04/06/2026 | Press release | Distributed by Public on 04/06/2026 12:47
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF REGISTERED
MANAGEMENT INVESTMENT COMPANIES
| Investment Company Act file number: | 811-23439 |
| Exact name of registrant as specified in charter: | ETF Opportunities Trust |
| Address of principal executive offices: |
8730 Stony Point Parkway Suite 205 Richmond, VA 23235 |
| Name and address of agent for service |
The Corporation Trust Co. Corporation Trust Center 1209 Orange St. Wilmington, DE 19801 With Copy to: Practus, LLP 11300 Tomahawk Creek Parkway Suite 310 Leawood, KS 66211 |
| Registrant's telephone number, including area code: | (804) 267-7400 |
| Date of fiscal year end: | July 31 |
| Date of reporting period: | January 31, 2026 |
| Cultivar ETF |
ITEM 1.(a). Reports to Stockholders.
Cultivar ETFTailored Shareholder Report
|
semi-annual shareholder report January 31, 2026 Cultivar ETF Ticker: CVAR(Listed on the Cboe BZX Exchange) |
This semi-annual shareholder reportcontains important information about the Cultivar ETF for the period of August 1, 2025 to January 31, 2026. You can find additional information about the Fund at cultivarfunds.com/funds/. You can also request this information by contacting us at (833) 930-2229.
What were the Fund costs for the period?
(based on a hypothetical $10,000 investment)
|
Fund Name
|
Costs of a $10,000 investment
|
Costs paid as a percentage of a $10,000 investment
|
|
Cultivar ETF
|
$47
|
0.87%¹
|
| ¹ | Annualized. |
How did the Fund perform for the period?
For the six-month period from August 1, 2025, to January 31, 2026, the Fund outperformed its benchmark, the Russell 3000® Index. On a one-year basis, the Fund very slightly lagged the benchmark, while maintaining a more eclectic risk-informed posture. The Fund does not follow a capitalization-weighted indexed approach, as it focuses on active stock selection based on the portfolio managers' assessment of individual stock valuations, as well as broad macro risks.
What key factors affected the Fund's performance for the period?
The Fund's active assessment of individual security valuations and concerns about macro risks caused underweights to technology and consumer discretionary areas. This assessment also led the Fund to maintain an overweight in traditionally less volatile areas, such as cash and U.S. Treasuries, basic materials, consumer staples and healthcare.
Positioning
The fund held an overweight in the basic materials sector which it continued to trim opportunistically upon the recent surge in precious metals.The Fund also maintained its overweight in the healthcare and consumer staples sectors, as softness in these sectors provided investment opportunity within the Fund's desired valuation range.With mega-cap technology stocks appearing overvalued and with the index being driven higher by such valuations, the Fund exercised a measure of risk control by continuing to maintain its underweight in the technology sector relative to the benchmark.
Performance
The Fund posted a positive return that exceeded the benchmark for the six-month period ended January 31, 2026, and performed close to the benchmark over a one-year period then ended. It did this while maintaining broad diversification with a focus toward risk control measures.The focus on diversification was beneficial to performance relative to the benchmark during much of 2025 and into the first part of 2026. Positive impacts came from holdings in the materials sector, primarily through precious metals mining companies and lithium mining companies. Additionally, in the industrials area, there were a couple of key overweight positions that performed well. Lastly, a single oil services company provided much of the outperformance in the energy sector. A critical theme among all these performers was the patience required to hold while awaiting such timely performance movements.
Top Contributors- Minerals, Industrials, Energy
Top Detractors- Financial, Real Estate, Communication Services
Cumulative Performance
(based on a hypothetical $10,000 investment)
| * | Inception |
Annual Performance
|
1 Year
|
Average Annual Total Return Since Inception
|
|
|
Cultivar ETF
|
15.06%
|
6.78%
|
|
Russell 3000® Index
|
15.32%
|
11.51%
|
The Russell 3000® Index tracks the shares of the largest 3,000 publicly traded companies in the United States.
Visit cultivarfunds.com/funds/ for more recent performance information.
The Fund's past performance is not a good predictor of how the Fund will perform in the future. The graph and table do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or redemption of Fund shares.
Cultivar ETFTailored Shareholder Report
Sector Breakdown
|
Top Ten Holdings
|
|
|
US Treasury Bill 2/5/2026 2.88%
|
4.13%
|
|
US Treasury Bond 5/15/2052 2.875%
|
4.10%
|
|
MarketAxess Holdings, Inc.
|
3.98%
|
|
Core Laboratories, Inc.
|
3.62%
|
|
Southwest Airlines Co.
|
3.40%
|
|
Healthcare Services Group, Inc.
|
2.49%
|
|
Alexandria Real Estate Equities, Inc.
|
2.21%
|
|
Albemarle Corp.
|
2.15%
|
|
US Treasury Bond 5/15/2054 4.625%
|
2.11%
|
|
Northwest Natural Holding Co.
|
2.07%
|
Key Fund Statistics
(as of January 31, 2026)
|
Fund Net Assets
|
$38,271,752
|
|
Number of Holdings
|
89
|
|
Total Net Advisory Fee
|
$158,318
|
|
Portfolio Turnover Rate
|
15.58%
|
For additional information about the Fund; including its prospectus, financial statements and other information, holdings and proxy voting information, visit cultivarfunds.com/funds/.
What did the Fund invest in?
(% of Net Assets as of January 31, 2026)
ITEM 1.(b).
Not applicable.
| ITEM 2. | CODE OF ETHICS. |
Not applicable when filing a semi-annual report to shareholders.
| ITEM 3. | AUDIT COMMITTEE FINANCIAL EXPERT. |
Not applicable when filing a semi-annual report to shareholders.
| ITEM 4. | PRINCIPAL ACCOUNTANT FEES AND SERVICES. |
Not applicable when filing a semi-annual report to shareholders.
| ITEM 5. | AUDIT COMMITTEE OF LISTED REGISTRANTS. |
Not applicable when filing a semi-annual report to shareholders.
| ITEM 6. | INVESTMENTS. |
| (a) | The Registrant's Schedule of Investments is included as part of the Financial Statements and Financial Highlights filed under Item 7 of this Form. |
| (b) | Not applicable. |
| ITEM 7. | FINANCIAL STATEMENTS AND FINANCIAL HIGHLIGHTS FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES. |
FINANCIAL STATEMENTS
AND OTHER INFORMATION
Six Months Ended January 31, 2026 (Unaudited)
Cultivar ETF
Cultivar ETF
See Notes to Financial Statements
2
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Schedule of InvestmentsJanuary 31, 2026 (Unaudited)
|
|
|
|
|
Shares |
|
Value |
|
|
88.13% |
|
COMMON STOCKS |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1.26% |
|
COMMUNICATION SERVICES |
|
|
|
|
|
|
|
|
Comcast Corp. Class A |
|
9,149 |
|
$272,183 |
|
|
|
|
John Wiley & Sons, Inc. Class A |
|
6,679 |
|
208,585 |
|
|
|
|
|
|
|
|
480,768 |
|
|
|
|
|
|
|
|
|
|
|
4.10% |
|
CONSUMER DISCRETIONARY |
|
|
|
|
|
|
|
|
Advance Auto Parts |
|
5,217 |
|
250,468 |
|
|
|
|
Hasbro, Inc. |
|
2,166 |
|
193,445 |
|
|
|
|
Lululemon Athletica, Inc. ADR(A) |
|
2,228 |
|
388,786 |
|
|
|
|
Monro, Inc. |
|
11,673 |
|
218,519 |
|
|
|
|
NIKE, Inc. |
|
8,352 |
|
516,237 |
|
|
|
|
|
|
|
|
1,567,455 |
|
|
|
|
|
|
|
|
|
|
|
13.24% |
|
CONSUMER STAPLES |
|
|
|
|
|
|
|
|
Archer-Daniels-Midland Co. |
|
1,967 |
|
132,399 |
|
|
|
|
The Clorox Co. |
|
3,725 |
|
420,143 |
|
|
|
|
Dollar General Corp. |
|
3,883 |
|
556,939 |
|
|
|
|
General Mills, Inc. |
|
4,044 |
|
187,075 |
|
|
|
|
The Hershey Company |
|
3,382 |
|
658,644 |
|
|
|
|
Hormel Foods Corp. |
|
21,094 |
|
519,123 |
|
|
|
|
Ingredion, Inc. |
|
1,769 |
|
208,919 |
|
|
|
|
Kimberly-Clark Corp. |
|
4,606 |
|
460,554 |
|
|
|
|
Lamb Weston Holdings, Inc. |
|
6,632 |
|
304,608 |
|
|
|
|
McCormick & Co., Inc.(B) |
|
9,270 |
|
573,164 |
|
|
|
|
The JM Smucker Co. |
|
3,729 |
|
391,023 |
|
|
|
|
Target Corp. |
|
1,905 |
|
200,920 |
|
|
|
|
Tyson Foods, Inc. Class A |
|
6,970 |
|
455,350 |
|
|
|
|
|
|
|
|
5,068,861 |
|
|
|
|
|
|
|
|
|
|
|
6.36% |
|
ENERGY |
|
|
|
|
|
|
|
|
BP plc ADR |
|
8,361 |
|
316,715 |
|
|
|
|
Core Laboratories, Inc. ADR |
|
70,875 |
|
1,384,898 |
|
|
|
|
Equinor ASA ADR |
|
10,936 |
|
293,632 |
|
|
|
|
Halliburton Co. |
|
13,140 |
|
440,453 |
|
|
|
|
|
|
|
|
2,435,698 |
|
|
|
|
|
|
|
|
|
|
See Notes to Financial Statements
3
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Schedule of Investments - continuedJanuary 31, 2026 (Unaudited)
|
|
|
|
|
Shares |
|
Value |
|
|
8.74% |
|
FINANCIALS |
|
|
|
|
|
|
|
|
FactSet Research Systems, Inc. |
|
665 |
|
$169,149 |
|
|
|
|
Global Payments, Inc. |
|
6,468 |
|
464,014 |
|
|
|
|
Independent Bank Corp. |
|
4,243 |
|
342,750 |
|
|
|
|
Jack Henry & Associates, Inc. |
|
1,614 |
|
289,245 |
|
|
|
|
MarketAxess Holdings, Inc. |
|
8,992 |
|
1,521,716 |
|
|
|
|
PayPal Holdings, Inc. |
|
10,557 |
|
556,248 |
|
|
|
|
|
|
|
|
3,343,122 |
|
|
|
|
|
|
|
|
|
|
|
16.88% |
|
HEALTH CARE |
|
|
|
|
|
|
|
|
Agilent Technologies, Inc. |
|
1,242 |
|
166,242 |
|
|
|
|
Biogen, Inc.(A) |
|
2,837 |
|
510,348 |
|
|
|
|
Bio-Techne Corp. |
|
5,320 |
|
340,959 |
|
|
|
|
Bristol-Myers Squibb Co. |
|
3,913 |
|
215,411 |
|
|
|
|
CVS Health Corp. |
|
4,671 |
|
348,083 |
|
|
|
|
Edwards Lifescience Corp.(A) |
|
4,404 |
|
358,309 |
|
|
|
|
Fresenius Medical Care AG ADR |
|
12,252 |
|
278,120 |
|
|
|
|
Humana, Inc. |
|
2,433 |
|
474,922 |
|
|
|
|
Illumina, Inc.(A) |
|
3,506 |
|
507,704 |
|
|
|
|
Inogen, Inc.(A) |
|
27,252 |
|
160,787 |
|
|
|
|
Medtronic plc ADR |
|
4,866 |
|
501,003 |
|
|
|
|
Perrigo Co. plc ADR |
|
17,503 |
|
248,718 |
|
|
|
|
Pfizer, Inc. |
|
11,146 |
|
294,700 |
|
|
|
|
Regeneron Pharmaceuticals, Inc. |
|
550 |
|
407,798 |
|
|
|
|
Thermo Fisher Scientific, Inc. |
|
319 |
|
184,577 |
|
|
|
|
UnitedHealth Group, Inc. |
|
1,333 |
|
382,478 |
|
|
|
|
Veeva Systems, Inc. Class A(A) |
|
1,240 |
|
252,861 |
|
|
|
|
Zimmer Biomet Holdings |
|
4,196 |
|
365,346 |
|
|
|
|
Zoetis, Inc. |
|
3,697 |
|
461,460 |
|
|
|
|
|
|
|
|
6,459,826 |
|
|
|
|
|
|
|
|
|
|
|
10.75% |
|
INDUSTRIALS |
|
|
|
|
|
|
|
|
Copart, Inc.(A) |
|
2,417 |
|
98,082 |
|
|
|
|
Healthcare Services Group, Inc.(A) |
|
50,677 |
|
953,741 |
|
|
|
|
Lockheed Martin Corp. |
|
415 |
|
263,201 |
|
|
|
|
Paycom Software, Inc. |
|
2,854 |
|
384,576 |
|
|
|
|
Proto Labs, Inc.(A) |
|
11,294 |
|
594,629 |
|
|
|
|
Southwest Airlines Co. |
|
27,368 |
|
1,300,527 |
|
|
|
|
UPS, Inc. Class B |
|
2,225 |
|
236,339 |
|
|
|
|
Canadian National Railway Co. ADR |
|
2,929 |
|
281,828 |
|
|
|
|
|
|
|
|
4,112,923 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
See Notes to Financial Statements
4
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Schedule of Investments - continuedJanuary 31, 2026 (Unaudited)
|
|
|
|
|
Shares |
|
Value |
|
|
6.63% |
|
INFORMATION TECHNOLOGY |
|
|
|
|
|
|
|
|
Accenture plc Class A ADR |
|
722 |
|
$190,348 |
|
|
|
|
Adobe, Inc.(A) |
|
1,274 |
|
373,600 |
|
|
|
|
Cognex Corp. |
|
6,346 |
|
245,844 |
|
|
|
|
Cognizant Tech Solutions |
|
2,297 |
|
188,492 |
|
|
|
|
Dassault Systemes S.A. ADR |
|
10,798 |
|
296,945 |
|
|
|
|
Microchip Technology, Inc. |
|
2,903 |
|
220,396 |
|
|
|
|
Nice Systems Ltd. ADR(A) |
|
1,325 |
|
140,993 |
|
|
|
|
Qorvo, Inc.(A) |
|
6,028 |
|
470,847 |
|
|
|
|
Skyworks Solutions, Inc. |
|
3,696 |
|
206,089 |
|
|
|
|
STMicroelectronics NV ADR |
|
7,296 |
|
203,485 |
|
|
|
|
|
|
|
|
2,537,039 |
|
|
|
|
|
|
|
|
|
|
|
9.91% |
|
MATERIALS |
|
|
|
|
|
|
|
|
Albemarle Corp. |
|
4,830 |
|
824,143 |
|
|
|
|
Barrick Mining Corporation ADR |
|
17,024 |
|
779,529 |
|
|
|
|
First Majestic Silver Corp. ADR |
|
17,801 |
|
370,973 |
|
|
|
|
FMC Corp. |
|
12,388 |
|
195,730 |
|
|
|
|
Newmont Goldcorp Corp. |
|
6,026 |
|
677,021 |
|
|
|
|
Nutrien Ltd. ADR |
|
5,680 |
|
391,295 |
|
|
|
|
Sociedad Quimica y Minera de Chile SA ADR(A) |
|
7,238 |
|
556,168 |
|
|
|
|
|
|
|
|
3,794,859 |
|
|
|
|
|
|
|
|
|
|
|
5.09% |
|
REAL ESTATE |
|
|
|
|
|
|
|
|
Alexandria Real Estate Equities, Inc. REIT |
|
15,504 |
|
847,139 |
|
|
|
|
Crown Castle, Inc. REIT |
|
1,952 |
|
169,453 |
|
|
|
|
CubeSmart REIT |
|
2,573 |
|
96,565 |
|
|
|
|
Douglas Emmett, Inc. REIT |
|
22,081 |
|
233,175 |
|
|
|
|
Empire State Realty Trust REIT |
|
18,243 |
|
120,951 |
|
|
|
|
LTC Properties, Inc. REIT |
|
4,929 |
|
179,761 |
|
|
|
|
Piedmont Realty Trust, Inc. REIT |
|
23,660 |
|
199,217 |
|
|
|
|
Weyerhaeuser Co. REIT |
|
3,987 |
|
102,785 |
|
|
|
|
|
|
|
|
1,949,046 |
|
|
|
|
|
|
|
|
|
|
See Notes to Financial Statements
5
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Schedule of Investments - continuedJanuary 31, 2026 (Unaudited)
|
|
|
|
|
Shares |
|
Value |
|
|
5.17% |
|
UTILITIES |
|
|
|
|
|
|
|
|
Eversource Energy |
|
8,697 |
|
$601,224 |
|
|
|
|
Northwest Natural Holding Co. |
|
17,025 |
|
792,684 |
|
|
|
|
Portland General Electric |
|
7,710 |
|
387,427 |
|
|
|
|
The York Water Co. |
|
5,910 |
|
198,458 |
|
|
|
|
|
|
|
|
1,979,793 |
|
|
|
|
|
|
|
|
|
|
|
88.13% |
|
TOTAL COMMON STOCKS |
|
33,729,390 |
|
||
|
|
|
(Cost: $31,691,157) |
|
|
|
|
|
|
|
|
|
|
Principal |
|
Value |
|
|
6.21% |
|
US TREASURY BONDS |
|
|
|
|
|
|
|
|
US Treasury 05/15/2052 2.875% |
|
$2,253,000 |
|
$1,567,800 |
|
|
|
|
US Treasury 05/15/2054 4.625% |
|
845,000 |
|
809,407 |
|
|
|
|
|
|
|
|
|
|
|
6.21% |
|
TOTAL US TREASURY BONDS |
|
2,377,207 |
|
||
|
|
|
(Cost: $2,497,305) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
4.13% |
|
US TREASURY BILLS |
|
|
|
|
|
|
|
|
US Treasury Bill 02/05/2026 2.88%(C) |
|
1,580,000 |
|
1,579,529 |
|
|
|
|
|
|
|
|
|
|
|
4.13% |
|
TOTAL US TREASURY BILLS |
|
1,579,529 |
|
||
|
|
|
(Cost: $1,579,377) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
98.47% |
|
TOTAL INVESTMENTS |
|
37,686,126 |
|
||
|
|
|
(Cost: $35,767,839) |
|
|
|
|
|
|
1.53% |
|
Other assets, net of liabilities |
|
585,626 |
|
||
|
100.00% |
|
NET ASSETS |
|
$38,271,752 |
|
||
(A)Non-income producing.
(B)Non-voting shares.
(C)Zero coupon security. The rate shown is the yield-to-maturity on the date of January 31, 2026.
ADR - Security represented is held by the custodian in the form of American Depositary Receipts.
REIT - Real Estate Investment Trust.
See Notes to Financial Statements
6
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Statement of Assets and Liabilities
January 31, 2026 (Unaudited)
|
ASSETS |
|
|
|
|
Investments at value (cost of $35,767,839) (Note 1) |
|
$37,686,126 |
|
|
Cash |
|
549,555 |
|
|
Dividends, interest and reclaims receivable |
|
64,453 |
|
|
TOTAL ASSETS |
|
38,300,134 |
|
|
|
|
|
|
|
LIABILITIES |
|
|
|
|
Accrued advisory fees |
|
28,382 |
|
|
TOTAL LIABILITIES |
|
28,382 |
|
|
NET ASSETS |
|
$38,271,752 |
|
|
|
|
|
|
|
Net Assets Consist of: |
|
|
|
|
Paid-in capital |
|
$35,128,722 |
|
|
Distributable earnings (accumulated deficits) |
|
3,143,030 |
|
|
Net Assets |
|
$38,271,752 |
|
|
|
|
|
|
|
NET ASSET VALUE PER SHARE |
|
|
|
|
Shares Outstanding (unlimited number of shares of beneficial interest authorized without par value) |
|
1,315,000 |
|
|
Net Asset Value and Offering Price Per Share |
|
$29.10 |
|
CULTIVAR ETF
Statement of OperationsSix Months Ended January 31, 2026 (Unaudited)
See Notes to Financial Statements
7
FINANCIAL STATEMENTS | JANUARY 31, 2026
|
INVESTMENT INCOME |
|
|
|
Dividend income (net of foreign tax withheld of $4,810) |
|
$358,232 |
|
Interest income |
|
84,074 |
|
Total investment income |
|
442,306 |
|
|
|
|
|
EXPENSES |
|
|
|
Investment advisory fees (Note 2) |
|
158,318 |
|
Total expenses |
|
158,318 |
|
|
|
|
|
Net investment income (loss) |
|
283,988 |
|
|
|
|
|
REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS |
|
|
|
Net realized gain (loss) on investments(1) |
|
1,885,958 |
|
Net realized gain (loss) on foreign currency transactions |
|
1,360 |
|
Net realized gain (loss) on investments and foreign currency transactions |
|
1,887,318 |
|
|
|
|
|
Net change in unrealized appreciation (depreciation) of investments |
|
2,028,481 |
|
|
|
|
|
Net realized and unrealized gain (loss) |
|
3,915,799 |
|
|
|
|
|
INCREASE (DECREASE) IN NET ASSETS FROM OPERATIONS |
|
$4,199,787 |
(1)Includes realized gains (losses) as a result of in-kind transactions (Note 3).
CULTIVAR ETF
Statements of Changes in Net Assets
See Notes to Financial Statements
8
FINANCIAL STATEMENTS | JANUARY 31, 2026
|
|
Six Months Ended |
|
Year Ended |
|
|
|
INCREASED (DECREASE) IN NET ASSETS FROM |
|
|
|
|
|
|
|
|
|
|
|
|
|
OPERATIONS |
|
|
|
|
|
|
Net investment income (loss) |
|
$283,988 |
|
$510,595 |
|
|
Net realized gain (loss) on investments and foreign currency transactions |
|
1,887,318 |
|
555,019 |
|
|
Net change in unrealized appreciation (depreciation) ofinvestments |
|
2,028,481 |
(416,670 |
) |
|
|
Increase (decrease) in net assets from operations |
|
4,199,787 |
648,944 |
|
|
|
|
|
|
|
|
|
|
DISTRIBUTIONS TO SHAREHOLDERS |
|
|
|
|
|
|
Distributions from earnings |
|
(556,818 |
) |
(1,078,098 |
) |
|
Decrease in net assets from distributions |
|
(556,818 |
) |
(1,078,098 |
) |
|
|
|
|
|
|
|
|
CAPITAL STOCK TRANSACTIONS (NOTE 5) |
|
|
|
|
|
|
Shares sold |
|
3,341,309 |
|
3,582,188 |
|
|
Shares redeemed |
|
(1,929,516 |
) |
(2,044,231 |
) |
|
Increase (decrease) in net assets from capital stock transactions |
|
1,411,793 |
1,537,957 |
|
|
|
|
|
|
|
|
|
|
NET ASSETS |
|
|
|
|
|
|
Increase (decrease) during period |
|
5,054,762 |
|
1,108,803 |
|
|
Beginning of period |
|
33,216,990 |
32,108,187 |
|
|
|
End of period |
|
$38,271,752 |
$33,216,990 |
|
This page intentionally left blank.
CULTIVAR ETF
Selected Per Share Data Throughout Each Period
See Notes to Financial Statements
11
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Financial Highlights
See Notes to Financial Statements
10
FINANCIAL STATEMENTS | JANUARY 31, 2026
|
|
Six Months Ended |
|
Years Ended July 31, |
|
Period Ended |
|
|||||
|
|
|
2025 |
|
2024 |
|
2023 |
|
|
|||
|
Net asset value, beginning of period |
|
$26.26 |
|
$26.65 |
|
$25.44 |
|
$25.13 |
|
$25.00 |
|
|
Investment activities |
|
|
|
|
|
|
|
|
|
|
|
|
Net investment income (loss)(1) |
|
0.22 |
|
0.42 |
|
0.48 |
|
0.37 |
|
0.22 |
|
|
Net realized and unrealized gain (loss) on investments(2) |
|
3.05 |
|
0.09 |
|
1.09 |
|
1.20 |
|
(0.09 |
) |
|
Total from investment activities |
|
3.27 |
|
0.51 |
|
1.57 |
|
1.57 |
|
0.13 |
|
|
Distributions |
|
|
|
|
|
|
|
|
|
|
|
|
Net investment income |
|
(0.41 |
) |
(0.59 |
) |
(0.36 |
) |
(0.37 |
) |
- |
|
|
Net realized gain |
|
(0.02 |
) |
(0.31 |
) |
- |
(0.89 |
) |
- |
|
|
|
Total distributions |
|
(0.43 |
) |
(0.90 |
) |
(0.36 |
) |
(1.26 |
) |
- |
|
|
Net asset value, end of period |
|
$29.10 |
|
$26.26 |
|
$26.65 |
|
$25.44 |
|
$25.13 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Return(3) |
|
15.06 |
% |
2.04 |
% |
6.23 |
% |
6.81 |
% |
0.54 |
% |
|
Ratios/Supplemental Data |
|
|
|
|
|
|
|
|
|
|
|
|
Ratios to average net assets(4) |
|
|
|
|
|
|
|
|
|
|
|
|
Expenses |
|
0.87 |
% |
0.87 |
% |
0.87 |
% |
0.87 |
% |
0.87 |
% |
|
Net investment income (loss) |
|
1.56 |
% |
1.60 |
% |
1.97 |
% |
1.53 |
% |
1.39 |
% |
|
Portfolio turnover rate(5) |
|
15.58 |
% |
57.33 |
% |
42.57 |
% |
78.94 |
% |
41.27 |
% |
|
Net assets, end of period (000s) |
|
$38,272 |
|
$33,217 |
|
$32,108 |
|
$26,072 |
|
$24,506 |
|
(1)Per share amounts calculated using the average shares outstanding during the period.
(2)Realized and unrealized gains and losses per share in this caption are balancing amounts necessary to reconcile the change in net asset value per share for the period and may not reconcile with the aggregate gains and losses in the Statement of Operations due to share transactons for the period.
(3)Total return is for the period indicated and has not been annualized for periods less than one year.
(4)Ratios to average net assets have been annualized for periods less than a year.
(5)Portfolio turnover rate is for the period indicated, excludes the effect of securities received or delivered from processing in-kind creations or redemptions and has not been annualized for periods less than one year.
*The Fund commenced operations on December 22, 2021.
12
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Notes to Financial Statements
January 31, 2026 (Unaudited)
NOTE 1 - ORGANIZATION AND SIGNIFICANT ACCOUNTING POLICIES
The Cultivar ETF (the "Fund") is a non-diversified series of ETF Opportunities Trust, a Delaware statutory trust (the "Trust") which was organized on March 18, 2019 and is registered under the Investment Company Act of 1940, as amended (the "1940 Act") as an open-end management investment company. The offering of the Fund's shares is registered under the Securities Act of 1933, as amended. The Fund commenced operations on December 22, 2021.
The Fund's investment objective is to seek to achieve long-term capital appreciation.
The Fund is deemed to be an individual operating and reporting segment and is not part of a consolidated reporting entity. The objective and strategy, as outlined in the Fund's prospectus under the heading "Principal Investment Strategies," are used by Cultivar Capital, Inc. (the "Advisor")to make investment decisions, and the results of the Fund's operations, as shown in its Statement of Operations and Financial Highlights, are the information utilized for the day-to-day management of the Fund. Due to the significance of oversight and its role in the Fund's management, the Advisor's portfolio managers are deemed to be the Chief Operating Decision Maker.
The following is a summary of significant accounting policies consistently followed by the Fund. The policies are in conformity with accounting principles generally accepted in the United States of America ("GAAP"). The Fund follows the investment company accounting and reporting guidance of the Financial Accounting Standards Board ("FASB") Accounting Standards Codification Topic 946 "Financial Services - Investment Companies".
Security Valuation
The Fund records its investments at fair value. Generally, the Fund's domestic securities are valued each day at the last quoted sales price on each security's primary exchange. Securities traded or dealt in upon one or more securities exchanges for which market quotations are readily available and not subject to restrictions against resale are valued at the last quoted sales price on the primary exchange or, in the absence of a sale on the primary exchange, at the mean between the current bid and ask prices on such exchange. Securities primarily traded in the NASDAQ National Market System for which market quotations are readily available shall be valued using the NASDAQ Official Closing Price. If market quotations are not readily available, securities are valued at their fair market value as determined in good faith under procedures
13
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Notes to Financial Statements - continuedJanuary 31, 2026 (Unaudited)
approved by the Trust's Board of Trustees (the "Board"). Although the Board is ultimately responsible for fair value determinations under Rule 2a-5 of the 1940 Act, the Board has delegated day-to-day responsibility for oversight of the valuation of the Fund's assets to the Advisor as the Valuation Designee pursuant to the Fund's policies and procedures. Securities that are not traded or dealt in any securities exchange (whether domestic or foreign) and for which over-the-counter market quotations are readily available generally are valued at the last sale price or, in the absence of a sale, at the mean between the current bid and ask prices on such over-the-counter market. Generally, trading in US government securities is substantially completed each day at various times before the scheduled close of the New York Stock Exchange. The Fund values these securities using the last quoted sales price each day.
The Fund has a policy that contemplates the use of fair value pricing to determine the Net Asset Value ("NAV") per share of the Fund when market prices are unavailable as well as under special circumstances, such as: (I) if the primary market for a portfolio security suspends or limits trading or price movements of the security; and (ii) when an event occurs after the close of the exchange on which a portfolio security is principally traded, but prior to the time as of which the Fund's NAV is calculated, that is likely to have changed the value of the security.
When the Fund uses fair value pricing to determine the NAV per share of the Fund, securities will not be priced on the basis of quotations from the primary market in which they are traded, but rather may be priced by another method that the Valuation Designee believes accurately reflects fair value. Any method used will be approved by the Board and results will be monitored to evaluate accuracy. The Fund's policy is intended to result in a calculation of the Fund's NAV that fairly reflects security values as of the time of pricing.
The Fund has adopted fair valuation accounting standards that establish an authoritative definition of fair value and set out a hierarchy for measuring fair value. These standards require additional disclosures about the various inputs used to develop the measurements of fair value. These inputs are summarized in the three broad levels listed below.
Various inputs are used in determining the value of the Fund's investments. GAAP established a three-tier hierarchy of inputs to establish a classification of fair value measurements for disclosure purposes. Level 1 includes quoted prices in active markets for identical securities. Level 2 includes other significant observable market-based inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.). Level 3 includes significant
14
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Notes to Financial Statements - continuedJanuary 31, 2026 (Unaudited)
unobservable inputs (including the Fund's own assumptions in determining fair value of investments).
The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities.
The following is a summary of the level of inputs used to value the Fund's investments as of January 31, 2026:
|
|
|
Level 1 |
|
Level 2 |
|
Level 3 |
|
Total |
|
Common Stocks |
|
$33,729,390 |
|
$- |
|
$- |
|
$33,729,390 |
|
US Treasury Bonds |
|
- |
|
2,377,207 |
|
- |
|
2,377,207 |
|
US Treasury Bills |
|
- |
1,579,529 |
- |
1,579,529 |
|||
|
|
$33,729,390 |
$3,956,736 |
$- |
$37,686,126 |
Refer to the Fund's Schedule of Investments for a listing of the securities by type and sector. The Fund held no Level 3 securities at any time during the six months ended January 31, 2026.
Security Transactions and Income
Security transactions are accounted for on the trade date. The cost of securities sold is determined generally on a specific identification basis to calculate realized gains and losses from security transactions for book and tax purposes. Dividends are recorded on the ex-dividend date. Interest income is recorded on an accrual basis. Withholding taxes on foreign dividends have been provided for in accordance with the Fund's understanding of the applicable country's tax rules and rates.
Foreign Currency Translation
The books and records of the Fund are maintained in U.S. dollars. Investment valuations and other assets and liabilities initially expressed in foreign currencies are converted each business day into U.S. dollars based upon current exchange rates. Prevailing foreign exchange rates may generally be obtained at the close of the NYSE (normally, 4:00 p.m. Eastern Time). The portion of realized and unrealized gains or losses on investments due to fluctuations in foreign currency exchange rates is not separately disclosed and is included in realized and unrealized gains or losses on investments, when applicable.
15
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Notes to Financial Statements - continuedJanuary 31, 2026 (Unaudited)
Accounting Estimates
In preparing financial statements in conformity with GAAP, management makes estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures of contingent assets and liabilities at the date of the financial statements, as well as the reported amounts of investment income and expenses during the reporting period. Actual results could differ from those estimates.
Federal Income Taxes
The Fund has complied and intends to continue to comply with the requirements of the Internal Revenue Code applicable to regulated investment companies and to distribute all of its taxable income to its shareholders. The Fund also intends to distribute sufficient net investment income and net capital gains, if any, so that it will not be subject to excise tax on undistributed income and gains. Therefore, no federal income tax or excise provision is required.
Management has concluded that no liability for unrecognized tax benefits should be recorded related to uncertain tax positions taken in the Fund's tax returns. The Fund has no examinations in progress and management is not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly change in the next twelve months. Interest and penalties, if any, associated with any federal or state income tax obligations are recorded as income tax expense as incurred.
Reclassification of Capital Accounts
GAAP requires that certain components of net assets relating to permanent differences be reclassified between financial and tax reporting. For the six months ended January 31, 2026, there were no such reclassifications.
Dividends and Distributions
Dividends from net investment income, if any, are declared and paid at least annually by the Fund. The Fund distributes its net realized capital gains, if any, to shareholders annually. The Fund may also pay a special distribution at the end of a calendar year to comply with federal tax requirements. All distributions are recorded on the ex-dividend date.
16
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Notes to Financial Statements - continuedJanuary 31, 2026 (Unaudited)
Creation Units
The Fund issues and redeems shares to certain institutional investors (typically market makers or other broker-dealers) only in blocks of at least 10,000 shares known as "Creation Units." Purchasers of Creation Units ("Authorized Participants") will be required to pay to Citibank, N.A. (the "Custodian") a fixed transaction fee ("Creation Transaction Fee") in connection with creation orders that is intended to offset the transfer and other transaction costs associated with the issuance of Creation Units. The standard Creation Transaction Fee will be the same regardless of the number of Creation Units purchased by an investor on the applicable Business Day. The Creation Transaction Fee charged by the Custodian for each creation order is $300. Authorized Participants wishing to redeem shares will be required to pay to the Custodian a fixed transaction fee ("Redemption Transaction Fee") to offset the transfer and other transaction costs associated with the redemption of Creation Units. The standard Redemption Transaction Fee will be the same regardless of the number of Creation Units redeemed by an investor on the applicable Business Day. The Redemption Transaction Fee charged by the Custodian for each redemption order is $300.
Except when aggregated in Creation Units, shares are not redeemable securities. Shares of the Fund may only be purchased or redeemed by Authorized Participants. An Authorized Participant is either (i) a broker-dealer or other participant in the clearing process through the Continuous Net Settlement System of the National Securities Clearing Corporation or (ii) a Depository Trust Company ("DTC") participant and, in each case, must have executed an agreement with the Fund's principal underwriter (the "Distributor") with respect to creations and redemptions of Creation Units ("Participation Agreement"). Most retail investors will not qualify as Authorized Participants or have the resources to buy and sell whole Creation Units. Therefore, they will be unable to purchase or redeem the shares directly from the Fund. Rather, most retail investors will purchase shares in the secondary market with the assistance of a broker and will be subject to customary brokerage commissions or fees. The following table discloses the Creation Unit breakdown based on the NAV as of January 31, 2026:
|
|
|
Creation Unit Shares |
|
Creation Transaction Fee |
|
Value |
|
Cultivar ETF |
|
10,000 |
|
$300 |
|
$291,000 |
To the extent contemplated by a participant agreement, in the event an Authorized Participant has submitted a redemption request in proper form
17
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Notes to Financial Statements - continuedJanuary 31, 2026 (Unaudited)
but is unable to transfer all or part of the shares comprising a Creation Unit to be redeemed to the Distributor, on behalf of the Fund, by the time as set forth in a participant agreement, the Distributor may nonetheless accept the redemption request in reliance on the undertaking by the Authorized Participant to deliver the missing shares as soon as possible, which undertaking is secured by the Authorized Participant's delivery and maintenance of collateral equal to a percentage of the value of the missing shares as specified in the participant agreement. A participant agreement may permit the Fund to use such collateral to purchase the missing shares, and could subject an Authorized Participant to liability for any shortfall between the cost of the Fund acquiring such shares and the value of the collateral. Amounts are disclosed as Segregated Cash Balance from Authorized Participants for Deposit Securities and Collateral Payable upon Return of Deposit Securities on the Statement of Assets and Liabilities, when applicable.
Officers and Trustees Indemnification
Under the Trust's organizational documents, its officers and trustees are indemnified against certain liabilities arising out of the performance of their duties to the Fund. In addition, in the normal course of business, the Fund enters into contracts with its vendors and others that provide for general indemnifications. The Fund's maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Fund. However, based on experience, the Fund expects that the risk of loss will be remote.
NOTE 2 - INVESTMENT ADVISORY AND DISTRIBUTION AGREEMENTS AND OTHER TRANSACTIONS WITH AFFILIATES
The Advisor currently provides investment advisory services pursuant to an investment advisory agreement (the "Advisory Agreement"). Under the terms of the Advisory Agreement, the Advisor is responsible for the day-to-day management of the Fund's investments. The Advisor also: (i) furnishes the Fund with office space and certain administrative services; (ii) provides guidance and policy direction in connection with its daily management of the Fund's assets, subject to the authority of the Board; and (iii) is responsible for oversight of the Fund's sub-advisor. Under the Advisory Agreement, the Advisor has agreed, at its own expense and without reimbursement from the Fund, to pay all expenses of the Fund, except for: the fee paid to the Advisor pursuant to the Investment Advisory Agreement, interest expenses, taxes, acquired fund fees and expenses, brokerage commissions and any other portfolio transaction related expenses and fees arising out of transactions effected on behalf of the Fund,
18
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Notes to Financial Statements - continuedJanuary 31, 2026 (Unaudited)
credit facility fees and expenses, including interest expenses, and litigation and indemnification expenses and other extraordinary expenses not incurred in the ordinary course of the Fund's business.
For its services with respect to the Fund, the Advisor is entitled to receive an annual advisory fee, calculated daily and payable monthly as a percentage of the Fund's average daily net assets, at the rate of 0.87%.
The Advisor has retained Tidal Investments, LLC (the "Sub-Advisor"), to serve as sub-advisor for the Fund. Pursuant to an Investment Sub-Advisory Agreement between the Advisor and the Sub-Advisor (the "Sub-Advisory Agreement"), the Sub-Advisor is responsible for the day-to-day management of the Fund's trading process, which includes Creation and/or Redemption basket processing. The Sub-Advisor does not select investments for the Fund's portfolio.
For its services, the Sub-Advisor is paid a fee by the Advisor of 0.04%, which is calculated daily and paid monthly, based on the Fund's average daily net assets, subject to a minimum of $25,000 per year.
Fund Administrator
Commonwealth Fund Services, Inc. ("CFS") acts as the Fund's administrator. As administrator, CFS supervises all aspects of the operations of the Fund except those performed by the Advisor and the Sub-Advisor. For its services, fees to CFS are computed daily and paid monthly based on the average daily net assets of the Fund. The Advisor pays these fees.
Custodian
Citibank,N.A. serves as the Fund's Custodian pursuant to a Global Custodial and Agency Services Agreement. For its services, Citibank, N.A. is entitled to a fee. The Advisor pays these fees monthly.
Fund Accountant and Transfer Agent
Citi Fund Services, Ohio, Inc. serves as the Fund's Fund Accountant and Transfer Agent pursuant to a Services Agreement. For its services, Citi Fund Services, Ohio, Inc. is entitled to a fee. The Advisor pays these fees monthly.
19
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Notes to Financial Statements - continuedJanuary 31, 2026 (Unaudited)
Distributor
Foreside Fund Services, LLC serves as the Fund's principal underwriter pursuant to an ETF Distribution Agreement. For its services, Foreside Fund Services, LLC is entitled to a fee. The Advisor pays these fees monthly.
Trustees and Officers
Each Trustee who is not an "interested person" of the Trust receives compensation for their services to the Fund. Each Trustee receives an annual retainer fee, paid quarterly. Trustees are reimbursed for any out-of-pocket expenses incurred in connection with attendance at meetings. The Advisor pays these costs.
Certain officers of the Trust are also officers and/or directors of CFS. Additionally, Practus, LLP serves as legal counsel to the Trust. John H. Lively, Secretary of the Trust, is Managing Partner of Practus LLP. J. Stephen King, Jr. and Robert J. Rhatigan, each an Assistant Secretary of the Trust, are Partners of Practus LLP. None of the officers and/or directors of CFS, Mr. Lively, Mr. King or Mr. Rhatigan receives any special compensation from the Trust or the Fund for serving as officers of the Trust.
The Fund's Chief Compliance Officer and Assistant Chief Compliance Officer are not compensated directly by the Fund for their service. However, the Assistant Chief Compliance Officer is the Managing Member of Watermark Solutions, LLC ("Watermark"), which provides certain compliance services to the Fund, including the provision of the Chief Compliance Officer and the Assistant Chief Compliance Officer. The Chief Compliance Officer is the Managing Member of Fit Compliance, LLC, which has been retained by Watermark to provide the Chief Compliance Officer's services. The Advisor pays these fees monthly.
NOTE 3 - INVESTMENTS
The costs of purchases and proceeds from the sales of securities other than in-kind transactions, short-term notes and US Government securities for the six months ended January 31, 2026, were as follows:
|
Purchases |
|
Sales |
|
$5,318,650 |
|
$5,225,044 |
20
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Notes to Financial Statements - continuedJanuary 31, 2026 (Unaudited)
The costs of purchases and proceeds from the sales of in-kind transactions associated with creations and redemptions for the six months ended January 31, 2026, were as follows:
|
Purchases |
|
Sales |
|
Realized Gains |
|
$2,834,081 |
|
$1,800,818 |
|
$732,070 |
The costs of purchases and proceeds from the sales of long-term Government securities for the six months ended January 31, 2026, were as follows:
|
Purchases |
|
Sales |
|
$72,806 |
|
$ - |
NOTE 4 - DISTRIBUTIONS TO SHAREHOLDERS AND TAX COMPONENTS OF CAPITAL
Distributions are determined on a tax basis and may differ from net investment income and realized capital gains for financial reporting purposes. Differences may be permanent or temporary. Permanent differences are reclassified among capital accounts in the financial statements to reflect their tax character. Temporary differences arise when certain items of income, expense, gain or loss are recognized in different periods for financial statement and tax purposes; these differences will reverse at some time in the future. Differences in classification may also result from the treatment of short-term gains as ordinary income for tax purposes.
The tax character of distributions paid during the six months ended January 31, 2026 and the year ended July 31, 2025, were as follows:
|
|
Six Months Ended |
|
Year Ended |
|
|
Distributions paid from: |
|
|
|
|
|
Ordinary income |
|
$527,945 |
|
$830,825 |
|
Realized gains |
|
28,873 |
247,273 |
|
|
|
$556,818 |
$1,078,098 |
21
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Notes to Financial Statements - continuedJanuary 31, 2026 (Unaudited)
As of January 31, 2026, the components of distributable earnings (accumulated deficits) on a tax basis were as follows:
|
Accumulated undistributed net investment income (loss) |
|
$21,634 |
|
Accumulated net realized gain (loss) on investments |
|
1,203,109 |
|
Net unrealized appreciation (depreciation) of investments |
|
1,918,287 |
|
|
$3,143,030 |
Cost of securities for Federal Income tax purposes and the related tax-based net unrealized appreciation (depreciation) consist of:
|
Cost |
|
Gross Unrealized Appreciation |
|
Gross Unrealized Depreciation |
|
Total Unrealized Appreciation (Depreciation) |
|
$35,767,839 |
|
$5,728,025 |
|
$(3,809,738) |
|
$1,918,287 |
NOTE 5 - TRANSACTIONS IN SHARES OF BENEFICIAL INTEREST
Shares of the Fund are listed for trading on the Cboe BZX Exchange (the "Exchange") and trade at market prices rather than at NAV. Shares of the Fund may trade at a price that is greater than, at, or less than NAV. The Fund will issue and redeem shares at NAV only in blocks of 10,000 shares (each block of shares is called a "Creation Unit"). Creation Units are issued and redeemed for cash and/or in-kind for securities. Individual shares may only be purchased and sold in secondary market transactions through brokers. Except when aggregated in Creation Units, the shares are not redeemable securities of the Fund.
All orders to create Creation Units must be placed with the Fund's distributor or transfer agent either (1) through the Continuous Net Settlement System of the NSCC ("Clearing Process"), a clearing agency that is registered with the U.S. Securities and Exchange Commission ("SEC"), by a "Participating Party," i.e., a broker-dealer or other participant in the Clearing Process; or (2) outside the Clearing Process by a DTC Participant. In each case, the Participating Party or the DTC Participant must have executed an agreement with the Distributor with respect to creations and redemptions of Creation Units ("Participation Agreement"); such parties are collectively referred to as "APs" or "Authorized Participants." All Fund shares, whether created through or outside the Clearing Process, will be entered on the records of DTC for the account of a DTC Participant.
22
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Notes to Financial Statements - continuedJanuary 31, 2026 (Unaudited)
Shares of beneficial interest transactions for the Fund were:
|
|
|
Six Months Ended |
|
Year Ended July 31, 2025 |
|
|
Shares sold |
|
120,000 |
|
140,000 |
|
|
Shares redeemed |
|
(70,000 |
) |
(80,000 |
) |
|
Net increase (decrease) |
|
50,000 |
60,000 |
|
NOTE 6 - RISKS OF INVESTING IN THE FUND
It is important that you closely review and understand the risks of investing in the Fund. The Fund's NAV and investment return will fluctuate based upon changes in the value of its portfolio securities. You could lose money on your investment in the Fund, and the Fund could underperform other investments. There is no guarantee that the Fund will meet its investment objective. An investment in the Fund is not a deposit of a bank and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. A complete description of the principal risks is included in the Fund's prospectus under the heading "Principal Risks."
NOTE 7 - SUBSEQUENT EVENTS
Management has evaluated all transactions and events subsequent to the date of the Statement of Assets and Liabilities through the date on which these financial statements were issued. Except as already included in the notes to these financial statements, no additional items require disclosure.
23
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Supplemental Information (Unaudited)
Changes in and disagreements with accountants for open-end management investment companies.
Not applicable.
Proxy disclosures for open-end management investment companies.
Not applicable.
Remuneration paid to Directors, Officers, and others of open-end management investment companies.
Because Cultivar Capital, Inc. (the "Advisor") has agreed in the Investment Advisory Agreement to cover all operating expenses of the Funds, subject to certain exclusions as provided for therein, the Advisor pays the compensation to each Independent Trustee and the Chief Compliance Officer for services to the Fund from the Advisor's management fees.
Statement Regarding Basis for Approval of Investment Advisory Contract.
InvestmentAdvisory Agreement and Sub-Advisory Agreement Renewal and Approval Cultivar ETF
At a meeting held on September 23-24, 2025 and on October 29, 2025 (each a "Meeting"), the Board of Trustees (the "Board") of the ETF Opportunities Trust (the "Trust") considered the approval of the continuation of the Amended and Restated Investment Advisory Agreement (the "Advisory Agreement") between the Trust and Cultivar Capital, Inc. ("Cultivar") and the Amended and Restated DelegatedServices Sub-Advisory Agreement (the "Sub-Advisory Agreement") between Cultivar and Tidal Investments,LLC ("Tidal"), each with respect to the Cultivar ETF. TheBoard discussed the arrangements between Cultivar and the Trust and Cultivarand Tidal with respect to the Cultivar ETF. The Boardreflected on its discussions with the representatives from Cultivar earlier in the Meeting regarding the manner in which the Cultivar ETF was to be managed and the roles and responsibilities of Cultivar and Tidal under the Advisory Agreement and the Sub-Advisory Agreement (collectively, the "Cultivar Advisory Agreements").
The Trustees reviewed a memorandum from Trust Counsel that addressed the Trustees' duties when considering the continuation of the Cultivar Advisory Agreementsand the responses of Cultivar and Tidal to requests for information from Trust Counsel on behalf of the Board. A copy of this memorandum had been provided tothe Trustees in advance of the Meeting. The Trustees also
24
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Supplemental Information (Unaudited) - continued
reviewed the responsesof Cultivar and Tidal to requests for information from Trust Counselon behalf of the Board and noted that the responses includeda copy of financial information for Cultivar and Tidal, anexpense comparison analysis for the Cultivar ETF and comparable ETFs, andthe Cultivar Advisory Agreements. The Trustees discussed the types of information and factors that should be considered by the Board in order to make an informed decision regarding the approval of the Cultivar Advisory Agreements, including the following material factors: (i) the nature,extent, and quality of the services provided by Cultivar andTidal; (ii) the investment performance of the Cultivar ETF and Cultivar; (iii) the costs of the services to be provided and profits to be realized by Cultivar and Tidal from their relationship with the Cultivar ETF; (iv) the extent to which economies of scale would be realized if the Cultivar ETF grows and whether advisory fee levels reflect those economies of scale for the benefit of its shareholders; and (v) possible conflicts of interest and other benefits.
In assessing thesefactors and reaching its decisions, the Board took into considerationinformation specifically prepared or presented at the Meeting. The Board requested or was provided with information and reports relevant to the approval of the Cultivar Advisory Agreements, including: (i) information regarding the services and support to be provided by Cultivar and Tidal to the Cultivar ETF and its shareholders; (ii) presentations by management of Cultivar and Tidal addressingthe investment philosophy, investment strategy, personnel and operations to be utilizedin managing the Cultivar ETF; (iii) informationpertaining to the compliance structure of Cultivar and Tidal; (iv) disclosure information contained in the Cultivar ETF's registration statement and Cultivar's and Tidal's Forms ADV and/or their policies and procedures; and (v) the memorandum from Trust Counsel that summarized the fiduciary duties and responsibilities of the Board in reviewing and approving theCultivar Advisory Agreements, including the material factors set forth above and the types of information included in each factor that should be considered by the Board in order to make an informed decision.
The Board considered that it also requested and receivedvarious informational materials including, without limitation: (i) documents containing information about Cultivar and Tidal, including financial information, information on personnel and the servicesto be provided by Cultivar and Tidal to the Cultivar ETF, each firm's compliance program, information on any current legal matters, and other general information; (ii) expenses of the Cultivar ETF and comparative expense and performance information for other ETFs with strategies similar to the Cultivar
25
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Supplemental Information (Unaudited) - continued
ETF prepared by an independent third party; (iii) the anticipated effectof size on the Cultivar ETF's performance and expenses; and (iv) benefits anticipated to be realized by Cultivar and Tidal from their relationship with the Cultivar ETF.
TheBoard did not identify any particular information that was mostrelevant to its consideration to approve the Cultivar Advisory Agreements and each Trustee may have afforded different weight to the various factors. In deciding whether toapprove the Cultivar Advisory Agreements, the Trustees considered numerous factors, including:
The nature, extent, and quality of the services provided by Cultivar and Tidal.
In this regard, the Board considered the responsibilities of Cultivarand Tidal under their respective Cultivar Advisory Agreement. The Board reviewed the services provided by Cultivar and by Tidal to the Cultivar ETF, including, without limitation, Cultivar's process for formulating investment recommendations and the processes of both Cultivar and Tidal for assuring compliance with the Cultivar ETF's investment objectives and limitations; Tidal's processes for trade execution and broker-dealer selection for portfolio transactions; the coordinationof services by Cultivar for the Cultivar ETF among the service providers; and the anticipated efforts of Cultivar to promote the Cultivar ETF and grow its assets. The Board considered: the staffing, personnel, and methods of operating of Cultivar and Tidal; the education and experience of their personnel; and information provided regarding their compliance programs, policies and procedures. The Board considered the methods utilized by Cultivar in supervising Tidalas a sub-adviser to the Cultivar ETF and the relationshipbetween Cultivar and Tidal. After reviewing the foregoing and further informationfrom Cultivar and Tidal, the Board concluded that the quality,extent, and nature of the services provided by Cultivar and Tidal were satisfactory and adequate for the Cultivar ETF.
The investment performance of the Cultivar ETF
The Board reviewed the Cultivar ETF's performance. In considering its investment performance, the Board reviewed reports prepared by Broadridge Financial Solutions ("Broadridge"), and compared the performance of the Cultivar ETF with the performance of its benchmark index, the Russell 3000 Index ("Russell 3000"), the funds in its Morningstar category, the Mid-Cap Value Funds category (its "Category"), and a peer group selected from its Category by Broadridge, consisting of 13 funds (its "Peer Group"). The Board noted that the Cultivar ETF had underperformed the Russell 3000, and the medians of its Category and Peer Group, for the one-year and three-year periods ended June 30, 2025.
26
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Supplemental Information (Unaudited) - continued
In discussing the Cultivar ETF's underperformance, the Board noted that, as explained by the Adviser, although the Cultivar ETF is in the Mid-Cap Value Funds category, its strategy is more of an all-cap strategy that generally includes more small-cap stocks which affects how the Cultivar ETF performs compared to its Peer Group and Category.
After a detailed discussion of the Cultivar ETF's performance, the Board concluded, in light of all the facts and circumstances, that the investment performance of the Cultivar ETF's performance was satisfactory, but noted that it would continue to monitor the Cultivar ETF's performance.
The costs of services tobe provided and profits to be realized by Cultivar andTidal from their relationship with the Cultivar ETF
In this regard, the Board considered the financial condition of Cultivar and the level of commitment to the Cultivar ETF by Cultivar. The Board also considered the assets and expenses of the Cultivar ETF, including the nature and frequency of advisory and sub-advisory fee payments. The Board noted the information on profitability provided by Cultivar and Tidal. The Trustees considered Cultivar ETF's unitary fee structure and compared the unitary fee of the Cultivar ETF to the fees of the medians of its Category and Peer Group. The Trustees noted that the Cultivar ETF's gross and net expense ratio and gross and net advisory fee were each higher than the medians of its Category and Peer Group, but that the Cultivar ETF's expense ratios and advisory fees were within the range of other funds in its Category and Peer Group. The Board noted that Cultivar does not manage separate accounts with strategies similar to the Cultivar ETF. The Trustees also considered the split of the advisory fees paid to Cultivar versus those paid to Tidal and the respective services provided by each to the Cultivar ETF. The Board also considered that Tidal represented that its fee for sub-advising the Cultivar ETF is consistent with the range of fees charged to its other clients.
After further consideration, the Board concluded that the profitability of Cultivar and Tidal was not unreasonable, and the fees to be paid to Cultivar (who in turn pays Tidal) were within an acceptable range in light of the services to be rendered by Cultivar and Tidal.
27
FINANCIAL STATEMENTS | JANUARY 31, 2026
CULTIVAR ETF
Supplemental Information (Unaudited) - continued
The extent to which economies of scale wouldbe realized as the Cultivar ETF grows and whether advisory fee levels reflect these economies of scale for the benefit of the Cultivar ETF's shareholders.
The Trustees considered that, at the Cultivar ETF's current size, it was not anticipated that Cultivar or Tidal would achieve economies of scale with respect to the services provided to the Cultivar ETF. They noted that the unitary fee structure of the Cultivar ETF limits shareholders' exposure to fee and expense increases.
Possible conflicts of interest and other benefits.
In evaluating the possibility for conflicts of interest, the Board considered such matters as: the experience and ability of the advisory and sub-advisory personnel assigned to the Cultivar ETF; the basis of decisions to buy or sell securities for the Cultivar ETF; the substance and administration of the Code of Ethics and other relevant policies of Cultivar andTidal. The Board noted that Cultivar and Tidal have each represented that it does not utilize soft dollars or commission recapture with regard to the Cultivar ETF. The Board also considered potential benefits for Cultivar and Tidal in managing the Cultivar ETF. Following further consideration and discussion, the Board concluded that the standards and practices of Cultivar and Tidal relating to the identification and mitigation of potential conflicts of interest, as well as thebenefits to be derived by each of Cultivar and Tidalfrom managing the Cultivar ETF were satisfactory.
After additional consideration of the factors delineated in the memorandum provided by Trust Counsel and further discussion and careful review by the Trustees, the Board determined that the compensation payable under eachCultivar Advisory Agreement was fair, reasonable and within a rangeof what could have been negotiated at arms-length in light of all the surrounding circumstances, and approved the continuation of the Cultivar Advisory Agreements for the Cultivar ETF.
| ITEM 8. | CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES. |
Not applicable.
| ITEM 9. | PROXY DISCLOSURES FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES. |
Not applicable.
| ITEM 10. | REMUNERATION PAID TO DIRECTORS, OFFICERS, AND OTHERS OF OPEN-END MANAGEMENT INVESTMENT COMPANIES. |
Reference Item 7 which includes renumeration paid to the Trustees and Officers in the Supplemental Information.
| ITEM 11. | STATEMENT REGARDING BASIS FOR APPROVAL OF INVESTMENT ADVISORY CONTRACT. |
Reference Item 7 which includes investment advisory contract renewal in the Supplemental Information.
| ITEM 12. | DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES. |
Not applicable to this Registrant because it is not a closed-end management investment company.
| ITEM 13. | PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES. |
Not applicable to this Registrant because it is not a closed-end management investment company.
| ITEM 14. | PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS. |
Not applicable to this Registrant because it is not a closed-end management investment company.
| ITEM 15. | SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS. |
There have been no material changes to the procedures by which shareholders may recommend nominees to the registrant's board of trustees.
| ITEM 16. | CONTROLS AND PROCEDURES. |
(a) The registrant's principal executive and principal financial officers, or persons performing similar functions, have concluded that the registrant's disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940, as amended (the "1940 Act") (17 CFR 270.30a-3(c))) are effective, as of a date within 90 days of the filing date of the report that includes the disclosure required by this paragraph, based on their evaluation of these controls and procedures required by Rule 30a-3(b) under the 1940 Act (17 CFR 270.30a-3(b)) and Rules 13a-15(b) or 15d-15(b) under the Securities Exchange Act of 1934, as amended (17 CFR 240.13a-15(b) or 240.15d- 15(b)).
(b) There were no changes in the registrant's internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act (17 CFR 270.30a-3(d)) that occurred during the period covered by this report that have materially affected, or are reasonably likely to materially affect, the registrant's internal control over financial reporting.
| ITEM 17. | DISCLOSURE OF SECURITIES LENDING ACTIVITIES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES. |
Not applicable to this Registrant because it is not a closed-end management investment company.
| ITEM 18. | RECOVERY OF ERRONEOUSLY AWARDED COMPENSATION. |
Not applicable.
| ITEM 19. | EXHIBITS. |
| (a)(1) | Code of Ethics in response to Item 2 of this Form N-CSR - Not applicable. |
| (a)(2) | Any policy required by the listing standards adopted pursuant to Rule 10D-1 under the Exchange Act of 1934 - Not applicable. |
| (a)(3) | Certifications pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto. |
| (a)(3)(1) | Any written solicitation to purchase securities under Rule 23c-1 under the Investment Company Act of 1940 - Not applicable. |
| (a)(3)(2) | Change in the registrant's independent public accountant - Not applicable. |
| (b) | Certifications pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 are attached hereto. |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
Registrant: ETF Opportunities Trust
| By (Signature and Title)*: | /s/ Karen Shupe |
|
Karen Shupe Principal Executive Officer |
|
| Date: April 6, 2026 |
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.
| By (Signature and Title)*: | /s/ Karen Shupe |
|
Karen Shupe Principal Executive Officer |
|
| Date: April 6, 2026 | |
| By (Signature and Title)*: | /s/ Ann MacDonald |
|
Ann MacDonald Principal Financial Officer |
|
| Date: April 6, 2026 |
* Print the name and title of each signing officer under his or her signature.