(F).
Lending Portfolio Securities
For the purpose of achieving income, the Funds may lend their portfolio securities, provided (1) the loan is secured
continuously by collateral consisting of U.S. Government securities or cash or cash equivalents (cash, U.S. Government
securities, negotiable certificates of deposit, bankers’ acceptances or letters of credit) maintained on a daily mark-to-
market basis in an amount at least equal to the current market value of the securities loaned, (2) the Funds may at any
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        9
time call the loan and obtain the return of securities loaned, (3) the Funds will receive any interest or dividends received
on the loaned securities, and (4) the aggregate value of the securities loaned will not at any time exceed one-third of the
total assets of a Fund.
U.S. Government Securities
The Funds may invest in U.S. government securities. These securities may be backed by the credit of the government
as a whole or only by the issuing agency. U.S. Treasury bonds, notes, and bills and some agency securities, such as
those issued by the Federal Housing Administration and the Government National Mortgage Association (Ginnie Mae),
are backed by the full faith and credit of the U.S. government as to payment of principal and interest and are the highest
quality government securities. Other securities issued by U.S. government agencies or instrumentalities, such as
securities issued by the Federal Home Loan Banks and the Federal Home Loan Mortgage Corporation (Freddie Mac),
are supported only by the credit of the agency that issued them, and not by the U.S. government. Securities issued by
the Federal Farm Credit System, the Federal Land Banks, and the Federal National Mortgage Association (Fannie Mae)
are supported by the agency’s right to borrow money from the U.S. Treasury under certain circumstances, but are not
backed by the full faith and credit of the U.S. government.
The Funds’ investments in U.S. Government securities may include agency step-up obligations. These obligations are
structured with a coupon rate that “steps-up” periodically over the life of the obligation. Step-up obligations typically
contain a call option, permitting the issuer to buy back the obligation upon exercise of the option. Step-up obligations
are designed for investors who are unwilling to invest in a long-term security in a low interest rate environment. Step-up
obligations are used in an attempt to reduce the risk of a price decline should interest rates rise significantly at any time
during the life of the obligation. However, step-up obligations also carry the risk that market interest rates may be
significantly below the new, stepped-up coupon rate. If this occurs, the issuer of the obligation likely will exercise the call
option, leaving investors with cash to reinvest. As a result, these obligations may expose the Funds to the risk that
proceeds from a called security may be reinvested in another security paying a lower rate of interest.
Fundamental and Non-Fundamental Investment Limitations
The Trust (on behalf of the Funds) has adopted the following restrictions as fundamental policies, which may not be
changed without the favorable “vote of the holders of a majority of the outstanding voting securities” of a Fund, as
defined under the 1940 Act.  Under the 1940 Act, the “vote of the holders of a majority of the outstanding voting
securities” means the vote of the holders of the lesser of (i) 67% of the shares of a Fund represented at a meeting at
which the holders of more than 50% of its outstanding shares are represented at the meeting in person or by proxy; or
(ii) more than 50% of the outstanding shares of the Fund. Other investment practices which may be changed by the
Board without the approval of shareholders to the extent permitted by applicable law, regulation or regulatory policy are
considered non-fundamental (“Non-Fundamental”).
Each Fund may not:
1.Issue senior securities, borrow money or pledge their assets, except that (i) the Fund may borrow from banks in
amounts not exceeding one-third of its total assets (including the amount borrowed) less liabilities (other than
borrowings); and (ii) this restriction shall not prohibit the Fund from engaging in options transactions, reverse
repurchase agreements, purchasing securities on a when-issued, delayed delivery, or forward delivery basis, or
short sales in accordance with its objectives and strategies;
2.Underwrite the securities of other issuers (except that the Fund may engage in transactions involving the
acquisition, disposition or resale of its portfolio securities under circumstances where it may be considered to
be an underwriter under the Securities Act);
3.Purchase or sell real estate or interests in real estate, unless acquired as a result of ownership of securities
(although the Fund may purchase and sell securities which are secured by real estate and securities of
companies that invest or deal in real estate);
4.Purchase or sell physical commodities or commodities contracts, unless acquired as a result of ownership of
securities or other instruments and provided that this restriction does not prevent the Fund from engaging in
transactions involving currencies and futures contracts and options thereon or investing in securities or other
instruments that are secured by physical commodities;
5.Make personal loans of money or loans of its assets to persons who control or are under common control with
the Fund (except that the Fund may lend its portfolio securities, enter into repurchase agreements, purchase
debt securities consistent with the investment policies of the Fund, and invest in loans, including assignments
and participation interests); or
6.(a) (Tuttle Capital Thematic ETF only) Concentrate its investments (i.e., invest more than 25% of its net assets)
in any industry or group of related industries.
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        10
(b) (Tuttle Capital AI Inference ETF, Tuttle Capital AI TokenMax ETF, Tuttle Capital AI Test Equipment ETF,
Tuttle Capital AI Memory Wall ETF, Tuttle Capital On-Device AI ETF, and Tuttle Capital AI Network Fabric ETF
only) Concentrate its investments (i.e., invest more than 25% of its net assets) in any industry or group of
related industries, except that the Fund will concentrate its investments in the semiconductor industry.
(c) (Tuttle Capital AI Drug Discovery ETF only) Concentrate its investments (i.e., invest more than 25% of its
net assets) in any industry or group of related industries, except that the Fund will concentrate its investments
in the biotechnology and life sciences tools & services industries.
(d) (Tuttle Capital AI Substrate ETF and Tuttle Capital AI Capacitor ETF only) Concentrate its investments (i.e.,
invest more than 25% of its net assets) in any industry or group of related industries, except that the Fund will
concentrate its investments in the electronic components industry.
(e) (Tuttle Capital AI DC Power Architecture ETF only) Concentrate its investments (i.e., invest more than 25%
of its net assets) in any industry or group of related industries, except that the Fund will concentrate its
investments in the electrical equipment and semiconductors industries.
(f) (Tuttle Capital Owned Intelligence ETF only) Concentrate its investments (i.e., invest more than 25% of its
net assets) in any industry or group of related industries, except that the Fund will concentrate its investments
in the software industry.
(g) (Tuttle Capital Space Data Centers ETF only) Concentrate its investments (i.e., invest more than 25% of its
net assets) in any industry or group of related industries, except that the Fund will concentrate its investments
in the aerospace & defense industry.
(h) (Tuttle Capital Robotic Perception ETF only) Concentrate its investments (i.e., invest more than 25% of its
net assets) in any industry or group of related industries, except that the Fund will concentrate its investments
in the electronic equipment & instruments industry.
(i) (Tuttle Capital AI Thermal Management ETF only) Concentrate its investments (i.e., invest more than 25% of
its net assets) in any industry or group of related industries, except that the Fund will concentrate its
investments in the electrical equipment and building products industries.
The foregoing concentration policies do not apply to securities issued or guaranteed by the U.S. government, its
agencies or instrumentalities or repurchase agreements with respect thereto.
In addition to the investment restrictions adopted as fundamental policies as set forth above, the Funds observe the
following non-fundamental restrictions, which may be changed without a shareholder vote. The following non-
fundamental policies may be changed without shareholder approval upon 60 days’ written notice to shareholders. Each
defined term used in the Funds’ non-fundamental policies has the same meaning as set forth in the Funds’ Prospectus
unless otherwise specified.
1.(Tuttle Capital AI Inference ETF only) Under normal market conditions, the Fund invests at least 80% of its net
assets (plus borrowings for investment purposes) in equity securities of AI Inference Companies. 
2.(Tuttle Capital AI TokenMax ETF only) Under normal market conditions, the Fund invests at least 80% of its net
assets (plus borrowings for investment purposes) in equity securities of AI TokenMax Companies.
3.(Tuttle Capital AI Test Equipment ETF only) Under normal market conditions, the Fund invests at least 80% of
its net assets (plus borrowings for investment purposes) in equity securities of AI Test Equipment Companies.
4.(Tuttle Capital AI Memory Wall ETF only) Under normal market conditions, the Fund invests at least 80% of its
net assets (plus borrowings for investment purposes) in equity securities of AI Memory Wall Companies.
5.(Tuttle Capital On-Device AI ETF only) Under normal market conditions, the Fund invests at least 80% of its net
assets (plus borrowings for investment purposes) in equity securities of On-Device AI Companies.
6.(Tuttle Capital AI Network Fabric ETF only) Under normal market conditions, the Fund invests at least 80% of
its net assets (plus borrowings for investment purposes) in equity securities of AI Network Fabric Companies.
7.(Tuttle Capital AI Drug Discovery ETF only) Under normal market conditions, the Fund invests at least 80% of
its net assets (plus borrowings for investment purposes) in equity securities of AI Drug Discovery Companies.
8.(Tuttle Capital AI Capacitor ETF only) Under normal market conditions, the Fund invests at least 80% of its net
assets (plus borrowings for investment purposes) in equity securities of AI Capacitor Companies.
9.(Tuttle Capital AI DC Power Architecture ETF only) Under normal market conditions, the Fund invests at least
80% of its net assets (plus borrowings for investment purposes) in equity securities of AI DC Power Architecture
Companies.
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        11
10.(Tuttle Capital Owned Intelligence ETF only) Under normal market conditions, the Fund invests at least 80% of
its net assets (plus the amount of any borrowings for investment purposes) in equity securities of Owned
Intelligence Companies.
11.(Tuttle Capital Space Data Centers ETF only) Under normal market conditions, the Fund invests at least 80%
of its net assets (plus borrowings for investment purposes) in equity securities of Space Data Center
Companies.
12.(Tuttle Capital Robotic Perception ETF only) Under normal market conditions, the Fund invests at least 80% of
its net assets (plus borrowings for investment purposes) in equity securities of Robotic Perception Companies.
13.(Tuttle Capital AI Substrate ETF only) Under normal market conditions, the Fund invests at least 80% of its net
assets (plus borrowings for investment purposes) in equity securities of AI Substrate Companies.
14.(Tuttle Capital AI Thermal Management ETF only) Under normal market conditions, the Fund invests at least
80% of its net assets (plus borrowings for investment purposes) in equity securities of AI Thermal Management
Companies.
In determining its compliance with the fundamental investment restriction on concentration, a Fund will consider the
investments of other investment companies in which such Fund invests to the extent it has sufficient information about
such investment companies. With respect to a Fund’s investments in affiliated investment companies, the Fund will
consider its entire investment in any investment company with a policy to concentrate, or having otherwise disclosed
that it is concentrated, in a particular industry or group of related industries as being invested in such industry or group
of related industries.
The following descriptions of certain provisions of the 1940 Act may assist investors in understanding the above policies
and restrictions:
Concentration. The SEC has defined concentration as investing more than 25% of a Fund’s net assets in an
industry or group of industries, with certain exceptions. Concentration is determined at the time each Fund
makes an investment. It is possible for the value of a Fund’s net assets invested in an industry in which it does
not have a policy to concentrate to exceed 25% due to factors other than an investment made by the Fund,
such as fluctuations in the market value of the Fund’s portfolio investments. During times when a Fund is
experiencing such a passive exceedance of the 25% limit, the Fund may continue to accept orders for the
purchase of Creation Units that include one or more investments in the relevant industry or cash-in-lieu of such
investments (and subsequent purchase of such investments with the cash-in-lieu amount) consistent with SEC
guidance and applicable law.
Borrowing. The 1940 Act presently allows a Fund to borrow from a bank (including pledging, mortgaging or
hypothecating assets) in an amount up to 33 1/3% of its total assets (not including temporary borrowings up to
5% of its total assets).
Senior Securities. Senior securities may include any obligation or instrument issued by a Fund evidencing
indebtedness. The 1940 Act generally prohibits a fund from issuing senior securities. An exemptive rule under
the 1940 Act, however, permits a fund to enter into transactions that might otherwise be deemed to be senior
securities, such as derivative transactions, reverse repurchase agreements and similar financing transactions,
and short sales, subject to certain conditions.
Lending. Under the 1940 Act, a Fund may only make loans if expressly permitted by its investment policies.
The Funds’ current investment policy on lending is that a Fund may not make loans if, as a result, more than 33
1/3% of its total assets would be lent to other parties, except that a Fund may: (i) purchase or hold debt
instruments in accordance with its investment objective and policies; (ii) enter into repurchase agreements; and
(iii) engage in securities lending as described in this SAI.
Real Estate and Commodities. The 1940 Act does not directly restrict a Fund’s ability to invest in real estate
or commodities, but the 1940 Act requires every investment company to have a fundamental investment policy
governing such investments.
Underwriting. Under the 1940 Act, underwriting securities involves the Funds purchasing securities directly
from an issuer for the purpose of selling (distributing) them or participating in any such activity either directly or
indirectly.
Percentage Limitations
If a percentage limitation is adhered to at the time of investment or contract, a later increase or decrease in percentage
resulting from any change in value or total or net assets will not result in a violation of such restriction, except that the
percentage limitations with respect to the borrowing of money and illiquid investments will be observed continuously.  If
the percentage of a Fund’s net assets invested in illiquid investments exceeds 15% due to market activity or changes in
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        12
the Fund’s portfolio, such Fund will take appropriate measures to reduce its holdings of illiquid investments in
accordance with the 1940 Act and such Fund's policies and procedures. 
For purposes of applying the limitation set forth in the concentration policy set forth above, the Fund may use the
Standard Industrial Classification (SIC) Codes, North American Industry Classification System (NAICS) Codes, MSCI
Global Industry Classification System, FTSE/Dow Jones Industry Classification Benchmark (ICB) system, or any other
reasonable industry classification system (including systems developed by the Adviser) to identify each industry.
Exchange Listing and Trading
A discussion of exchange listing and trading matters associated with an investment in the Funds are contained in the
summary section of the Prospectus and in the Prospectus section entitled “Buying and Selling Fund Shares.” The
discussion below supplements, and should be read in conjunction with, such sections of the Prospectus.
The shares of the Funds are approved for listing and trading on the Exchange. The shares trade on the Exchange at
prices that may differ to some degree from its NAV. There can be no assurance that the requirements of the Exchange
necessary to maintain the listing of shares of the Funds will continue to be met.
The Exchange may, but is not required to, remove the shares of a Fund from listing if: (1) following the initial twelve-
month period beginning upon the commencement of trading of the Fund, there are fewer than 50 beneficial holders of
the shares (2) the Fund is no longer eligible to operate in reliance on Rule 6c-11 under the 1940 Act; (3) the Fund fails
to meet certain continuing listing standards of the Exchange; or (4) such other event occurs or condition exists that, in
the opinion of the Exchange, makes further dealings on the Exchange inadvisable. In addition, the Exchange will
remove the shares of a Fund from listing and trading upon termination of the Trust or the Fund. The Trust reserves the
right to adjust the share price of the Funds in the future to maintain convenient trading ranges for investors. Any
adjustments would be accomplished through stock splits or reverse stock splits, which would have no effect on the net
assets of the Funds. 
As in the case of other publicly traded securities, brokers’ commissions on transactions will be based on negotiated
commission rates at customary levels.
The base and trading currency of the Funds is the U.S. dollar. The base currency is the currency in which each Fund's
NAV is calculated and the trading currency is the currency in which shares of the Funds are listed and traded on the
Exchange.
Management of the Funds
Board of Trustees
The management and affairs of the Funds are supervised by the Board. The Board consists of three individuals. The
Trustees are fiduciaries and are governed by the laws of the State of Delaware in this regard. The Board establishes
policies for the operation of the Funds and appoints the officers who conduct the daily business of the Funds.
The Role of the Board of Trustees
The Board provides oversight of the management and operations of the Trust. Like all registered investment companies,
the day-to-day responsibility for the management and operation of the Trust is the responsibility of various service
providers to the Trust and its individual series, such as the Adviser; Foreside Fund Services, LLC, the Funds’ principal
underwriter (the “Distributor”); U.S. Bancorp Fund Services, LLC, doing business as U.S. Bank Global Fund Services,
the Funds’ administrator (the “Administrator”) and transfer agent (the “Transfer Agent”); and U.S. Bank, N.A., the Funds’
Custodian, each of whom are discussed in greater detail in this SAI. The Board approves all significant agreements
between the Trust and its service providers, including the agreements with the Adviser, Distributor, Administrator,
Custodian and Transfer Agent. The Board has appointed various individuals of certain of these service providers as
officers of the Trust, with responsibility to monitor and report to the Board on the Trust’s day-to-day operations. In
conducting this oversight, the Board receives regular reports from these officers and service providers regarding the
Trust’s operations. The Board has appointed a Chief Compliance Officer (“CCO”) who reports directly to the Board and
who administers the Trust’s compliance program and regularly reports to the Board as to compliance matters, including
an annual compliance review. Some of these reports are provided as part of formal Board Meetings, which are held four
times per year, in person, and such other times as the Board determines is necessary, and involve the Board’s review of
recent Trust operations. From time to time one or more members of the Board may also meet with Trust officers in less
formal settings, between formal Board Meetings, to discuss various topics. In all cases, however, the role of the Board
and of any individual Trustee is one of oversight and not of management of the day-to-day affairs of the Trust, and its
oversight role does not make the Board a guarantor of the Trust’s investments, operations, or activities.
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        13
Board Leadership Structure
The Board has structured itself in a manner that it believes allows it to effectively perform its oversight function. The
Board is comprised of three Trustees that are not considered to be “interested persons” of the Funds, as defined by the
1940 Act (“Independent Trustees”) – Messrs. David A. Massart, David M. Swanson and Robert J. Kern. Accordingly,
100% of the members of the Board are Independent Trustees, who are Trustees that are not affiliated with the
investment adviser to the Funds, or their affiliates or other service providers to the Funds. Prior to July 6, 2020, Mr. Kern
was considered an “interested person” of the Trust as defined in the 1940 Act (“Interested Trustee”). He was considered
an Interested Trustee by virtue of the fact that he had served as a board member of Quasar Distributors, LLC, which
acts as principal underwriter to many of the Trust’s underlying funds and had been an Executive Vice President of the
Administrator. The Board has established two standing committees, an Audit Committee and a Nominating &
Governance Committee. The Committees are discussed in greater detail under “Board Committees” below. Each of the
Audit Committee and the Nominating & Governance Committee are comprised entirely of Independent Trustees. The
Independent Trustees have engaged independent counsel to advise them on matters relating to their responsibilities in
connection with the Trust, as well as the Funds.
The Independent Trustees have appointed David A. Massart as Chairman. Mr. Massart also serves as lead Independent
Trustee with responsibilities to coordinate activities of the Independent Trustees, act as a liaison with the Trust’s service
providers, officers, legal counsel, and other Trustees between meetings, help to set Board meeting agendas, and serve
as chair during executive sessions of the Independent Trustees.
In accordance with the fund governance standards prescribed by the SEC under the 1940 Act, the Independent
Trustees on the Nominating & Governance Committee select and nominate all candidates for Independent Trustee
positions. Each Trustee was appointed to serve on the Board because of his experience, qualifications, attributes and
skills as set forth in the subsection “Trustee Qualifications” below.
The Board reviews its structure regularly in light of the characteristics and circumstances of the Trust, including: the
affiliated or unaffiliated nature of each investment adviser; the number of funds that comprise the Trust; the variety of
asset classes that those funds reflect; the net assets of the Trust; the committee structure of the Trust; and the
independent distribution arrangements of each of the Trust’s underlying funds.
The Board has determined that the inclusion of all Independent Trustees as members of the Audit Committee and the
Nominating & Governance Committee allows all such Trustees to participate in the full range of the Board’s oversight
duties, including oversight of risk management processes discussed below.  Given the composition of the Board and the
function and composition of its various committees as described above, the Trust has determined that the Board’s
leadership structure is appropriate.
Board Oversight of Risk Management
As part of its oversight function, the Board receives and reviews various risk management reports and assessments and
discusses these matters with appropriate management and other personnel, including personnel of the Trust’s service
providers. Because risk management is a broad concept comprised of many elements (such as, for example,
investment risk, issuer and counter-party risk, compliance risk, operational risk, business continuity risk, etc.) the
oversight of different types of risks is handled in different ways. For example, the CCO regularly reports to the Board
during Board Meetings and meets in executive session with the Independent Trustees and their legal counsel to discuss
compliance and operational risks. In addition, the Trustees meet with the President, Treasurer and the Funds’
independent registered public accounting firm to discuss, among other things, the internal control structure of the Funds’
financial reporting function. The full Board receives reports from the investment advisers to the underlying funds and the
portfolio manager as to investment risks.
Trustees and Officers
The Trustees and officers of the Trust are listed below with their addresses, present positions with the Trust and
principal occupations over at least the last five years.
Name, Address and
Year of Birth
Position(s)
Held with
the Trust
Term of
Office and
Length of
Time
Served
Number of
Portfolios in
Trust
Overseen by
Trustee
Principal
Occupation(s)
During the Past Five
Years
Other
Directorships
Held by Trustee
During the Past
Five Years
Independent Trustees
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        14
Name, Address and
Year of Birth
Position(s)
Held with
the Trust
Term of
Office and
Length of
Time
Served
Number of
Portfolios in
Trust
Overseen by
Trustee
Principal
Occupation(s)
During the Past Five
Years
Other
Directorships
Held by Trustee
During the Past
Five Years
David A. Massart
615 E. Michigan St.
Milwaukee, WI 53202
Year of Birth: 1967
Trustee and
Chairman
Indefinite
Term; Since
April 2011
36
Partner and
Managing Director,
Beacon Pointe
Advisors, LLC (since
2022); Co-Founder
and Chief Investment
Strategist, Next
Generation Wealth
Management, Inc.
(2005-2021).
Independent
Trustee, ETF
Series Solutions
(71 Portfolios)
(2012-present).
David M. Swanson
615 E. Michigan St.
Milwaukee, WI 53202
Year of Birth: 1957
Trustee and
Nominating &
Governance
Committee
Chairman
Indefinite
Term; Since
April 2011
36
Founder and
Managing Principal,
SwanDog Strategic
Marketing, LLC
(2006-present).
Independent Trustee, RiverNorth
Funds (3 Portfolios) (2018-
present); RiverNorth Managed
Duration Municipal Income Fund,
Inc. (1 Portfolio) (2019-present);
RiverNorth Opportunistic Municipal
Income Fund, Inc. (1 Portfolio)
(2018-present); RiverNorth Capital
and Income Fund (1 Portfolio)
(2018-present); RiverNorth
Opportunities Fund, Inc. (1
Portfolio) (2015-present);
RiverNorth/DoubleLine Strategic
Opportunity Fund, Inc. (1 Portfolio)
(2019-present); RiverNorth
Flexible Municipal Income Fund,
Inc. (1 Portfolio) (2020-present);
RiverNorth Flexible Municipal
Income Fund II, Inc. (1 Portfolio)
(2021-present); RiverNorth
Managed Duration Municipal
Income Fund II, Inc. (1 Portfolio)
(2022-present); Independent
Trustee, ALPS Variable Investment
Trust (7 Portfolios) (2006 to 2025).
Robert J. Kern
615 E. Michigan St.
Milwaukee, WI 53202
Year of Birth: 1958
Trustee and
Audit
Committee
Chairman
Indefinite
Term; Since
January 2011
36
Retired (2018-
Present); Executive
Vice President, U.S.
Bancorp Fund
Services, LLC
(1994-2018).
None
Officers
Brian R. Wiedmeyer
615 E. Michigan St.
Milwaukee, WI 53202
Year of Birth: 1973
President
and Principal
Executive
Officer
Indefinite
Term; Since
November
2018
N/A
Vice President, U.S.
Bancorp Fund
Services, LLC (2005-
present).
N/A
Deborah Ward
615 E. Michigan St.
Milwaukee, WI 53202
Year of Birth: 1966
Vice
President,
Chief
Compliance
Officer and
Anti-Money
Laundering
Officer
Indefinite
Term; Since
April 2013
N/A
Senior Vice
President, U.S.
Bancorp Fund
Services, LLC (2004-
present).
N/A
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        15
Name, Address and
Year of Birth
Position(s)
Held with
the Trust
Term of
Office and
Length of
Time
Served
Number of
Portfolios in
Trust
Overseen by
Trustee
Principal
Occupation(s)
During the Past Five
Years
Other
Directorships
Held by Trustee
During the Past
Five Years
Aaron G. Johanson
615 E. Michigan St.
Milwaukee, WI 53202
Year of Birth: 1977
Treasurer,
Principal
Financial
Officer and
Vice
President
Indefinite
Term: Since
June 2026
(Treasurer
and Principal
Financial
Officer);
Indefinite
Term: Since
October 2025
(Vice
President)
N/A
Assistant Vice
President, U.S.
Bancorp Fund
Services, LLC (2013-
present).
N/A
Jason M. Venner
615 E Michigan St.
Milwaukee, WI 53202
Year of Birth: 1972
Secretary
Indefinite
Term: Since
November
2024
N/A
Vice President, U.S.
Bancorp Fund
Services, LLC (2024-
present); Managing
Director & Associate
General Counsel,
Charles Schwab &
Co, Inc. (2017-2024).
N/A
Benjamin Eirich
615 E. Michigan St.
Milwaukee, WI 53202
Year of Birth: 1981
Assistant
Treasurer
and Vice
President
Indefinite
Term; Since
June 2026
(Assistant
Treasurer);
Indefinite
Term; Since
November
2018 (Vice
President)
N/A
Vice President, U.S.
Bancorp Fund
Services, LLC (2008-
present).
N/A
Eli Bilderback
615 E. Michigan St.
Milwaukee, WI 53202
Year of Birth: 1991
Assistant
Treasurer
and Vice
President
Indefinite
Term; Since
March 2024
N/A
Officer, U.S. Bancorp
Fund Services, LLC
(2022 -present);
Operations Analyst,
U.S. Bank N.A. 
(2018 -2022).
N/A
Nasir Saiyed
615 E. Michigan St.
Milwaukee, WI 53202
Year of Birth: 2000
Assistant
Treasurer
and Vice
President
Indefinite
Term; Since
February
2025
N/A
Officer, U.S. Bancorp
Fund Services, LLC
(2025 - present);
Fund Administrator,
U.S. Bancorp Fund
Services, LLC.
(2023-2025).
N/A
Trustee Qualifications
The Board believes that each of the Trustees has the qualifications, experience, attributes and skills appropriate to their
continued service as Trustees of the Trust in light of the Trust’s business and structure. The Trustees have substantial
business and professional backgrounds that indicate they have the ability to critically review, evaluate and assess
information provided to them. Certain of these business and professional experiences are set forth in detail in the table
above. In addition, the Trustees have substantial board experience and, in their service to the Trust, have gained
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        16
substantial insight as to the operation of the Trust. The Board annually conducts a “self-assessment” wherein the
effectiveness of the Board and the individual Trustees is reviewed.
In addition to the information provided in the table above, below is certain additional information concerning each
individual Trustee. The information provided below, and in the table above, is not all-inclusive. Many of the Trustees’
qualifications to serve on the Board involve intangible elements, such as intelligence, integrity, work ethic, the ability to
work together, the ability to communicate effectively, the ability to exercise judgment, the ability to ask incisive
questions, and commitment to shareholder interests.
Mr. Kern’s trustee attributes include substantial industry experience, including over 35 years of service with U.S.
Bancorp Fund Services, LLC (the fund accountant (“Fund Accountant”), Administrator, and Transfer Agent to the Trust)
where he managed business development and the mutual fund transfer agent operation including investor services,
account services, legal compliance, document processing and systems support. He also served as a board member of
U.S. Bancorp Fund Services, LLC and previously served as a board member of Quasar Distributors, LLC (the principal
underwriter of many of the Trust’s series). The Board believes Mr. Kern’s experience, qualifications, attributes and skills
on an individual basis and in combination with those of the other Trustees lead to the conclusion that he possesses the
requisite skills and attributes as a Trustee to carry out oversight responsibilities with respect to the Trust.
Mr. Massart’s trustee attributes include substantial industry experience, including over two decades working with high
net worth individuals, families, trusts and retirement accounts to make strategic and tactical asset allocation decisions,
evaluate and select investment managers and manage client relationships. He is currently the Partner and Managing
Director of Beacon Pointe Advisors, LLC. Previously, he served as Chief Investment Strategist and lead member of the
investment management committee of the SEC registered investment advisory firm he co-founded. He also previously
served as Managing Director of Strong Private Client and as a Manager of Wells Fargo Investments, LLC. The Board
believes Mr. Massart’s experience, qualifications, attributes and skills on an individual basis and in combination with
those of the other Trustees lead to the conclusion that he possesses the requisite skills and attributes as a Trustee to
carry out oversight responsibilities with respect to the Trust.
Mr. Swanson’s trustee attributes include substantial industry experience, including over 35 years of senior management
and marketing experience with over 30 years dedicated to the financial services industry. He is currently the Founder
and Managing Principal of a marketing strategy boutique serving asset and wealth management businesses. He has
also served as Chief Operating Officer and Chief Marketing Officer of Van Kampen Investments, President and Chief
Executive Officer of Scudder, Stevens & Clark, Canada, Ltd., Managing Director and Head of Global Investment
Products at Morgan Stanley, Director of Marketing for Morgan Stanley Mutual Funds, Director of Marketing for Kemper
Funds, and Executive Vice President and Head of Distribution for Calamos Investments. The Board believes Mr.
Swanson’s experience, qualifications, attributes and skills on an individual basis and in combination with those of the
other Trustees lead to the conclusion that he possesses the requisite skills and attributes as a Trustee to carry out
oversight responsibilities with respect to the Trust.
This discussion of the Trustees’ experience and qualifications is pursuant to SEC requirements, does not constitute
holding out the Board or any Trustee as having special expertise, and shall not impose any greater responsibility or
liability on any such Trustee or the Board by reason thereof.
Trustee and Management Ownership of Fund Shares
The Funds have not commenced operations as of the date of this SAI and consequently, none of the Trustees or
Officers of the Trust owned shares of the Funds as of such date.
Board Committees
Audit Committee. The Trust has an Audit Committee, which is comprised of all the Independent Trustees. The Audit
Committee reviews financial statements and other audit-related matters for the Funds. The Audit Committee also holds
discussions with management and with the Funds’ independent registered public accounting firm concerning the scope
of the audit and the auditor’s independence.
Nominating & Governance Committee. The Trust has a Nominating & Governance Committee, which is comprised of all
the Independent Trustees. The Nominating & Governance Committee is responsible for seeking and reviewing
candidates for consideration as nominees for the position of trustee and meets only as necessary.
The Nominating & Governance Committee will consider nominees recommended by shareholders for vacancies on the
Board. Recommendations for consideration by the Nominating & Governance Committee should be sent to the
President of the Trust in writing together with the appropriate biographical information concerning each such proposed
nominee, and such recommendation must comply with the notice provisions set forth in the Trust’s Bylaws. In general,
to comply with such procedures, such nominations, together with all required information, must be delivered to and
received by the President of the Trust at the principal executive office of the Trust not fewer than 120 days, and no more
than 150 days, prior to the shareholder meeting at which any such nominee would be voted on. Shareholder
recommendations for nominations to the Board will be accepted on an ongoing basis. The Nominating & Governance
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        17
Committee’s procedures with respect to reviewing shareholder nominations will be disclosed as required by applicable
securities laws.
Board Consultant
Effective July 4, 2026, the Board engaged Kristina Nelson as a consultant to the Board with respect to its oversight of
the Trust. In this role, Ms. Nelson attends all meetings of the Board and provides advice with respect to investment
company operations and the investment management business as well as any other guidance that the Board may
request from time to time. In exchange for her services, Ms. Nelson receives a retainer, paid quarterly, from the Trust.
Ms. Nelson most recently was employed, since May 2010, by U.S. Bancorp Fund Services LLC (Fund Services), the
administrator to the Trust and its series and various other investment companies. In addition to her service as consultant
to the Board, the Board has appointed Ms. Nelson to the Board as a trustee. That appointment is expected to become
effective in early January 2027. Ms. Nelson’s consultant role will end when her appointment as trustee takes effect.
Trustee Compensation
The Trustees each receive an annual retainer of $98,000. The Chairman of the Audit Committee receives additional
compensation of $18,000, the Chairman of the Nominating & Governance Committee receives additional compensation
of $8,000 and the Chairman of the Board receives $12,500, each annually. The Trustees each receive $8,000 for
regularly scheduled meetings and $2,500 for additional meetings.
In addition, since July 2026, Kristina Nelson has served as a Board consultant and receives a quarterly retainer of
$18,357 and a per meeting fee of $6,000. Ms. Nelson’s estimated compensation for an annual period is $103,500. Ms.
Nelson’s appointment as Trustee is expected to become effective in early January 2027, at which time, Ms. Nelson’s
consultant role will terminate and she will be paid in the same manner as the other Independent Trustees.
The following table sets forth the estimated compensation to be received by the Trustees for the Funds’ initial fiscal
period ended August 31, 2027, with such amounts paid by the Adviser from its management fee.
Name of Person/
Position
Estimated Aggregate
Compensation from
the Fund(1)(2)
Pension or Retirement
Benefits Accrued as
Part of Fund
Expenses
Estimated Annual
Benefits Upon
Retirement
Estimated Total
Compensation from
the Funds and the
Trust(2) Paid to
Trustees
David A. Massart(3)
$3,191
None
None
$114,875
David M. Swanson(4)
$3,097
None
None
$111,500
Robert J. Kern(5)
$3,306
None
None
$119,000
(1)The Trustee was paid this amount for each Fund in this SAI.
(2)Trustee fees and expenses are allocated among the Funds and any other series comprising the Trust.
(3)The Trust includes other portfolios in addition to the Funds.
(4)Independent Trustee and Chairman
(5)Independent Trustee and Nominating & Governance Committee Chairman
(6)Independent Trustee and Audit Committee Chairman
Control Persons and Principal Shareholders
A principal shareholder is any person who owns of record or beneficially 5% or more of the outstanding shares of a
Fund. A control person is one who owns beneficially or through controlled companies more than 25% of the voting
securities of a Fund or acknowledges the existence of control. A controlling person possesses the ability to control the
outcome of matters submitted for shareholder vote by a Fund. As of the date of this SAI, there were no principal
shareholders or control persons.
Investment Adviser
Investment Adviser
Investment advisory services are provided to the Funds by the Adviser, Tuttle Capital Management, LLC, 155 Lockwood
Rd., Riverside, Connecticut 06878 pursuant to an investment advisory agreement (the “Advisory Agreement”).
Pursuant to the Advisory Agreement, the Adviser provides the Funds with investment research and advice and furnishes
the Funds with an investment program consistent with each Fund’s investment objective and policies, subject to the
supervision of the Board. The Adviser determines which portfolio securities will be purchased or sold, arranges for the
placing of orders for the purchase or sale of portfolio securities, selects brokers or dealers to place those orders,
maintains books and records with respect to the securities transactions and reports to the Board on each Fund’s
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        18
investments and performance. The Adviser is solely responsible for making investment decisions on behalf of each
Fund, under the Advisory Agreement. The Board will have sole responsibility for selecting, evaluating the performance
of, and replacing as necessary any of the service providers to the Funds, including the Adviser.
After an initial two-year period, the Advisory Agreement will continue in effect from year to year, only if such continuance
is specifically approved at least annually by: (i) the Board or the vote of a majority of the outstanding voting securities of
the Funds; and (ii) the vote of a majority of the Independent Trustees, cast in person at a meeting called for the purpose
of voting on such approval. The Advisory Agreement is terminable without penalty by the Trust, on behalf of a Fund,
upon 60 days’ written notice to the Adviser, when authorized by either: (i) a majority vote of a Fund’s shareholders; or (ii)
by a vote of a majority of the Board or by the Adviser upon 60 days’ written notice to the Trust. The Advisory Agreement
will automatically terminate in the event of its “assignment,” as defined under the 1940 Act. The Advisory Agreement
provides that the Adviser under such agreement shall not be liable for any error of judgment or mistake of law or for any
loss arising out of any investment or for any act or omission in the execution of portfolio transactions for the Funds,
except for willful misfeasance, bad faith or negligence in the performance of its duties, or by reason of reckless
disregard of its obligations and duties thereunder.
In consideration of the services provided by the Adviser pursuant to the Advisory Agreement, the Adviser is entitled to
receive from the Funds a management fee computed daily and paid monthly, based on a percentage of each Fund’s
average annual net assets, as specified in the Prospectus. Under the Investment Advisory Agreement, the Adviser has
agreed to pay all expenses incurred by the Funds except for: (i) brokerage expenses and other fees, charges, taxes,
levies or expenses (such as stamp taxes) incurred in connection with the execution of portfolio transactions or in
connection with creation and redemption transactions (including without limitation any fees, charges, taxes, levies or
expenses related to the purchase or sale of an amount of any currency, or the patriation or repatriation of any security or
other asset, related to the execution of portfolio transactions or any creation or redemption transactions); (ii) fees or
expenses in connection with any arbitration, litigation or pending or threatened arbitration or litigation, including any
settlements in connection therewith; (iii) extraordinary expenses (in each case as determined by a majority of the
independent trustees); (iv) distribution fees and expenses paid by the Funds under any distribution plan adopted
pursuant to Rule 12b-1 under the 1940 Act; (v) interest and taxes of any kind or nature (including, but not limited to,
income, excise, transfer and withholding taxes); (vi) any fees and expenses related to the provision of securities lending
services; (vii) the advisory fee payable to the Adviser; and (viii) all costs incurred in connection with shareholder
meetings and all proxy solicitations (except for such shareholder meetings and proxy solicitations related to: (a)
changes to the Investment Advisory Agreement, (b) changes in control at the Adviser, (c) the election of any Board
member who is an “interested person” of the Adviser (as that term is defined under Section 2(a)(19) of the 1940 Act), (d)
matters initiated by the Adviser, or (e) any other matters that directly benefit the Adviser). The internal expenses of
pooled investment vehicles in which the Funds may invest (acquired fund fees and expenses) are not expenses of the
Funds and are not paid by the Adviser.
Each Fund is new and has not paid fees to the Adviser pursuant to the Advisory Agreement as of the date of this SAI.
Portfolio Managers
As disclosed in the Prospectus, Matthew Tuttle, Chief Investment Officer of the Adviser, is the portfolio manager for
each Fund (“Portfolio Manager”).
The following table provides information regarding other accounts, excluding the Funds, managed by the Portfolio
Manager as of September 15, 2026:
Portfolio Manager
Account Category
Number of
Accounts
Total Assets
in the
Accounts (in
billions)
# of Accounts
Paying a
Performance
Fee
Total Assets of
Accounts
Paying a
Performance
Fee
Matthew Tuttle
Registered investment
companies
78
$5.28
0
$0
Other pooled
investment vehicles
0
$0
0
$0
Other Accounts
0
$0
0
$0
The Portfolio Manager’s management of “other accounts” may give rise to conflicts of interest in connection with the
management of the Funds’ investments, on the one hand, and the investments of the other accounts, on the other. The
other accounts may have the same investment objective as the Funds. Therefore, a potential conflict of interest may
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        19
arise as a result of the identical investment objectives, whereby the Portfolio Manager could favor one account over
another. Another potential conflict could include a Portfolio Manager’s knowledge about the size, timing and possible
market impact of Fund trades, whereby a Portfolio Manager could use this information to the advantage of other
accounts and to the disadvantage of the Funds. However, the Adviser has established policies and procedures to
ensure that the purchase and sale of securities among all accounts it manages are fairly and equitably allocated.
Compensation
The Portfolio Manager will receive a blend of fixed salary, discretionary bonus, and distributions from the Adviser to the
extent a portfolio manager has equity ownership in the Adviser. The Portfolio Manager’s compensation is not directly
based on the performance or assets of the Fund. Each Portfolio Manager is also entitled to participate in the Adviser’s
401(k) retirement plan which is offered to all employees of the Adviser.
As of the date of this SAI, the portfolio manager of the Funds did not beneficially own any shares of the Funds.
Service Providers
U.S. Bancorp Fund Services, LLC, doing business as U.S. Bank Global Fund Services (“Fund Services”), located at
615 East Michigan Street, Milwaukee, Wisconsin, 53202, serves as the Administrator, Fund Accountant and Transfer
Agent for the Funds.
Pursuant to the Fund Servicing Agreement between the Trust and Fund Services, Fund Services provides certain
administrative services to the Funds including, among other responsibilities, portfolio accounting services, tax
accounting services and furnishing financial reports, coordinating the negotiation of contracts and fees with, and the
monitoring of performance and billing of, the Funds’ independent contractors and agents; preparation for signature by
an officer of the Trust of all documents required to be filed for compliance by the Trust and the Funds with applicable
laws and regulations; arranging for the computation of performance data, including NAV per share and yield; responding
to shareholder inquiries; arranging for the maintenance of books and records of the Funds; and providing, at its own
expense, office facilities, equipment and personnel necessary to carry out its duties. In this capacity, Fund Services
does not have any responsibility or authority for the investment management of the Funds. the determination of
investment policy, or for any matter pertaining to the distribution of Fund shares. As compensation for its services, the
Adviser pays Fund Services a fee based on each Funds’ average daily net assets, subject to an annual minimum fee.
Each Fund is new and the Adviser has not paid any administration fees to Fund Services with respect to each Fund as
of the date of this SAI.
Pursuant to a custody agreement between the Trust and the Funds, U.S. Bank N.A., an affiliate of Fund Services,
serves as the custodian of the Funds’ assets (the “Custodian”). Pursuant to the custody agreement, the Custodian
receives an annual fee from the Adviser based on the Funds’ total average daily net assets, subject to a minimum
annual fee, and certain settlement charges. The Custodian also is entitled to certain out-of-pocket expenses. The
Custodian’s address is 1555 North RiverCenter Drive, Suite 302, Milwaukee, Wisconsin, 53212. The Custodian does
not participate in decisions relating to the purchase and sale of securities by the Funds. U.S. Bank and its affiliates may
participate in revenue sharing arrangements with service providers of mutual funds in which the Funds may invest.
Legal Counsel
Morgan, Lewis & Bockius, LLP, 1111 Pennsylvania Avenue, NW, Washington, D.C. 20004, serves as counsel to the
Trust and as independent legal counsel to the Board.
Independent Registered Public Accounting Firm
Cohen & Company, Ltd., 875 E Wisconsin Ave, Suite 210, Milwaukee, Wisconsin 53202, serves as the independent
registered public accounting firm for the Funds. Its services include auditing each Fund’s financial statements. Cohen &
Co Advisory, LLC, an affiliate of Cohen & Company, Ltd., provides tax services as requested.
Distribution of Fund Shares
The Trust has entered into a distribution agreement (the “Distribution Agreement”) with Foreside Fund Services, LLC, a
wholly owned subsidiary of Foreside Financial Group, LLC (dba ACA Group), 190 Middle Street, Suite 301, Portland,
Maine 04101 pursuant to which the Distributor acts as the Funds’ principal underwriter and distributes shares. Shares
are continuously offered for sale by the Distributor only in Creation Units. The Distributor will not distribute shares in
amounts less than a Creation Unit.
Under the Distribution Agreement, the Distributor, as agent for the Trust, will receive orders for the purchase and
redemption of Creation Units, provided that any subscriptions and orders will not be binding on the Trust until accepted
by the Trust. The Distributor will deliver prospectuses and, upon request, Statements of Additional Information to
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        20
persons purchasing Creation Units and will maintain records of orders placed with it. The Distributor is a broker-dealer
registered under the Securities Exchange Act of 1934, as amended (the “Exchange Act”) and a member of the Financial
Industry Regulatory Authority (“FINRA”).
The Distributor may also enter into agreements with securities dealers (“Soliciting Dealers”) who will solicit purchases of
Creation Units of shares. Such Soliciting Dealers may also be Authorized Participants (as discussed in “Purchase and
Issuance of Shares in Creation Units” below) or DTC Participants (as defined below).
The Distribution Agreement has an initial term of two years and will continue in effect only if such continuance is
specifically approved at least annually by the Board of Trustees or by vote of a majority of the Funds’ outstanding voting
securities and, in either case, by a majority of the Independent Trustees. The Distribution Agreement is terminable
without penalty by the Trust, on behalf of the Funds, on 60 days’ written notice when authorized either by a majority vote
of a Fund’s shareholders or by vote of a majority of the Board of Trustees, including a majority of the Trustees who are
not “interested persons” (as defined under the 1940 Act) of the Trust, or by the Distributor on 60 days’ written notice, and
will automatically terminate in the event of its “assignment,” as defined in the 1940 Act.
Distribution (Rule 12b-1) Plan
The Trust has adopted a Distribution Plan (the “Plan”) in accordance with the provisions of Rule 12b-1 under the 1940
Act, which regulates circumstances under which an investment company may directly or indirectly bear expenses
relating to the distribution of its shares. The Funds do not presently intend to make any payments pursuant to the Plan.
Continuance of the Plan with respect to the Funds must be approved annually by a majority of the Trustees of the Trust
and by a majority of the Trustees who are not interested persons (as defined in the 1940 Act) of the Trust and have no
direct or indirect financial interest in the Plan or in any agreements related to the Plan (“Qualified Trustees”). The Plan
requires that quarterly written reports of amounts spent under the Plan and the purposes of such expenditures be
furnished to and reviewed by the Trustees. The Plan may not be amended to increase materially the amount that may
be spent thereunder with respect to the Funds without approval by a majority of the outstanding shares of any class of a
Fund that is affected by such increase. All material amendments of the Plan will require approval by a majority of the
Trustees of the Trust and of the Qualified Trustees.
Under the Plan, the Distributor may make payments pursuant to written agreements to financial institutions and
intermediaries such as banks, savings and loan associations and insurance companies including, without limit,
investment counselors, broker-dealers and the Distributor’s affiliates and subsidiaries (collectively, “Agents”) as
compensation for services and reimbursement of expenses incurred in connection with distribution assistance. The Plan
is characterized as a compensation plan since the distribution fee will be paid to the Distributor without regard to the
distribution expenses incurred by the Distributor or the amount of payments made to other financial institutions and
intermediaries. The Trust intends to operate the Plan in accordance with its terms and with FINRA rules concerning
sales charges.
Under the Plan, subject to the limitations of applicable law and regulations, the Funds are authorized to compensate the
Distributor up to the maximum amount to finance any activity primarily intended to result in the sale of Creation Units of
the Funds or for providing or arranging for others to provide shareholder services and for the maintenance of
shareholder accounts. Such activities may include, but are not limited to: (i) delivering copies of the Funds’ then current
reports, prospectuses, notices, and similar materials, to prospective purchasers of Creation Units; (ii) marketing and
promotional services, including advertising; (iii) paying the costs of and compensating others, including Authorized
Participants with whom the Distributor has entered into written Authorized Participant Agreements, for performing
shareholder servicing on behalf of the Funds; (iv) compensating certain Authorized Participants for providing assistance
in distributing the Creation Units of the Funds, including the travel and communication expenses and salaries and/or
commissions of sales personnel in connection with the distribution of the Creation Units of the Funds; (v) payments to
financial institutions and intermediaries such as banks, savings and loan associations, insurance companies and
investment counselors, broker-dealers, mutual fund supermarkets and the affiliates and subsidiaries of the Trust’s
service providers as compensation for services or reimbursement of expenses incurred in connection with distribution
assistance; (vi) facilitating communications with beneficial owners of shares, including the cost of providing (or paying
others to provide) services to beneficial owners of shares, including, but not limited to, assistance in answering inquiries
related to shareholder accounts, and (vi) such other services and obligations as are set forth in the Distribution
Agreement.
Marketing Support Payments
The Adviser, out of its own profits and resources and without additional cost to the Funds or their shareholders, may
provide cash payments or other compensation (“Support Payments”) to certain financial intermediaries who sell and/or
promote the sale of shares of the Funds. Subject to and in accordance with the terms of the Funds’ prospectus, the
Adviser may make Support Payments to such financial intermediaries related to marketing/distribution support,
education training or support, shareholder servicing, sales meetings, inclusion on sales lists (including a preferred or
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        21
select sales list), participation in sales programs, and for making shares of the Funds available to the intermediaries’
customers generally and in investment programs.
Support Payments made by the Adviser to intermediaries may be calculated in different ways, including: (1) as a
percentage of net sales; (2) as a percentage of net assets; (3) as a flat fee; and, (4) in the case of payments to an
affiliated broker-dealer, as a percentage of the expected annualized revenue to be received by the Adviser on new
assets invested in the Funds as a result of the services provided by the affiliated broker-dealer with an offset for
qualifying redemptions from the Funds.
The possibility of receiving, or the receipt of, such Support Payments as described above may provide such
intermediaries and/or their salespersons with an incentive to favor sales of shares of the Funds, and other funds whose
affiliates make similar compensation available, over other investments that do not make such payments. Investors may
wish to take such payment arrangements into account when considering and evaluating any recommendations relating
to the Funds and other ETFs.
Portfolio Transactions and Brokerage
The Adviser determines which securities are to be purchased and sold by the Funds and which broker-dealers are
eligible to execute the Funds’ portfolio transactions. Purchases and sales of securities on an exchange are effected
through brokers that charge a commission while purchases and sales of securities in the OTC market will generally be
executed directly with the primary “market-maker” unless, in the opinion of the Adviser, a better price and execution can
otherwise be obtained by using a broker for the transaction. Purchases and sales of portfolio securities that are fixed
income securities (for instance, money market instruments and bonds, notes and bills) usually are principal
transactions. In a principal transaction, the party from whom the Funds purchase or to whom the Funds sell is acting on
its own behalf (and not as the agent of some other party, such as its customers). These securities normally are
purchased directly from the issuer or from an underwriter or market maker for the securities. The price of securities
purchased from underwriters includes a disclosed fixed commission or concession paid by the issuer to the underwriter,
and prices of securities purchased from dealers serving as market makers reflects the spread between the bid and
asked price. The price of OTC securities usually includes an undisclosed commission or markup.
Purchases of portfolio securities for the Funds will be effected through broker-dealers (including banks) that specialize
in the types of securities that the Funds will be holding, unless better executions are available elsewhere. Dealers
usually act as principal for their own accounts. Purchases from dealers will include a spread between the bid and the
asked price. If the execution and price offered by more than one dealer are comparable, the order may be allocated to a
dealer that has provided research or other services as discussed below.
In placing portfolio transactions, the Adviser will use reasonable efforts to choose broker-dealers capable of providing
the services necessary to obtain the most favorable price and execution available. The full range and quality of services,
such as the size of the order, the difficulty of execution, the operational facilities of the firm involved, the firm’s risk in
positioning a block of securities, and other factors available, will be considered in making these determinations. In those
instances where it is reasonably determined that more than one broker-dealer can offer the services needed to obtain
the most favorable price and execution available, consideration may be given to those broker-dealers that furnish or
supply research and statistical information to the Adviser that it may lawfully and appropriately use in its investment
advisory capacities, as well as provide other brokerage services incidental to execution services. Research and
statistical information may include reports that are common in the industry such as industry research reports and
periodicals, quotation systems, software for portfolio management and formal databases. Typically, the research will be
used to service all of the Adviser’s accounts, although a particular client may not benefit from all the research received
on each occasion. The Adviser considers research information, which is in addition to and not in lieu of the services
required to be performed by it under its Advisory Agreement with the Funds, to be useful in varying degrees, but of
indeterminable value.
While it is the Adviser’s general policy to first seek to obtain the most favorable price and execution available in
selecting a broker-dealer to execute portfolio transactions for the Funds, weight may also be given to the ability of a
broker-dealer to furnish brokerage and research services to the Funds or to the Adviser, even if the specific services are
not directly useful to the Funds and may be useful to the Adviser in advising other clients. In negotiating commissions
with a broker or evaluating the spread to be paid to a dealer, the Funds may therefore pay a higher commission or
spread than would be the case if no weight were given to the furnishing of these supplemental services, provided that
the amount of such commission or spread has been determined in good faith by the Adviser to be reasonable in relation
to the value of the brokerage and/or research services provided by such broker-dealer. The standard of reasonableness
is to be measured in light of the Adviser’s overall responsibilities to the Funds.
Investment decisions for the Funds are made independently from those of other client accounts of the Adviser and its
affiliates. Nevertheless, it is often the case that identical securities will be acceptable for both the Funds and one or
more of such other client accounts. In such event, the position of the Funds and such other client account(s) in the
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        22
same issuer may vary and the length of time that each may choose to hold its investment in the same issuer may
likewise vary. However, to the extent any of these client accounts seek to acquire the same security as the Funds at the
same time, the Funds may not be able to acquire as large a portion of such security as it desires, or it may have to pay
a higher price or obtain a lower yield for such security. Similarly, the Funds may not be able to obtain as high a price for,
or as large an execution of, an order to sell any particular security at the same time. If one or more of such client
accounts simultaneously purchases or sells the same security that the Funds are purchasing or selling, each day’s
transactions in such security will be allocated between the Funds and all such client accounts in a manner deemed
equitable by the Adviser, taking into account the respective sizes of the accounts and the amount being purchased or
sold. It is recognized that in some cases this system could have a detrimental effect on the price or value of the security
insofar as the Funds are concerned. In other cases, however, it is believed that the ability of the Funds to participate in
volume transactions may produce better executions for the Funds. Notwithstanding the above, the Adviser may execute
buy and sell orders for accounts and take action in performance of its duties with respect to any of its accounts that may
differ from actions taken with respect to another account, so long as the Adviser shall, to the extent practical, allocate
investment opportunities to accounts, including the Funds, over a period of time on a fair and equitable basis and in
accordance with applicable law.
Portfolio transactions may be placed with broker-dealers who sell shares of the Funds subject to rules adopted by
FINRA and the SEC. Portfolio transactions may also be placed with broker-dealers in which the Adviser has invested on
behalf of the Funds and/or client accounts.
Each Fund is new and has not paid brokerage commissions as of the date of this SAI.
Portfolio Turnover
A Fund may sell a portfolio investment soon after its acquisition if the Adviser believes that such a disposition is
consistent with attaining the investment objective of the Fund. The Funds’ investments may be sold for a variety of
reasons, such as a more favorable investment opportunity or other circumstances bearing on the desirability of
continuing to hold such investments. A high rate of portfolio turnover (over 100%) may involve correspondingly greater
transaction costs, which must be borne directly by the Funds and ultimately by their shareholders. High portfolio
turnover may result in the realization of substantial net capital gains. To the extent short-term capital gains are realized,
distributions attributable to such gains will be ordinary income for federal income tax purposes.
Each Fund is new and does not have portfolio turnover information to report as of the date of this SAI.
Code of Ethics
The Trust and the Adviser have each adopted Codes of Ethics under Rule 17j-1 of the 1940 Act. These codes permit,
subject to certain conditions, personnel of the Trust and Adviser to invest in securities that may be purchased or held by
the Funds.
Proxy Voting Procedures
The Board has adopted proxy voting policies and procedures (“Proxy Policies”) wherein the Trust has delegated to the
Adviser the responsibility for voting proxies relating to portfolio securities held by the Funds as part of the Adviser’s
investment advisory services, subject to the supervision and oversight of the Board. Notwithstanding this delegation of
responsibilities, however, the Funds retain the right to vote proxies relating to their portfolio securities. The fundamental
purpose of the Proxy Policies is to ensure that each vote will be in a manner that reflects the best interest of the Funds
and their shareholders, taking into account the value of the Funds’ investments.
The Adviser’s Proxy Voting Policies and Procedures
The guiding principle by which the Adviser votes on all matters submitted to security holders is the maximization of the
ultimate economic value of its clients’ holdings. The Adviser does not permit voting decisions to be influenced in any
manner that is contrary to, or dilutive of, the guiding principle set forth above. It is the Adviser’s policy to avoid situations
where there is any conflict of interest or perceived conflict of interest affecting voting decisions. Any conflicts of interest,
regardless of whether actual or perceived, will be addressed in accordance with these policies and procedures.
It is the general policy of Adviser to vote on all matters presented to security holders in any proxy, and these policies
and procedures have been designed with that in mind. However, the Adviser reserves the right to abstain on any
particular vote or otherwise withhold its vote on any matter if in the judgment of the Adviser, the costs associated with
voting such proxy outweigh the benefits to clients or if the circumstances make such an abstention or withholding
otherwise advisable and in the best interest of the clients, in the judgment of the Adviser. Each vote is cast on a case-
by-case basis, taking into consideration the Adviser’s contractual obligations to its clients and all other relevant facts and
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        23
circumstances at the time of the vote. The Adviser may vote proxies related to the same security differently for each
client.
For clients that have delegated to the Adviser the discretionary power to vote the securities held in their account, the
Adviser does not generally accept any subsequent directions on specific matters presented to security holders or
particular securities held in the account, regardless of whether such subsequent directions are from the client itself or a
third party. The Adviser views the delegation of discretionary voting authority as an absolute choice for its clients. The
Adviser’s clients shall be responsible for notifying their custodians of the name and address of the person or entity with
voting authority.
Where the Adviser acts as investment adviser to a closed-end and/or open-end registered investment company and is
responsible for voting their proxies, such proxies will be voted in accordance with any applicable investment restrictions
of a fund and, to the extent applicable, any proxy voting procedures or resolutions or other instructions approved by an
authorized person of a fund.
Absent any legal or regulatory requirement to the contrary, it is generally the policy of the Adviser to maintain the
confidentiality of the votes that it casts on behalf of its clients. Any registered investment companies managed by the
Adviser disclose the votes cast on their behalf in accordance with all legal and regulatory requirements. Any client of the
Adviser can obtain details of how the Adviser has voted the securities in its account by contacting the Adviser. The
Adviser does not, however, generally disclose the results of voting decisions to third parties.
The actual voting records relating to portfolio securities during the most recent 12-month period ended June 30 are
available without charge, upon request, by calling toll-free, 866-303-8623, or by accessing the SEC’s website at
www.sec.gov.
Anti-Money Laundering Compliance Program
The Trust has established an Anti-Money Laundering Compliance Program (the “Program”) as required by the Uniting
and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001
(“USA PATRIOT Act”). To ensure compliance with this law, the Trust’s Program provides for the development of internal
practices, procedures and controls, designation of anti-money laundering compliance officers, an ongoing training
program and an independent audit function to determine the effectiveness of the Program. Ms. Deborah Ward has been
designated as the Trust’s Anti-Money Laundering Compliance Officer.
Procedures to implement the Program include, but are not limited to: determining that the Distributor and the Transfer
Agent have established proper anti-money laundering procedures; reporting suspicious and/or fraudulent activity
checking shareholder names against designated government lists, including Office of Foreign Asset Control (“OFAC”),
and a complete and thorough review of all new opening account applications. The Funds will not transact business with
any person or legal entity whose identity and beneficial owners, if applicable, cannot be adequately verified under the
provisions of the USA PATRIOT Act.
As a result of the Program, the Funds may be required to “freeze” the account of a shareholder if the shareholder
appears to be involved in suspicious activity or if certain account information matches information on government lists of
known terrorists or other suspicious persons, or the Funds may be required to transfer the account or proceeds of the
account to a governmental agency.
Portfolio Holdings Information
The Board has adopted a policy regarding the disclosure of information about each Fund’s security holdings. Each
Fund’s entire portfolio holdings are publicly disseminated each day the Funds are open for business and through
financial reporting and news services including publicly available internet web sites. In addition, the composition of the
Deposit Securities is publicly disseminated daily prior to the opening of the Exchange via the National Securities
Clearing Corporation (“NSCC”).
Purchase and Issuance of Shares in Creation Units
The Trust issues and redeems shares of the Funds only in large blocks, known as “Creation Units,” which amount may
change from time to time. The Trust issues and sells shares of the Funds: (i) in Creation Units on a continuous basis
through the Funds’ distributor, without a sales load (but subject to transaction fees), at its NAV per share next
determined after receipt of an order, on any day the Funds’ primary listing exchange is open for business (“Business
Day”), in proper form pursuant to the terms of the Authorized Participant Agreement (“Participant Agreement”); or (ii)
pursuant to the dividend reinvestment service of The Depository Trust Company (“DTC”). The NAV of each Fund’s
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        24
shares is calculated each Business Day as of the close of regular trading on each Fund’s primary listing exchange,
generally 4:00 p.m., Eastern time. The Funds will not issue or redeem fractional Creation Units.
Fund Deposit
The consideration for purchase of a Creation Unit of the Funds generally consist of the Deposit Securities and the Cash
Component, computed as described below. Notwithstanding the foregoing, the Trust reserves the right to permit or
require the substitution of Deposit Cash to be added to the Cash Component to replace any Deposit Security. When
accepting purchases of Creation Units for all or a portion of Deposit Cash, the Funds may incur additional costs
associated with the acquisition of Deposit Securities that would otherwise be provided by an in-kind purchaser. These
additional costs associated with the acquisition of Deposit Securities (“Non-Standard Charges”) may be recoverable
from the purchaser of creation units. 
Together, the Deposit Securities or Deposit Cash, as applicable, and the Cash Component constitute the “Fund
Deposit,” which represents the minimum initial and subsequent investment amount for a Creation Unit of each Fund.
The “Cash Component” is an amount equal to the difference between the NAV of the shares (per Creation Unit) and the
market value of the Deposit Securities or Deposit Cash, as applicable. If the Cash Component is a positive number (i.e.,
the NAV per Creation Unit exceeds the market value of the Deposit Securities or Deposit Cash, as applicable), the Cash
Component will be such positive amount. If the Cash Component is a negative number (i.e., the NAV per Creation Unit
is less than the market value of the Deposit Securities or Deposit Cash, as applicable), the Cash Component shall be
such negative amount and the creator will be entitled to receive cash in an amount equal to the Cash Component. The
Cash Component serves the function of compensating for any differences between the NAV per Creation Unit and the
market value of the Deposit Securities or Deposit Cash, as applicable. Computation of the Cash Component excludes
any stamp duty or other similar fees and expenses payable upon transfer of beneficial ownership of the Deposit
Securities, if applicable, which will be the sole responsibility of the Authorized Participant (as defined below).
The Funds through NSCC, make available on each Business Day, immediately prior to the opening of business on the
Exchange (currently 9:30 a.m., Eastern time), the list of the names and the required number of shares of each Deposit
Security or the required amount of Deposit Cash, as applicable, to be included in the current Fund Deposit (based on
information at the end of the previous Business Day) for each Fund. Such Fund Deposit is subject to any applicable
adjustments as described below, in order to effect purchases of Creation Units of the Funds until such time as the next-
announced composition of the Deposit Securities or the required amount of Deposit Cash, as applicable, is made
available.
The identity and number of shares of the Deposit Securities or the amount of Deposit Cash, as applicable, required for
the Fund Deposit for a Fund changes as rebalancing adjustments and corporate action events are reflected from time to
time by the Adviser with a view to the investment objective of such Fund.
The Trust reserves the right to permit or require the substitution of an amount of cash (i.e., a “cash in lieu” amount) to
replace any Deposit Security, which will be added to the Deposit Cash, if applicable, and the Cash Component,
including, without limitation, in situations where the Deposit Security: (i) may not be available in sufficient quantity for
delivery; (ii) may not be eligible for transfer through the systems of DTC for corporate securities and municipal
securities; (iii) may not be eligible for trading by an Authorized Participant or the investor for which it is acting; (iv) would
be restricted under the securities laws or where the delivery of the Deposit Security to the Authorized Participant would
result in the disposition of the Deposit Security by the Authorized Participant becoming restricted under the securities
laws; or (v) in certain other situations (collectively, “custom orders”).
Procedures for Purchase of Creation Units
To be eligible to place orders with the Distributor to purchase a Creation Unit of a Fund, an entity must be (i) a
“Participating Party”, i.e., a broker-dealer or other participant in the clearing process through the Continuous Net
Settlement System of the NSCC (the “Clearing Process”), a clearing agency that is registered with the SEC; or (ii) a
DTC Participant (see “BOOK ENTRY ONLY SYSTEM” above). In addition, each Participating Party or DTC Participant
(each, an “Authorized Participant”) must execute a Participant Agreement that has been agreed to by the Distributor,
and that has been accepted by the Transfer Agent and the Trust, with respect to purchases and redemptions of Creation
Units. Each Authorized Participant will agree, pursuant to the terms of a Participant Agreement, on behalf of itself or any
investor on whose behalf it will act, to certain conditions, including that it will pay to the Trust an amount of cash
sufficient to pay the Cash Component together with the Creation Transaction Fee (defined below) and any other
applicable fees and taxes. The Adviser may retain all or a portion of the Transaction Fee to the extent the Adviser bears
the expenses that otherwise would be borne by the Trust in connection with the purchase of a Creation Unit, which the
Transaction Fee is designed to cover.
All orders to purchase shares directly from the Funds must be placed for one or more Creation Units and in the manner
and by the time set forth in the Participant Agreement (the “Cut-Off Time”). Orders to purchase Creation Units on the
next Business Day must be submitted as a “Future Dated Trade” between 4:30 p.m. Eastern time and 5:30 p.m. Eastern
time on the prior Business Day. Orders to purchase Creation Units on the current Business Day must be submitted on
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        25
such Business Day by 3:00 p.m. Eastern time; provided, however, that a Fund may, but is not required to, permit orders
until 4:00 p.m. Eastern time or until the market close in the event an exchange closes early. Such times may be
modified by the Funds from time to time by disclosure to Authorized Participants or amendment to the Participation
Agreement and/or applicable order form. The date on which an order to purchase Creation Units (or an order to redeem
Creation Units, as set forth below) is received and accepted is referred to as the “Order Placement Date.”
An Authorized Participant may require an investor to make certain representations or enter into agreements with respect
to the order (e.g., to provide for payments of cash, when required). Investors should be aware that their particular broker
may not have executed a Participant Agreement and that, therefore, orders to purchase shares directly from the Funds
in Creation Units have to be placed by the investor’s broker through an Authorized Participant that has executed a
Participant Agreement. In such cases there may be additional charges to such investor. At any given time, there may be
only a limited number of broker-dealers that have executed a Participant Agreement and only a small number of such
Authorized Participants may have international capabilities.
On days when the Exchange closes earlier than normal, the Funds may require orders to create Creation Units to be
placed earlier in the day. In addition, if a market or markets on which the Funds’ investments are primarily traded is
closed on any day, the Funds will also generally not accept orders on such day. Orders must be transmitted by an
Authorized Participant by telephone or other transmission method acceptable to the Transfer Agent pursuant to
procedures set forth in the Participant Agreement. With respect to the Funds, the Transfer Agent will notify the
Distributor and Custodian of such order. The Custodian will then provide such information to the appropriate local sub-
custodian(s). Those placing orders through an Authorized Participant should allow sufficient time to permit proper
submission of the purchase order to the Transfer Agent by the Cut-Off Time on the Business Day on which the order is
placed. Economic or market disruptions or changes, or telephone or other communication failure may impede the ability
to reach the Transfer Agent or an Authorized Participant.
Fund Deposits must be delivered by an Authorized Participant through the Federal Reserve System (for cash) or
through DTC (for corporate securities), through a subcustody agent (for foreign securities) and/or through such other
arrangements allowed by the Trust or its agents. With respect to foreign Deposit Securities, the Custodian shall cause
the subcustodian of the Funds to maintain an account into which the Authorized Participant shall deliver, on behalf of
itself or the party on whose behalf it is acting, such Deposit Securities (or Deposit Cash for all or a part of such
securities, as permitted or required), with any appropriate adjustments as advised by the Trust. Foreign Deposit
Securities must be delivered to an account maintained at the applicable local subcustodian. A Fund Deposit transfer
must be ordered by the Authorized Participant in a timely fashion so as to ensure the delivery of the requisite number of
Deposit Securities or Deposit Cash, as applicable, to the account of a Fund or its agents by no later than 12:00 p.m.
Eastern time (or such other time as specified by the Trust) on the Settlement Date. If the Funds or their agents do not
receive all of the Deposit Securities, or the required Deposit Cash in lieu thereof, by such time, then the order may be
deemed rejected and the Authorized Participant shall be liable to the Funds for losses, if any, resulting therefrom. The
“Settlement Date” for the Funds is generally the next Business Day after the Order Placement Date. All questions as to
the number of Deposit Securities or Deposit Cash to be delivered, as applicable, and the validity, form and eligibility
(including time of receipt) for the deposit of any tendered securities or cash, as applicable, will be determined by the
Trust, whose determination shall be final and binding. The amount of cash represented by the Cash Component must
be transferred directly to the Custodian through the Federal Reserve Bank wire transfer system in a timely manner so
as to be received by the Custodian no later than the Settlement Date. If the Cash Component and the Deposit
Securities or Deposit Cash, as applicable, are not received by the Custodian in a timely manner by the Settlement Date,
the creation order may be cancelled. Upon written notice to the Transfer Agent, such canceled order may be
resubmitted the following Business Day using a Fund Deposit as newly constituted to reflect the then current NAV of a
Fund.
The order shall be deemed to be received on the Business Day on which the order is placed provided that the order is
placed in proper form prior to the applicable cut-off time and the federal funds in the appropriate amount are deposited
with the Custodian on the Settlement Date. If the order is not placed in proper form as required, or federal funds in the
appropriate amount are not received on the Settlement Date, then the order may be deemed to be rejected and the
Authorized Participant shall be liable to the Funds for losses, if any, resulting therefrom. A creation request is considered
to be in “proper form” if all procedures set forth in the Participant Agreement and this SAI are properly followed.
Issuance of a Creation Unit
Except as provided herein, Creation Units will not be issued until the transfer of good title to the Trust of the Deposit
Securities or payment of Deposit Cash, as applicable, and the payment of the Cash Component have been completed.
When the subcustodian has confirmed to the Custodian that the required Deposit Securities (or the cash value thereof)
have been delivered to the account of the relevant subcustodian or subcustodians, the Distributor and the Adviser will
be notified of such delivery, and the Trust will issue and cause the delivery of the Creation Units. The delivery of
Creation Units so created generally will occur no later than the next Business Day following the day on which the
purchase order is deemed received by the Distributor, unless the Fund and Authorized Participant agree to a different
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        26
timeline for settlement or the transaction is exempt from the requirements of Rule 15c6-1 under the 1934 Act. However,
the Funds reserve the right to settle Creation Unit transactions on a basis other than the next Business Day following
the day on which the purchase order is deemed received by the Distributor in order to accommodate foreign market
holiday schedules, to account for different treatment among foreign and U.S. markets of dividend record dates and ex-
dividend dates (that is the last day the holder of a security can sell the security and still receive dividends payable on the
security), and in certain other circumstances. The Authorized Participant will be liable to the Funds for losses, if any,
resulting from unsettled orders.
Creation Units may be purchased in advance of receipt by the Trust of all or a portion of the applicable Deposit
Securities as described below. In these circumstances, the initial deposit will have a value greater than the NAV of the
shares on the date the order is placed in proper form since in addition to available Deposit Securities, cash must be
deposited in an amount equal to the sum of (i) the Cash Component, plus (ii) an additional amount of cash equal to a
percentage of the market value as set forth in the Participant Agreement, of the undelivered Deposit Securities (the
“Additional Cash Deposit”), which will be maintained in a separate non-interest bearing collateral account. The
Authorized Participant must deposit with the Custodian the Additional Cash Deposit, as applicable, by 12:00 p.m.
Eastern time (or such other time as specified by the Trust) on the Settlement Date. If the Funds or their agents do not
receive the Additional Cash Deposit in the appropriate amount, by such time, then the order may be deemed rejected
and the Authorized Participant shall be liable to the Funds for losses, if any, resulting therefrom. An additional amount of
cash will be required to be deposited with the Trust, pending delivery of the missing Deposit Securities to the extent
necessary to maintain the Additional Cash Deposit with the Trust in an amount at least equal to the applicable
percentage, as set forth in the Participant Agreement, of the daily marked to market value of the missing Deposit
Securities. The Participant Agreement will permit the Trust to buy the missing Deposit Securities at any time. Authorized
Participants will be liable to the Trust for the costs incurred by the Trust in connection with any such purchases. These
costs will be deemed to include the amount by which the actual purchase price of the Deposit Securities exceeds the
market value of such Deposit Securities on the day the purchase order was deemed received by the Distributor plus the
brokerage and related transaction costs associated with such purchases. The Trust will return any unused portion of the
Additional Cash Deposit once all of the missing Deposit Securities have been properly received by the Custodian or
purchased by the Trust and deposited into the Trust. In addition, a Transaction Fee as set forth below under “Creation
Transaction Fee” will be charged in all cases, unless otherwise advised by the Funds, and Non-Standard Charges may
also apply. The delivery of Creation Units so created generally will occur no later than the Settlement Date.
Acceptance of Orders of Creation Units
The Trust reserves the right to reject an order for Creation Units transmitted to it by the Transfer Agent in respect of the
Funds including, without limitation, if (a) the order is not in proper form; (b) the Deposit Securities or Deposit Cash, as
applicable, delivered by the Participant are not as disseminated through the facilities of the NSCC for that date by the
Custodian; (c) the investor(s), upon obtaining the shares ordered, would own 80% or more of the currently outstanding
shares of the Funds; (d) the acceptance of the Fund Deposit would, in the opinion of counsel, be unlawful; (e) the
acceptance or receipt of the order for a Creation Unit would, in the opinion of counsel to the Trust, be unlawful; or (f)
circumstances outside the control of the Trust, the Custodian, the Transfer Agent and/or the Adviser make it for all
practical purposes not feasible to process orders for Creation Units.
Examples of such circumstances include acts of God or public service or utility problems such as fires, floods, extreme
weather conditions and power outages resulting in telephone, telecopy and computer failures; market conditions or
activities causing trading halts; systems failures involving computer or other information systems affecting the Trust, the
Distributor, the Custodian, a sub-custodian, the Transfer Agent, DTC, NSCC, Federal Reserve System, or any other
participant in the creation process, and other extraordinary events. The Distributor shall notify a prospective creator of a
Creation Unit and/or the Authorized Participant acting on behalf of the creator of a Creation Unit of its rejection of the
order of such person. The Trust, the Transfer Agent, the Custodian, any sub-custodian and the Distributor are under no
duty, however, to give notification of any defects or irregularities in the delivery of Fund Deposits nor will either of them
incur any liability for the failure to give any such notification. The Trust, the Transfer Agent, the Custodian and the
Distributor will not be liable for the rejection of any purchase order for Creation Units.
All questions as to the number of shares of each security in the Deposit Securities and the validity, form, eligibility and
acceptance for deposit of any securities to be delivered will be determined by the Trust, and the Trust’s determination
will be final and binding.
Creation Transaction Fee
A purchase (i.e., creation) transaction fee is imposed for the transfer and other transaction costs associated with the
purchase of Creation Units, and investors will be required to pay a Creation Transaction Fee regardless of the number
of Creation Units created in the transaction. The Funds may adjust the creation transaction fee from time to time based
upon actual experience. The fixed creation fee may be waived on certain orders if the Funds’ custodian has determined
to waive some or all of the creation order costs associated with the order or another party, such as the Funds’
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        27
investment adviser, has agreed to pay such fee. In addition, the Funds may impose a Non-Standard Charge of up to 2%
of the value of the creation transactions for cash creations, non- standard orders, or partial cash purchases for the
Funds. The Funds may adjust the Non-Standard Charge from time to time based upon actual experience. Investors who
use the services of an Authorized Participant, broker or other such intermediary may be charged a fee for such services,
which may include an amount for the Creation Transaction Fee and Non-Standard Charges. Investors are responsible
for the costs of transferring the securities constituting the Deposit Securities to the account of the Trust. The Funds may
determine to not charge a Non-Standard Charge on certain orders when the Funds’ investment adviser has determined
that doing so is in the best interests of Fund shareholders, e.g. , for creation of orders that facilitate the rebalance of the
Funds’ portfolio in a more tax efficient manner than could be achieved without such order. The Adviser may retain all or
a portion of the Transaction Fee to the extent the Adviser bears the expenses that otherwise would be borne by the
Trust in connection with the purchase of a Creation Unit, which the Transaction Fee is designed to cover. The standard
Creation Transaction Fee for the Funds is $300.
Risks of Purchasing Creation Units
There are certain legal risks unique to investors purchasing Creation Units directly from the Funds. Because the Funds’
shares may be issued on an ongoing basis, a “distribution” of shares could be occurring at any time. Certain activities
that a shareholder performs as a dealer could, depending on the circumstances, result in the shareholder being deemed
a participant in the distribution in a manner that could render the shareholder a statutory underwriter and subject to the
prospectus delivery and liability provisions of the Securities Act. For example, a shareholder could be deemed a
statutory underwriter if it purchases Creation Units from the Funds, breaks them down into the constituent shares, and
sells those shares directly to customers, or if a shareholder chooses to couple the creation of a supply of new shares
with an active selling effort involving solicitation of secondary-market demand for shares. Whether a person is an
underwriter depends upon all of the facts and circumstances pertaining to that person’s activities, and the examples
mentioned here should not be considered a complete description of all the activities that could cause a shareholder to
be deemed an underwriter.
Dealers who are not “underwriters” but are participating in a distribution (as opposed to engaging in ordinary secondary-
market transactions), and thus dealing with a Fund’s shares as part of an “unsold allotment” within the meaning of
Section 4(a)(3)(C) of the Securities Act, will be unable to take advantage of the prospectus delivery exemption provided
by Section 4(a)(3)(C) of the Securities Act.
Redemption
Shares may be redeemed only in Creation Units at their NAV next determined after receipt of a redemption request in
proper form by the Funds through the Transfer Agent and only on a Business Day. EXCEPT UPON LIQUIDATION OF
THE FUNDS, THE TRUST WILL NOT REDEEM SHARES IN AMOUNTS LESS THAN CREATION UNITS. Investors
must accumulate enough shares in the secondary market to constitute a Creation Unit in order to have such shares
redeemed by the Trust. There can be no assurance, however, that there will be sufficient liquidity in the public trading
market at any time to permit assembly of a Creation Unit. Investors should expect to incur brokerage and other costs in
connection with assembling a sufficient number of shares to constitute a redeemable Creation Unit.
With respect to the Funds, the Custodian, through the NSCC, makes available immediately prior to the opening of
business on the Exchange (currently 9:30 a.m., Eastern time) on each Business Day, the list of the names and share
quantities of each Fund's portfolio securities that will be applicable (subject to possible amendment or correction) to
redemption requests received in proper form (as defined below) on that day (“Fund Securities”). Fund Securities
received on redemption may not be identical to Deposit Securities.
Redemption proceeds for a Creation Unit are paid either in-kind or in cash, or combination thereof, as determined by the
Trust. With respect to in-kind redemptions of the Funds, redemption proceeds for a Creation Unit will consist of Fund
Securities -- as announced by the Custodian on the Business Day of the request for redemption received in proper form
-- plus cash in an amount equal to the difference between the NAV of the shares being redeemed, as next determined
after a receipt of a request in proper form, and the value of the Fund Securities (the “Cash Redemption Amount”), less
any fixed redemption transaction fee as set forth below and any Non-Standard Charges. If the Fund Securities have a
value greater than the NAV of the shares, a compensating cash payment equal to the differential is required to be made
by or through an Authorized Participant by the redeeming shareholder. Notwithstanding the foregoing, at the Trust’s
discretion, an Authorized Participant may receive the corresponding cash value of the securities in lieu of the in-kind
securities value representing one or more Fund Securities.
Cash Redemption Method
Although the Trust does not ordinarily permit full or partial cash redemptions of Creation Units of the Funds, when full or
partial cash redemptions of Creation Units are available or specified for the Funds, they will be effected in essentially
the same manner as in-kind redemptions thereof. In the case of full or partial cash redemptions, the Authorized
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        28
Participant will receive the cash equivalent of the Fund Securities it would otherwise receive through an in-kind
redemption, plus the same Cash Amount to be paid to an in-kind redeemer.
Redemption Transaction Fees
A redemption transaction fee may be imposed for the transfer and other transaction costs associated with the
redemption of Creation Units, and Authorized Participants will be required to pay a Redemption Transaction Fee
regardless of the number of Creation Units created in the transaction. The redemption transaction fee is the same no
matter how many Creation Units are being redeemed pursuant to any one redemption request. The Funds may adjust
the redemption transaction fee from time to time based upon actual experience. The fixed redemption fee may be
waived on certain orders if the Funds’ custodian has determined to waive some or all of the redemption order costs
associated with the order of another party, such as the Funds’ investment adviser, has agreed to pay such fee. In
addition, the Funds may impose a Non-Standard Charge of up to 2% of the value of a redemption transaction for cash
redemptions, non-standard orders, or partial cash redemptions for the Funds. Investors who use the services of an
Authorized Participant, broker or other such intermediary may be charged a fee for such services which may include an
amount for the Redemption Transaction Fees and Non- Standard Charges. Investors are responsible for the costs of
transferring the securities constituting the Fund Securities to the account of the Trust. The Non-Standard Charges are
payable to the Funds as they incur costs in connection with the redemption of Creation Units, the receipt of Fund
Securities and the Cash Redemption Amount and other transactions costs. The standard Redemption Transaction Fee
for the Funds is $300.
Procedures for Redemption of Creation Units
Orders to redeem Creation Units must be submitted in proper form to the Transfer Agent prior to the time as set forth in
the Participant Agreement. A redemption request is considered to be in “proper form” if (i) an Authorized Participant has
transferred or caused to be transferred to the Trust’s Transfer Agent the Creation Unit(s) being redeemed through the
book- entry system of DTC so as to be effective by the time as set forth in the Participant Agreement and (ii) a request
in form satisfactory to the Trust is received by the Transfer Agent from the Authorized Participant on behalf of itself or
another redeeming investor within the time periods specified in the Participant Agreement. If the Transfer Agent does
not receive the investor’s shares through DTC’s facilities by the times and pursuant to the other terms and conditions
set forth in the Participant Agreement, the redemption request will be rejected.
All orders to redeem shares directly with the Funds must be placed for one or more Creation Units and in the manner
set forth in the Participant Agreement and by the Cut-Off Time. Orders to redeem Creation Units on the next Business
Day must be submitted as a “Future Dated Trade” between 4:30 p.m. Eastern time and 5:30 p.m. Eastern time on the
prior Business Day. Orders to redeem Creation Units on the current Business Day must be submitted by 3:00 p.m.
Eastern time on such Business Day.
The Authorized Participant must transmit the request for redemption, in the form required by the Trust, to the Transfer
Agent in accordance with procedures set forth in the Authorized Participant Agreement. Investors should be aware that
their particular broker may not have executed an Authorized Participant Agreement, and that, therefore, requests to
redeem Creation Units may have to be placed by the investor’s broker through an Authorized Participant which has
executed an Authorized Participant Agreement. Investors making a redemption request should be aware that such
request must be in the form specified by such Authorized Participant. Investors making a request to redeem Creation
Units should allow sufficient time to permit proper submission of the request by an Authorized Participant and transfer of
the shares to the Trust’s Transfer Agent; such investors should allow for the additional time that may be required to
effect redemptions through their banks, brokers or other financial intermediaries if such intermediaries are not
Authorized Participants.
Additional Redemption Procedures
In connection with taking delivery of shares of Fund Securities upon redemption of Creation Units, the Authorized
Participant must maintain appropriate custody arrangements with a qualified broker-dealer, bank or other custody
providers in each jurisdiction in which any of the Fund Securities are customarily traded, to which account such Fund
Securities will be delivered. Deliveries of redemption proceeds generally will be made within one Business Day of the
trade date. However, due to the schedule of holidays in certain countries, the different treatment among foreign and
U.S. markets of dividend record dates and dividend ex-dates (that is the last date the holder of a security can sell the
security and still receive dividends payable on the security sold), and in certain other circumstances, the delivery of in-
kind redemption proceeds may take longer than one Business Day after the day on which the redemption request is
received in proper form. The aforementioned circumstances include exceptional large redemptions combined with
exceptional market conditions such as a prolonged market closure. If neither the redeeming Shareholder nor the
Authorized Participant acting on behalf of such redeeming Shareholder has appropriate arrangements to take delivery
of the Fund Securities in the applicable foreign jurisdiction and it is not possible to make other such arrangements, or if
it is not possible to effect deliveries of the Fund Securities in such jurisdiction, the Trust may, in its discretion, exercise
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        29
its option to redeem such shares in cash, and the redeeming shareholder will be required to receive its redemption
proceeds in cash.
In addition, an investor may request a redemption in cash that the Funds may, in their sole discretion, permit. In either
case, the investor will receive a cash payment equal to the NAV of its shares based on the NAV of shares of each
relevant Fund next determined after the redemption request is received in proper form (minus a redemption transaction
fee and additional charge for requested cash redemptions specified above, to offset the Trust’s brokerage and other
transaction costs associated with the disposition of Fund Securities). The Funds may also, in its sole discretion, upon
request of a shareholder, provide such redeemer a portfolio of securities that differs from the exact composition of the
Fund Securities but does not differ in NAV.
Redemptions of shares for Fund Securities will be subject to compliance with applicable federal and state securities
laws and the Funds (whether or not it otherwise permits cash redemptions) reserve the right to redeem Creation Units
for cash to the extent that the Trust could not lawfully deliver specific Fund Securities upon redemptions or could not do
so without first registering the Fund Securities under such laws. An Authorized Participant or an investor for which it is
acting subject to a legal restriction with respect to a particular security included in the Fund Securities applicable to the
redemption of Creation Units may be paid an equivalent amount of cash. The Authorized Participant may request the
redeeming investor of the Shares or to enter into agreements with respect to such matters as compensating cash
payment. Further, an Authorized Participant that is not a “qualified institutional buyer,” (“QIB”) as such term is defined
under Rule 144A of the Securities Act, will not be able to receive Fund Securities that are restricted securities eligible for
resale under Rule 144A. An Authorized Participant may be required by the Trust to provide a written confirmation with
respect to QIB status in order to receive Fund Securities.
Because the portfolio securities of the Funds may trade on the relevant exchange(s) on days that the Exchange is
closed or are otherwise not Business Days for the Funds, shareholders may not be able to redeem their shares of the
Funds, or to purchase or sell shares of the Funds on the Exchange, on days when the NAV of the Funds could be
significantly affected by events in the relevant foreign markets.
The right of redemption may be suspended or the date of payment postponed with respect to the Funds (1) for any
period during which the Exchange is closed (other than customary weekend and holiday closings); (2) for any period
during which trading on the Exchange is suspended or restricted; (3) for any period during which an emergency exists
as a result of which disposal of the shares of the Funds or determination of the NAV of the shares is not reasonably
practicable; or (4) in such other circumstance as is permitted by the SEC.
Determination of Net Asset Value
The NAV for each Fund is computed by dividing the value of the net assets of a Fund (i.e., the value of its total assets
less total liabilities) by the total number of shares outstanding, rounded to the nearest cent. Expenses and fees,
including the management fees, are accrued daily and taken into account for purposes of determining NAV. The NAV of
the Funds is calculated at the close of the regular trading session on the New York Stock Exchange (ordinarily 4:00
p.m., Eastern time) on each day that such Exchange is open, provided that fixed-income assets may be valued as of the
announced closing time for trading in fixed- income instruments on any day that the Securities Industry and Financial
Markets Association (“SIFMA”) announces an early closing time.
Generally, the Funds’ investments are valued at market value or, in the absence of a market value, at fair value as
determined under fair value pricing policies approved by the Board. Pursuant to Rule 2a-5 under the 1940 Act, the
Adviser has been designated by the Board as the valuation designee for the Funds and has been delegated the
responsibility for making good faith, fair value determinations with respect to the Funds’ portfolio securities. When
market prices are not readily available, or believed by the Adviser to be unreliable, a security or other asset is valued at
its fair value by the Adviser as determined under fair value pricing procedures approved by the Board. The Board
reviews, no less frequently than annually, the adequacy of the Funds’ policies and procedures and the effectiveness of
their implementation. These fair value pricing procedures will also be used to price a security when corporate events,
events in the securities market and/or world events cause the Adviser to believe that a security’s last sale price may not
reflect its actual market value. The intended effect of using fair value pricing procedures is to ensure that the Funds are
accurately priced. The Board will regularly evaluate whether the Trust’s fair value pricing procedures continue to be
appropriate in light of the specific circumstances of the Funds and the quality of prices obtained through the application
of such procedures.
The Funds’ securities which are traded on securities exchanges are valued at the last sale price on the exchange on
which such securities are traded, as of the close of business on the day the securities are being valued or, lacking any
reported sales, at the mean between the last available bid and ask prices.
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        30
Securities traded on a securities exchange for which a last-quoted sales price is readily available will be valued at the
last sales price as reported by the primary exchange on which the securities are listed. Securities listed on the Nasdaq
National Market System (“Nasdaq”) will be valued at the Nasdaq Official Closing Price, which may differ from the last
sales price reported. Securities traded on a securities exchange for which a last-quoted sales price is not readily
available will be valued at the last bid, ask or mean between the bid and the ask price, as determined by the Advisor
and disclosed in the notes of the annual report. Equity securities traded in the over- the-counter market (“OTC”) market
in which no last sales price is available will be valued at the average of the last bid prices obtained from two or more
dealers unless there is only one dealer, in which case that dealer’s last bid price is used.
Stocks that are “thinly traded” or events occurring when a foreign market is closed but the Exchange is open may create
a situation where a market quote would not be readily available. When a market quote is not readily available, the
security’s value is based on “fair value” as determined by procedures adopted by the Board. The Board will periodically
review the reliability of the Funds’ fair value methodology. The Funds may hold portfolio securities, such as those traded
on foreign exchanges that trade on weekends or other days when the Funds’ shares are not priced. Therefore, the value
of the Funds’ shares may change on days when shareholders will not be able to purchase or redeem shares.
Dividends and Distributions
The following information supplements and should be read in conjunction with the section in the Prospectus entitled
“Dividends, Distributions and Taxes.”
General Policies
Distributions of net realized capital gains, if any, generally are declared and paid once a year, but the Funds may make
distributions on a more frequent basis to comply with the distribution requirements of the Internal Revenue Code of
1986, as amended (the “Code”), in all events in a manner consistent with the provisions of the 1940 Act.
Dividends and other distributions on shares are distributed, as described below, on a pro rata basis to Beneficial
Owners of such shares. Dividend payments are made through DTC Participants and Indirect Participants to Beneficial
Owners then of record with proceeds received from the Funds.
The Funds may make additional distributions to the extent necessary (i) to distribute the entire annual taxable income of
a Fund, plus any net capital gains and (ii) to avoid imposition of the excise tax imposed by Section 4982 of the Code.
Management of the Trust reserves the right to declare special dividends if, in its reasonable discretion, such action is
necessary or advisable to preserve a Fund’s eligibility for treatment as a regulated investment company (“RIC”) or to
avoid imposition of income or excise taxes on undistributed income.
Dividend Reinvestment Service
The Trust will not make the DTC book-entry dividend reinvestment service available for use by Beneficial Owners for
reinvestment of their cash proceeds, but certain individual broker- dealers may make available the DTC book-entry
Dividend Reinvestment Service for use by Beneficial Owners of the Funds through DTC Participants for reinvestment of
their dividend distributions. Investors should contact their brokers to ascertain the availability and description of these
services. Beneficial Owners should be aware that each broker may require investors to adhere to specific procedures
and timetables in order to participate in the dividend reinvestment service and investors should ascertain from their
brokers such necessary details. If this service is available and used, dividend distributions of both income and realized
gains will be automatically reinvested in additional whole shares of the same Fund purchased on the secondary market.
Distributions reinvested in additional shares of the Funds will nevertheless be taxable to Beneficial Owners acquiring
such additional shares to the same extent as if such distributions had been received in cash.
Federal Income Taxes
The following is a summary of certain additional federal income tax considerations generally affecting the Funds and
their shareholders that supplements the summary in the Prospectus. No attempt is made to present a comprehensive
explanation of the federal, state, local or foreign tax treatment of the Funds or their shareholders, and the discussion
here and in the Prospectus is not intended to be a substitute for careful tax planning.
The following general discussion of certain federal income tax consequences is based on provisions of the Code and
the regulations issued thereunder as in effect on the date of this SAI. New legislation, as well as administrative changes
or court decisions, may significantly change the conclusions expressed herein, and may have a retroactive effect with
respect to the transactions contemplated herein.
Shareholders are urged to consult their own tax advisers regarding the application of the provisions of tax law described
in this SAI in light of the particular tax situations of the shareholders and regarding specific questions as to federal,
state, or local taxes.
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        31
Regulated Investment Company (RIC) Status
Each Fund will seek to qualify for treatment as a RIC under Subchapter M of the Code. Provided that for each tax year
the Fund: (i) meets the requirements to be treated as a RIC (as discussed below); and (ii) distributes at least an amount
equal to the sum of 90% of the Fund’s investment company taxable income for such year (including, for this purpose,
the excess of net short-term capital gains over net long-term capital losses), computed without regard to the dividends-
paid deduction, and 90% of its net tax-exempt interest income for such year (the “Distribution Requirement”), the Fund
itself generally will not be subject to federal income taxes to the extent the Fund’s income, including the Fund’s net
capital gain (the excess of the Fund’s net long-term capital gains over its net short-term capital losses), is distributed to
the Fund’s shareholders. One of several requirements for RIC qualification is that the Fund must receive at least 90% of
its gross income each year from dividends, interest, payments with respect to certain securities loans, gains from the
sale or other disposition of stock, securities or foreign currencies, or other income derived with respect to the Fund’s
business of investing in stock, securities, or foreign currencies and net income from interests in qualified publicly traded
partnerships, generally including master limited partnerships (the “90% Test”). A second requirement for qualification as
a RIC is that the Fund must diversify its holdings so that, at the end of each quarter of the Fund’s taxable year: (a) at
least 50% of the market value of the Fund’s total assets is represented by cash and cash items, U.S. government
securities, securities of other RICs, and other securities, with these other securities limited, in respect to any one issuer,
to an amount not greater than 5% of the value of the Fund’s total assets and not more than 10% of the outstanding
voting securities of such issuer; and (b) not more than 25% of the value of its total assets is invested in the securities
(other than U.S. government securities or securities of other RICs) of any one issuer, the securities (other than
securities of other RICs) of two or more issuers which the Fund controls and which are engaged in the same, similar, or
related trades or businesses, or the securities of one or more qualified publicly traded partnerships (the “Asset Test”).
For purposes of the 90% Test, the character of income earned by certain entities in which a Fund invests that are not
treated as corporations for U.S. federal income tax purposes (e.g., partnerships and LLCs that are not publicly traded
partnerships and that have not elected to be classified as corporations under applicable regulations) will generally pass
through to the Fund. Consequently, in order to qualify as a RIC, each Fund may be required to limit its equity
investments in such entities if they earn income that is nonqualifying income for purposes of the 90% Test.
If a Fund fails to satisfy the 90% Test or the Asset Test, the Fund may be eligible for relief provisions if the failures are
due to reasonable cause and not willful neglect and if a penalty tax is paid with respect to each failure to satisfy the
applicable requirements. Additionally, relief is provided for certain de minimis failures of the Asset Test where a Fund
corrects the failure within a specified period of time. In order to be eligible for the relief provisions with respect to a
failure to meet the Asset Test, a Fund may be required to dispose of certain assets. If these relief provisions are not
available to a Fund and it fails to qualify for treatment as a RIC for a taxable year, all of its taxable income would be
subject to tax at the regular corporate income tax rate without any deduction for distributions to shareholders, and its
distributions (including capital gains distributions) generally would be taxable as ordinary income dividends to its
shareholders, subject if certain requirements are met to the dividends-received deduction for corporate shareholders
and the lower tax rates on qualified dividend income received by noncorporate shareholders. To requalify for treatment
as a RIC in a subsequent taxable year, the Fund would be required to satisfy the RIC qualification requirements for that
year and to distribute any earnings and profits from any year in which the Fund failed to qualify for tax treatment as a
RIC. If a Fund fails to qualify as a RIC for a period longer than two taxable years, it would generally be required to pay a
Fund-level tax on certain net built-in gains recognized with respect to certain of its assets upon a disposition of such
assets within five years of qualifying as a RIC in a subsequent year. The Board reserves the right not to maintain the
qualification of each Fund for treatment as a RIC if it determines such course of action to be beneficial to shareholders.
If a Fund determines that it will not qualify for treatment as a RIC, the Fund will establish procedures to reflect the
anticipated tax liability in the Fund's NAV.
For each year, each Fund intends to distribute substantially all of its investment company taxable income (computed
without regard to the dividends-paid deduction) and any realized net capital gain (after taking into account any capital
loss carryovers). If a Fund failed to satisfy the distribution requirement for any taxable year, it would be taxed as a
regular corporation, with consequences generally similar to those described above.
If a Fund meets the Distribution Requirement but retains some or all of its income or gains, it will be subject to federal
income tax to the extent any such income or gains are not distributed. A Fund may designate certain amounts retained
as undistributed net capital gain in a notice to its shareholders, who (i) will be required to include in income for U.S.
federal income tax purposes, as long-term capital gain, their proportionate shares of the undistributed amount so
designated, (ii) will be entitled to credit their proportionate shares of the income tax paid by the Fund on that
undistributed amount against their federal income tax liabilities and to claim refunds to the extent such credits exceed
their liabilities and (iii) will be entitled to increase their tax basis, for federal income tax purposes, in their shares in the
Fund by an amount equal to the excess of the amount of undistributed net capital gain included in their respective
income over their respective income tax credits.
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        32
Each Fund will be subject to a nondeductible 4% federal excise tax on certain undistributed income if it does not
distribute (and is not deemed to distribute) to its shareholders in each calendar year an amount at least equal to 98% of
its ordinary income for the calendar year plus 98.2% of its capital gain net income for the twelve months ended October
31 of that year, subject to an increase for any shortfall in the prior year’s distribution. For this purpose, any ordinary
income or capital gain net income retained by a Fund and subject to corporate income tax will be considered to have
been distributed. Each Fund intends to declare and distribute dividends and distributions in the amounts and at the
times necessary to avoid the application of this 4% excise tax, but can make no assurances that all such tax liability will
be eliminated. For example, a Fund may receive delayed or corrected tax reporting statements from its investments that
cause such Fund to accrue additional income and gains after such Fund has already made its excise tax distributions
for the year.  In such a situation, a Fund may incur an excise tax liability resulting from such delayed receipt of such tax
information statements.
Capital losses in excess of capital gains (“net capital losses”) are not permitted to be deducted against a RIC’s net
investment income. Instead, for U.S. federal income tax purposes, potentially subject to certain limitations, a RIC may
carry net capital losses from any taxable year forward to offset capital gains in future years. Each Fund is permitted to
carry net capital losses forward indefinitely. To the extent subsequent capital gains are offset by such losses, they will
not result in U.S. federal income tax liability to a Fund and may not be distributed as capital gains to shareholders.
Generally, a Fund may not carry forward any losses other than net capital losses. Under certain circumstances, a Fund
may elect to treat certain losses as though they were incurred on the first day of the taxable year immediately following
the taxable year in which they were actually incurred.
Taxation of Shareholders
Distributions of net capital gains that the Funds report to a shareholder as capital gain dividends are taxable as long-
term capital gains, regardless of how long the shareholder has owned the shares. Long-term capital gains are generally
taxed to noncorporate shareholders at rates of up to 20%. All other dividends of the Funds (including dividends from
short-term capital gains) from its current and accumulated earnings and profits are generally subject to tax as ordinary
income, subject to the discussion of qualified dividend income below.
Subject to certain limitations and requirements, including holding period requirements, dividends reported by the Funds
as qualified dividend income will be taxable to noncorporate shareholders at rates of up to 20%. In general, dividends
may be reported by the Funds as qualified dividend income if they are paid from dividends received by the Funds on
common and preferred stock of U.S. companies or on stock of certain eligible foreign corporations, provided that certain
holding period and other requirements are met by the Funds with respect to the dividend-paying stocks in their
portfolios. Subject to certain limitations, eligible foreign corporations include those incorporated in possessions of the
United States or in certain countries with comprehensive tax treaties with the United States, and other foreign
corporations if the stock with respect to which the dividends are paid is readily tradable on an established securities
market in the United States. “Passive foreign investment companies” (described below) are not qualified foreign
corporations for this purpose. Noncorporate shareholders will only be eligible for the rates of up to 20% on a Fund’s
qualified dividend income distributions if the shareholders also meet certain holding period requirements with respect to
their shares in the Fund.
Certain dividends received by the Funds on stock of U.S. corporations (generally, dividends received by the Funds in
respect of any share of stock (1) as to which the Funds have met certain holding period requirements and (2) that is
held in an unleveraged position) may be eligible for the dividends-received deduction generally available to corporate
shareholders under the Code, provided such dividends are also appropriately reported as eligible for the dividends-
received deduction by the Funds. In order to qualify for the dividends-received deduction, corporate shareholders must
also meet minimum holding period requirements with respect to their Fund shares, taking into account any holding
period reductions from certain hedging or other transactions or positions that diminish their risk of loss with respect to
their Fund shares. Any corporate shareholder should consult its tax adviser regarding the possibility that its tax basis in
its shares may be reduced, for federal income tax purposes, by reason of “extraordinary dividends” received with
respect to the shares and, to the extent such basis would be reduced below zero, current recognition of income may be
required. The Funds’ investment strategies may significantly limit their ability to distribute dividends eligible for the
dividends-received deduction for corporations.
The Funds’ participation in loans of securities may affect the amount, timing, and character of distributions to Fund
shareholders. If a Fund participates in a securities lending transaction and receives a payment in lieu of dividends (a
“substitute payment”) with respect to securities on loan in a securities lending transaction, such income generally will not
constitute qualified dividend income and thus dividends attributable to such income will not be eligible for taxation at the
rates applicable to qualified dividend income. In addition, dividends attributable to such income will not be eligible for the
dividends-received deduction for corporate shareholders.
Although dividends generally will be treated as distributed when paid, any dividend declared by a Fund in October,
November or December and payable to shareholders of record in such a month that is paid during the following January
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        33
will be treated for U.S. federal income tax purposes as received by shareholders on December 31 of the calendar year
in which it was declared. In addition, certain distributions made after the close of a taxable year of the Funds may be
“spilled back” and treated for certain purposes as paid by a Fund during such taxable year. In such case, shareholders
generally will be treated as having received such dividends in the taxable year in which the distributions were actually
made. For purposes of calculating the amount of a RIC’s undistributed income and gain subject to the 4% excise tax
described above, such “spilled back” dividends are treated as paid by the RIC when they are actually paid.
Fund distributions, if any, that exceed a Fund’s current and accumulated earnings and profits may be treated as a return
of capital to shareholders. A return of capital distribution generally will not be taxable but will reduce the shareholder’s
cost basis and result in a higher capital gain or lower capital loss when the shares on which the distribution was
received are sold. After a shareholder’s basis in the shares has been reduced to zero, distributions in excess of
earnings and profits will be treated as gain from the sale of the shareholder’s shares.
The Funds’ shareholders will be notified annually as to the federal tax characterization of all distributions made by the
Funds. Distributions may be subject to state and local taxes.
U.S. individuals with income exceeding certain threshold amounts ($250,000 if married and filing jointly or if considered
a “surviving spouse” for federal income tax purposes, $125,000 if married filing separately and $200,000 in other cases)
are subject to a 3.8% tax on all or a portion of their “net investment income,” which generally includes interest,
dividends, and capital gains (including capital gains realized on the sale or exchange of shares of a Fund or the
redemption of Creation Units). This 3.8% tax also applies to all or a portion of the undistributed net investment income
of certain shareholders that are estates and trusts.
A taxable shareholder may wish to avoid investing in the Funds shortly before a dividend or other distribution, because
the distribution will generally be taxable even though it may economically represent a return of a portion of the
shareholder’s investment.
Shareholders who have not held Fund shares for a full year should be aware that a Fund may report and distribute to a
shareholder, as ordinary dividends or capital gain dividends, a percentage of income that is not equal to the percentage
of the Fund’s ordinary income or net capital gain, respectively, actually earned during the shareholder’s period of
investment in the Fund.
A sale of shares by a shareholder may give rise to a gain or loss. The difference between the selling price and the
shareholder’s tax basis for the shares sold generally determines the amount of the gain or loss realized on the sale or
exchange of shares. The tax basis of shares acquired by purchase will generally be based on the amount paid for
shares and then may be subsequently adjusted for other applicable transactions as required by the Code. Contact the
broker through whom you purchased your shares to obtain information with respect to the available basis reporting
methods and elections for your account.
In general, any gain or loss realized upon a taxable disposition of shares will be treated as capital gain or loss if the
shares are capital assets in the shareholder’s hands, and will be long-term capital gain or loss if the shares have been
held for more than one year, and short-term capital gain or loss if the shares are held for one year or less. Any loss
realized upon a taxable disposition of shares held for six months or less will be treated as long-term, rather than short-
term, to the extent of any amounts treated as distributions to the shareholder of long-term capital gain with respect to
the shares (including any amounts credited to the shareholder as undistributed capital gains). All or a portion of any loss
realized upon a taxable disposition of shares will be disallowed if substantially identical shares of a Fund are purchased
(through reinvestment of dividends or otherwise) within 30 days before or after the disposition. In such a case, the basis
of the newly purchased shares will be adjusted to reflect the disallowed loss.
An Authorized Participant who exchanges securities or other assets for Creation Units generally will recognize gain or
loss from the exchange. The gain or loss will be equal to the difference between the market value of the Creation Units
received and the sum of the Authorized Participant’s aggregate basis in the securities and other assets surrendered
plus the amount of cash paid for such Creation Units. The Internal Revenue Service (“IRS”), however, may assert that a
loss realized upon an exchange of securities for Creation Units cannot be deducted currently under the rules governing
“wash sales,” or on the basis that there has been no significant change in economic position. Any gain or loss realized
by an Authorized Participant upon a creation of Creation Units will be treated as capital gain or loss if the Authorized
Participant holds the securities exchanged therefor as capital assets, and otherwise will be ordinary income or loss. Any
capital gain or loss realized upon the creation of Creation Units will generally be treated as long-term capital gain or loss
if the securities or other assets exchanged for such Creation Units have been held by the Authorized Participant for
more than one year, and otherwise will be short-term capital gain or loss.
The Trust on behalf of the Funds has the right to reject an order for a purchase of Creation Units if the Authorized
Participant (or a group of Authorized Participants) would, upon obtaining the Creation Units so ordered, own 80% or
more of the outstanding shares of a Fund and if, pursuant to Section 351 of the Code, the Fund would have a basis in
the securities different from the market value of such securities on the date of deposit. The Trust also has the right to
require information necessary to determine beneficial share ownership for purposes of the 80% determination. If a Fund
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        34
does issue Creation Units to an Authorized Participant (or group of Authorized Participants) that would, upon obtaining
the Creation Units so ordered, own 80% or more of the outstanding shares of the Fund, the Authorized Participant (or
group of Authorized Participants) may not recognize gain or loss upon the exchange of securities for Creation Units.
An Authorized Participant who redeems Creation Units will generally recognize a gain or loss equal to the difference
between the sum of the aggregate market value of any securities received plus the amount of any cash received for
such Creation Units and the Authorized Participant’s basis in the Creation Units. Any gain or loss realized by an
Authorized Participant upon a redemption of Creation Units will be treated as capital gain or loss if the Authorized
Participant holds the shares comprising the Creation Units as capital assets, and otherwise will be ordinary income or
loss. Any capital gain or loss realized upon the redemption of Creation Units will generally be treated as long-term
capital gain or loss if the shares comprising the Creation Units have been held by the Authorized Participant for more
than one year, and otherwise will generally be short-term capital gain or loss. Any capital loss realized upon a
redemption of Creation Units held for six months or less will be treated as a long-term capital loss to the extent of any
amounts treated as distributions to the applicable Authorized Participant of long-term capital gains with respect to the
Creation Units (including any amounts credited to the Authorized Participant as undistributed capital gains).
Authorized Participants purchasing or redeeming Creation Units should consult their own tax advisers with respect to
the tax treatment of any creation or redemption transaction.
Due to the ability of the Authorized Participants to receive a full or partial cash redemption of Creation Units of the
Funds, the Funds may be required to execute additional sale or exchange transactions which may increase the taxable
income of the Funds and limit the tax efficiency of the Funds.
Taxation of Fund Investments
Certain of the Funds’ investments may be subject to complex provisions of the Code (including provisions relating to
hedging transactions, straddles, integrated transactions, foreign currency contracts, forward foreign currency contracts,
and notional principal contracts) that, among other things, may affect the character of gains and losses realized by the
Funds (e.g., may affect whether gains or losses are ordinary or capital), accelerate recognition of income to the Funds
and defer losses. These rules could therefore affect the character, amount and timing of distributions to shareholders.
These provisions also may require the Funds to mark to market certain types of positions in their portfolios (i.e., treat
them as if they were closed out) which may cause the Funds to recognize income without receiving cash with which to
make distributions in amounts necessary to satisfy the RIC distribution requirements for avoiding income and excise
taxes. The Funds intend to monitor their transactions, intend to make appropriate tax elections, and intend to make
appropriate entries in its books and records in order to mitigate the effect of these rules and preserve their qualification
for treatment as RICs.
Foreign Taxes
The Funds may be subject to withholding and other taxes imposed by foreign countries, including taxes on interest,
dividends and capital gains with respect to any investments in those countries. Any such taxes would, if imposed,
reduce the yield on or return from those investments. Tax conventions between certain countries and the U.S. may
reduce or eliminate such taxes in some cases. The Funds do not expect to satisfy the requirements for passing through
to their shareholders any share of foreign taxes paid by the Funds, with the result that shareholders will not be required
to include such taxes in their gross incomes and will not be entitled to a tax deduction or credit for any such taxes on
their own tax returns.
Backup Withholding
The Funds will be required in certain cases to withhold (as “backup withholding”) at the applicable withholding rate and
remit to the U.S. Treasury the amount withheld from taxable dividends paid to any shareholder who (1) fails to provide a
correct taxpayer identification number certified under penalty of perjury; (2) is subject to withholding by the IRS for
failure to properly report all payments of interest or dividends; (3) fails to provide a certified statement that he or she is
not subject to “backup withholding;” or (4) fails to provide a certified statement that he or she is a U.S. person (including
a U.S. resident alien). Backup withholding is not an additional tax and any amounts withheld may be credited against
the shareholder’s ultimate U.S. tax liability.
Tax-Exempt Shareholders
Certain tax-exempt shareholders, including qualified pension plans, IRAs, salary deferral arrangements, 401(k)s, and
other tax-exempt entities, generally are exempt from federal income taxation except with respect to their unrelated
business taxable income (“UBTI”). Tax-exempt entities are not permitted to offset losses from one trade or business
against the income or gain of another trade or business. Certain net losses incurred prior to January 1, 2018, are
permitted to offset gain and income created by an unrelated trade or business, if otherwise available. Under current law,
the Funds generally serve to block UBTI from being realized by their tax-exempt shareholders. However,
notwithstanding the foregoing, the tax-exempt shareholder could realize UBTI by virtue of an investment in a Fund
where, for example: (i) the Fund invests in residual interests of Real Estate Mortgage Investment Conduits (“REMICs”),
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        35
(ii) the Fund invests in a REIT that is a taxable mortgage pool (“TMP”) or that has a subsidiary that is a TMP or that
invests in the residual interest of a REMIC, or (iii) shares in the Fund constitute debt-financed property in the hands of
the tax-exempt shareholder within the meaning of Section 514(b) of the Code. Charitable remainder trusts are subject to
special rules and should consult their tax advisor. The IRS has issued guidance with respect to these issues and
prospective shareholders, especially charitable remainder trusts, are strongly encouraged to consult their tax advisors
regarding these issues.
A Fund’s shares held in a tax-qualified retirement account will generally not be subject to federal taxation on income and
capital gains distributions from the Fund until a shareholder begins receiving payments from their retirement account.
Because each shareholder’s tax situation is different, shareholders should consult their tax advisor about the tax
implications of an investment in the Funds.
Foreign Shareholders
Foreign shareholders (i.e., nonresident alien individuals and foreign corporations, partnerships, trusts and estates) are
generally subject to U.S. withholding tax at the rate of 30% (or a lower tax treaty rate) on distributions derived from
taxable ordinary income. Gains realized by foreign shareholders from the sale or other disposition of shares of the
Funds generally are not subject to U.S. taxation, unless the recipient is an individual who is physically present in the
U.S. for 183 days or more during the taxable year. Foreign shareholders who fail to provide an applicable IRS form may
be subject to backup withholding on certain payments from the Funds. Backup withholding will not be applied to
payments that are subject to the 30% (or lower applicable treaty rate) withholding tax described in this paragraph.
Different tax consequences may result if the foreign shareholder is engaged in a trade or business within the United
States. In addition, the tax consequences to a foreign shareholder entitled to claim the benefits of a tax treaty may be
different than those described above.
The 30% withholding tax also will not apply to dividends that the Funds report as (a) interest-related dividends, to the
extent such dividends are derived from a Fund’s “qualified net interest income,” or (b) short-term capital gain dividends,
to the extent such dividends are derived from the Funds’ “qualified short-term gain.” “Qualified net interest income” is a
Fund’s net income derived from U.S.-source interest and original issue discount, subject to certain exceptions and
limitations. “Qualified short-term gain” generally means the excess of the net short-term capital gain of a Fund for the
taxable year over its net long-term capital loss, if any. In the case of shares held through a broker, the broker may
withhold even if the Fund reports a payment as an interest-related dividend or a short-term capital gain dividend. Non-
U.S. shareholders should contact their brokers with respect to the application of these rules to their accounts.
Unless certain non-U.S. entities that hold Fund shares comply with IRS requirements that generally require them to
report information regarding U.S. persons investing in, or holding accounts with, such entities, a 30% withholding tax
may apply to certain Fund distributions payable to such entities. A non-U.S. shareholder may be exempt from the
withholding described in this paragraph under an applicable intergovernmental agreement between the U.S. and a
foreign government, provided that the shareholder and the applicable foreign government comply with the terms of the
agreement.
A beneficial holder of shares who is a foreign person may be subject to foreign, state and local tax and to the U.S.
federal estate tax in addition to the federal income tax consequences referred to above. If a shareholder is eligible for
the benefits of a tax treaty, any effectively connected income or gain will generally be subject to U.S. federal income tax
on a net basis only if it is also attributable to a permanent establishment or fixed base maintained by the shareholder in
the United States.
Certain Potential Tax Reporting Requirements
Under U.S. Treasury regulations, if a shareholder recognizes a loss of $2 million or more for an individual shareholder or
$10 million or more for a corporate shareholder (or certain greater amounts over a combination of years), the
shareholder must file with the IRS a disclosure statement on IRS Form 8886. Direct shareholders of portfolio securities
are in many cases excepted from this reporting requirement, but under current guidance shareholders of a RIC are not
excepted. A shareholder who fails to make the required disclosure to the IRS may be subject to adverse tax
consequences, including substantial penalties. The fact that a loss is reportable under these regulations does not affect
the legal determination of whether the taxpayer’s treatment of the loss is proper. Shareholders should consult their tax
advisers to determine the applicability of these regulations in light of their individual circumstances.
Other Issues
The Funds may be subject to tax or taxes in certain states where the Funds do business. Furthermore, in those states
which have income tax laws, the tax treatment of the Funds and of Fund shareholders with respect to distributions by
the Funds may differ from federal tax treatment.
The foregoing discussion is based on federal tax laws and regulations which are in effect on the date of this Statement
of Additional Information. Such laws and regulations may be changed by legislative or administrative action.
TUTTLE CAPITAL MANAGEMENT — MULTI-FUND STATEMENT OF ADDITIONAL INFORMATION                                                        36
Shareholders are advised to consult their tax advisers concerning their specific situations and the application of federal,
state, local and foreign taxes.
Financial Statements
As of the date of this SAI, the Funds have not yet commenced operations and, therefore, have not produced financial
statements. Once available, you can obtain a copy of the financial statements contained in the Funds’ Annual or Semi-
Annual Report.