ETF Opportunities Trust

09/19/2024 | Press release | Distributed by Public on 09/19/2024 14:19

Amendment Semi Annual Report by Investment Company Form N CSRS/A

af-financials_063024

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM N-CSR

CERTIFIED SHAREHOLDER REPORT OF REGISTERED

MANAGEMENT INVESTMENT COMPANIES

Investment Company Act file number: 811-23439
Exact name of registrant as specified in charter: ETF Opportunities Trust
Address of principal executive offices:

8730 Stony Point Parkway,

Suite 205

Richmond, VA 23235

Name and address of agent for service

The Corporation Trust Co.,

Corporation Trust Center,

1209 Orange St.,

Wilmington, DE 19801

With Copy to:

Practus, LLP

11300 Tomahawk Creek Parkway,

Suite 310

Leawood, KS 66211

Registrant's telephone number, including area code: (804) 267-7400
Date of fiscal year end: December 31
Date of reporting period: June 30, 2024
Applied Finance Valuation Large Cap ETF


EXPLANATORY NOTE

The Registrant is filing this amendment to its Form N-CSRS for the reporting period ended June 30, 2024, originally filed with the Securities and Exchange Commission on September 9, 2024 (Accession Number 0001999371-24-011685). The sole purpose of this amendment is to correct Item 11. Statement Regarding Basis for Approval of Investment Advisory Contract. Except as set forth above, this amendment does not amend, update or change any other items or disclosures found in the original Form N-CSR filing.

ITEM 1.(a). Reports to Stockholders.

Applied Finance Valuation Large Cap ETFTailored Shareholder Report

semi-annualShareholder ReportJune 30, 2024

Applied Finance Valuation Large Cap ETF

ticker:VSLU(Listed on NYSE Arca)

This semi-annual shareholder reportcontains important information about the Applied Finance Valuation Large Cap ETFfor the period of January 1, 2024 to June 30, 2024. You can find additional information about the Fund at https://appliedfinancefunds.com/ETF/InvestorResources. You can also contact us at (833) 356-0909. Distributed by Foreside Fund Services, LLC.

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

Applied Finance Valuation Large Cap ETF

$ 26.15

0.49 %¹

¹ Annualized

What did the Fund invest in?

(% of Net Assets as ofJune 30, 2024)

Sector Breakdown

Top Ten Holdings

Nvidia Corp.

8.4 %

Apple, Inc.

8.0 %

Alphabet, Inc. Class A

6.3 %

Microsoft Corp.

6.0 %

Mastercard, Inc. Class A

4.7 %

Meta Platforms, Inc.

4.0 %

Amazon.com, Inc.

3.7 %

Broadcom, Inc.

3.5 %

Visa, Inc. Class A

3.0 %

Merck & Company, Inc.

2.2 %

How has the Fund changed?

CHANGES TO ANNUAL AND SEMI-ANNUAL REPORTSThe Securities and Exchange Commission (SEC) has adopted rule and form amendments which have resulted in changes to the design and delivery of Annual and Semi-Annual Fund Reports (Reports). Reports are now streamlined to highlight key information. Certain information previously included in Reports, including financial statements, no longer appear in the Reports but will be available online within the Semi-Annual and Annual Financials and Other Information, delivered free of charge to shareholders upon request, and filed with the SEC.

For additional information about the Fund; including its prospectus, financial information, holdings and proxy information, visithttps://appliedfinancefunds.com/ETF/InvestorResources .

Key Fund Statistics

(as ofJune 30, 2024)

Net Assets (Millions)

$ 167.68

Number of Holdings

307

Portfolio Turnover Rate

16.70 %

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

For the Six Months Ended June 30, 2024 (unaudited)

Applied Finance Valuation Large Cap ETF

1

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Schedule of InvestmentsJune 30, 2024 (unaudited)

See Notes to Financial Statements

Security Description

Shares

Value

99.52%

COMMON STOCKS

12.51%

COMMUNICATION SERVICES

Alphabet, Inc. Class A

58,056

$

10,574,900

AT&T, Inc.

22,129

422,885

Charter Communications, Inc.(A)

1,266

378,483

Comcast Corp. Class A

9,172

359,176

Electronic Arts, Inc.

724

100,875

Fox Corp. Class A

3,394

116,652

Match Group, Inc.(A)

3,270

99,343

Meta Platforms, Inc.

13,447

6,780,246

Netflix, Inc.(A)

611

412,352

Omnicom Group, Inc.

2,245

201,377

The Interpublic Group

2,201

64,027

T-Mobile US, Inc.

4,618

813,599

Verizon Communications, Inc.

15,918

656,458

20,980,373

10.49%

CONSUMER DISCRETIONARY

Amazon.com, Inc.(A)

31,876

6,160,037

Autozone, Inc.(A)

248

735,097

Bath & Body Works, Inc.

1,386

54,123

Best Buy Co., Inc.

1,077

90,780

Booking Holdings, Inc.

281

1,113,182

Borg-Warner, Inc.

1,689

54,453

Caesars Entertainment, Inc.(A)

691

27,460

CarMax, Inc.(A)

250

18,335

Carnival Corporation ADR(A)

3,586

67,130

DR Horton, Inc.

2,069

291,584

Darden Restaurants, Inc.

248

37,527

Deckers Outdoor Corp.(A)

50

48,398

Domino's Pizza, Inc.

506

261,263

eBay, Inc.

2,055

110,395

Etsy, Inc.(A)

727

42,878

Expedia Group, Inc.(A)

651

82,019

Garmin Ltd. ADR

613

99,870

General Motors Co.

7,118

330,702

Genuine Parts Co.

824

113,976

Hasbro, Inc.

1,895

110,858

Hilton Worldwide Holdings, Inc.

3,640

794,248

Home Depot, Inc.

5,050

1,738,412

Lennar Corp.

662

99,214

2

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Schedule of Investments - continuedJune 30, 2024 (unaudited)

See Notes to Financial Statements

Security Description

Shares

Value

Lowe's Companies, Inc.

4,401

$

970,244

Lululemon Athletica, Inc. ADR(A)

487

145,467

Marriott International Class A

2,284

552,203

McDonald's Corp.

3,199

815,233

MGM Resorts International(A)

707

31,419

Mohawk Industries, Inc.(A)

210

23,854

NIKE, Inc.

4,242

319,720

NVR, Inc.(A)

29

220,068

O'Reilly Automotive, Inc.(A)

894

944,118

Polo Ralph Lauren Corp.

11

1,926

Pool Corp.

77

23,664

Pulte Group, Inc.

2,045

225,155

Royal Caribbean Cruises ADR(A)

1,035

165,010

Tapestry, Inc.

1,259

53,873

Tractor Supply Co.

430

116,100

Ulta Beauty, Inc.(A)

235

90,679

Yum! Brands, Inc.

3,015

399,367

17,580,041

5.40%

CONSUMER STAPLES

Altria Group, Inc.

8,510

387,631

Archer-Daniels-Midland Co.

2,665

161,099

Bunge Global Shares ADR

988

105,489

Campbell Soup Co.

462

20,878

Church & Dwight Co.

866

89,787

The Coca-Cola Co.

15,434

982,374

Conagra Brands, Inc.

240

6,821

Constellation Brands, Inc.

868

223,319

Dollar General Corp.

1,918

253,617

Dollar Tree, Inc.(A)

1,100

117,447

General Mills, Inc.

2,468

156,126

Hormel Foods Corp.

466

14,208

Kellanova

1,024

59,064

Kenvue, Inc.

8,564

155,694

Keurig Dr Pepper, Inc.

4,446

148,496

The Kraft Heinz Co.

4,015

129,363

Kroger Co.

2,898

144,697

McCormick & Co., Inc.

436

30,930

Mondelez International Inc. Class A

4,697

307,372

Monster Beverage Corp.(A)

3,708

185,215

PepsiCo, Inc.

4,286

706,890

Philip Morris International, Inc.

10,019

1,015,225

3

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Schedule of Investments - continuedJune 30, 2024 (unaudited)

See Notes to Financial Statements

Security Description

Shares

Value

The Procter & Gamble Co.

7,450

$

1,228,654

Target Corp.

1,517

224,577

The Hershey Company

1,267

232,913

The JM Smucker Co.

258

28,132

Walmart, Inc.

28,687

1,942,397

9,058,415

3.39%

ENERGY

APA Corp.

3,187

93,825

Chevron Corp.

6,515

1,019,076

ConocoPhillips

4,268

488,174

Coterra Energy, Inc.

3,243

86,491

Devon Energy Corp.

3,002

142,295

Diamondback Energy, Inc.

920

184,175

EOG Resources, Inc.

2,309

290,634

Exxon Mobil Corp.

14,832

1,707,460

Halliburton Co.

3,206

108,299

Kinder Morgan, Inc.

3,412

67,796

Marathon Oil Corp.

2,662

76,320

Marathon Petroleum Corp.

2,918

506,215

Phillips 66

2,219

313,256

Targa Resources Corp.

831

107,016

Valero Energy Corp.

3,105

486,740

5,677,772

11.73%

FINANCIALS

Aflac, Inc.

1,866

166,652

Aon plc ADR

3,644

1,069,806

Arch Capital Group Ltd. ADR(A)

1,300

131,157

Assurant, Inc.

10

1,663

CBOE Global Markets, Inc.

727

123,634

Chubb Ltd. ADR

819

208,911

Comerica, Inc.

516

26,337

Corpay, Inc.(A)

1,201

319,958

FactSet Research Systems, Inc.

241

98,393

Fidelity National Information Services, Inc.

2,392

180,261

Fiserv, Inc.(A)

6,644

990,222

Globe Life, Inc.

455

37,437

Hartford Financial Services Group, Inc.

709

71,283

Jack Henry & Associates, Inc.

238

39,513

JPMorgan Chase & Co.

5,218

1,055,393

Marsh & McLennan Cos, Inc.

1,793

377,821

4

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Schedule of Investments - continuedJune 30, 2024 (unaudited)

See Notes to Financial Statements

Security Description

Shares

Value

Mastercard, Inc. Class A

17,770

$

7,839,413

MetLife, Inc.

3,254

228,398

Moody's Corporation

998

420,088

Morgan Stanley

446

43,347

Northern Trust Corp.

233

19,567

PayPal Holdings, Inc.(A)

5,436

315,451

The PNC Financial Services Group, Inc.

441

68,567

Principal Financial Group, Inc.

399

31,302

Regions Financial Corp.

3,165

63,427

S&P 500 Global, Inc.

1,094

487,924

T Rowe Price Group, Inc.

484

55,810

The Travelers Companies, Inc.

251

51,038

US Bancorp

1,105

43,869

Visa, Inc. Class A

19,156

5,027,875

Willis Towers Watson plc ADR

23

6,029

W. R. Berkley Corp.

812

63,807

19,664,353

13.57%

HEALTH CARE

Abbott Laboratories

5,260

546,567

Abbvie, Inc.

19,138

3,282,550

Agilent Technologies, Inc.

1,330

172,408

Bio-Rad Laboratories, Inc.(A)

53

14,475

Bristol-Myers Squibb Co.

25,829

1,072,678

Cardinal Health, Inc.

911

89,569

Cencora, Inc.

2,710

610,563

Centene Corp.(A)

997

66,101

The Cigna Group

444

146,773

Danaher Corp.

499

124,675

DaVita, Inc.(A)

845

117,092

Edwards Lifescience Corp.(A)

2,455

226,768

Elevance Health, Inc.

417

225,956

GE Healthcare Technologies

1,454

113,296

Gilead Sciences, Inc.

15,998

1,097,623

HCA Healthcare, Inc.

1,642

527,542

Hologic, Inc.(A)

701

52,049

Humana, Inc.

239

89,302

Idexx Laboratories, Inc.(A)

400

194,880

Incyte Corp.(A)

1,900

115,178

Insulet Corp.(A)

218

43,992

Iqvia Holdings, Inc.(A)

2,422

512,108

Johnson & Johnson

21,129

3,088,215

5

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Schedule of Investments - continuedJune 30, 2024 (unaudited)

See Notes to Financial Statements

Security Description

Shares

Value

Labcorp Holdings, Inc.

255

$

51,895

McKesson Corp.

1,837

1,072,881

Medtronic plc ADR

2,719

214,012

Merck & Company, Inc.

30,404

3,764,015

Mettler-Toledo International, Inc.(A)

269

375,952

Molina Healthcare, Inc.(A)

254

75,514

Regeneron Pharmaceuticals, Inc.(A)

437

459,300

PerkinElmer, Inc.

246

25,796

STERIS plc ADR

68

14,929

Stryker Corp.

1,427

485,537

Thermo Fisher Scientific, Inc.

1,882

1,040,746

UnitedHealth Group, Inc.

3,100

1,578,706

Universal Health Services, Inc.

130

24,041

Vertex Pharmaceuticals(A)

1,217

570,432

Viatris, Inc.

4,402

46,793

Zimmer Biomet Holdings

234

25,396

Zoetis, Inc.

2,305

399,595

22,755,900

5.37%

INDUSTRIALS

3M Co.

3,206

327,621

Allegion plc ADR

637

75,262

Automatic Data Processing, Inc.

1,525

364,002

Broadridge Financial Solutions, Inc.

206

40,582

Builders FirstSource, Inc.(A)

1,425

197,234

Caterpillar, Inc.

2,108

702,175

CH Robinson Worldwide, Inc.

438

38,597

Cintas Corp.

250

175,065

CSX Corp.

10,643

356,008

Cummins, Inc.

675

186,928

Delta Air Lines, Inc.

3,101

147,111

Dover Corp.

646

116,571

Eaton Corp. plc

328

102,844

Equifax, Inc.

439

106,440

Expeditors International of Washington, Inc.

262

32,695

FedEx Corp.

410

122,934

Generac Holdings, Inc.(A)

284

37,550

General Dynamics Corp.

699

202,808

Grainger WW, Inc.

209

188,568

Honeywell International

2,077

443,523

JB Hunt Transport Services, Inc.

271

43,360

Huntington Ingalls Industries

21

5,173

6

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Schedule of Investments - continuedJune 30, 2024 (unaudited)

See Notes to Financial Statements

Security Description

Shares

Value

IDEX Corp.

16

$

3,219

Illinois Tool Works, Inc.

1,033

244,780

Ingersoll Rand, Inc.

1,472

133,716

Jacobs Solutions, Inc.

511

71,392

Johnson Controls International ADR

1,482

98,509

Leidos Holdings, Inc.

1,021

148,943

Lockheed Martin Corp.

1,218

568,928

Masco Corp.

2,028

135,207

Northrop Grumman Corp.

446

194,434

Old Dominion Freight

424

74,878

Otis Worldwide Corp.

4,512

434,325

Parker-Hannifin Corp.

240

121,394

Paychex, Inc.

875

103,740

Paycom Software, Inc.

95

13,589

Pentair plc ADR

986

75,597

Robert Half International, Inc.

442

28,279

Rockwell Automation, Inc.

246

67,719

Rollins, Inc.

708

34,543

RTX Corp.

2,470

247,963

A O Smith Corp.

288

23,553

Snap-on, Inc.

242

63,256

Southwest Airlines Co.

459

13,132

Textron, Inc.

236

20,263

Trane Technologies plc ADR

692

227,620

Transdigm Group, Inc.

209

267,020

Union Pacific Corp.

2,705

612,033

United Airlines Holdings(A)

2,322

112,989

United Rentals, Inc.

311

201,133

UPS, Inc. Class B

1,107

151,493

Veralto Corp.

2,299

219,486

Verisk Analytics, Inc.

280

75,474

Wabtec Corp.

1,044

165,004

Xylem, Inc.

263

35,671

9,002,333

35.01%

INFORMATION TECHNOLOGY

Accenture plc Class A ADR

4,876

1,479,427

Adobe, Inc.(A)

2,896

1,608,844

Amphenol Corp. Class A

3,184

214,506

Analog Devices, Inc.

1,414

322,760

Apple, Inc.

63,676

13,411,438

Applied Materials, Inc.

5,980

1,411,220

7

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Schedule of Investments - continuedJune 30, 2024 (unaudited)

See Notes to Financial Statements

Security Description

Shares

Value

Arista Networks, Inc.(A)

730

$

255,850

Autodesk, Inc.(A)

639

158,120

Broadcom, Inc.

3,661

5,877,845

Cadence Design Systems(A)

428

131,717

CDW Corp.

1,513

338,670

Cisco Systems, Inc.

22,985

1,092,017

Cognizant Tech Solutions

1,795

122,060

Corning, Inc.

2,855

110,917

Enphase Energy, Inc.(A)

230

22,933

EPAM Systems, Inc.(A)

14

2,634

F5, Inc.(A)

23

3,961

Fair Isaac Corp.(A)

227

337,926

Fortinet, Inc.(A)

2,060

124,156

Gartner Group, Inc.(A)

834

374,516

Hewlett-Packard Enterprise

4,601

97,403

HP, Inc.

11,946

418,348

International Business Machines Corp.

2,215

383,084

Jabil, Inc.

256

27,850

Juniper Networks, Inc.

696

25,376

Keysight Technologies, Inc.(A)

640

87,520

KLA Corp.

1,416

1,167,506

Lam Research Corp.

901

959,430

Microchip Technology, Inc.

4,660

426,390

Microsoft Corp.

22,502

10,057,268

Motorola Solutions, Inc.

618

238,579

NetApp, Inc.

790

101,752

Nvidia Corp.

114,104

14,096,408

NXP Semiconductors NV ADR

1,052

283,083

ON Semiconductor Corp.(A)

2,485

170,347

Qorvo, Inc.(A)

107

12,416

Qualcomm, Inc.

3,455

688,167

Roper Technologies, Inc.

492

277,321

Salesforce, Inc.

1,297

333,459

Skyworks Solutions, Inc.

714

76,098

Synopsys, Inc.(A)

227

135,079

TE Connectivity Ltd. ADR

496

74,613

Teledyne Technologies, Inc.(A)

13

5,044

Teradyne, Inc.

296

43,894

Texas Instruments, Inc.

4,496

874,607

Tyler Technologies, Inc.(A)

57

28,658

Verisign, Inc.(A)

1,209

214,960

58,706,177

8

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Schedule of Investments - continuedJune 30, 2024 (unaudited)

See Notes to Financial Statements

Security Description

Shares

Value

1.10%

MATERIALS

Amcor plc ADR

6,786

$

66,367

Avery Dennison Corp.

222

48,540

Ball Corporation

893

53,598

Celanese Corp. Class A

223

30,080

CF Industries Holdings, Inc.

1,043

77,307

Corteva, Inc.

598

32,256

Dow, Inc.

670

35,544

Eastman Chemical Co.

114

11,169

Freeport-McMoran, Inc.

5,057

245,770

International Paper Co.

1,997

86,171

LyondellBasell Industries NV ADR

1,267

121,201

Martin Marietta Materials, Inc.

100

54,180

The Mosaic Co.

2,420

69,938

Nucor Corp.

1,089

172,149

Packaging Corp. of America

211

38,520

PPG Industries, Inc.

489

61,560

The Sherwin-Williams Co.

1,676

500,169

Steel Dynamics, Inc.

1,089

141,026

1,845,545

0.82%

REAL ESTATE

American Tower Corp. (C)

2,515

488,866

AvalonBay Communities, Inc. (C)

6

1,241

Camden Property Trust (C)

225

24,550

Crown Castle, Inc.

1,396

136,389

Equity Residential (C)

447

30,995

Essex Property Trust, Inc. (C)

27

7,349

Federal Realty Investment Trust (C)

330

33,320

Healthpeak Properties, Inc.

3,415

66,934

Host Hotels & Resorts, Inc. (C)

2,295

41,264

Kimco Realty Corp. (C)

475

9,244

Mid-America Apartment Communities (C)

232

33,086

Public Storage (C)

421

121,101

Simon Property Group, Inc. (C)

1,814

275,365

UDR, Inc. (C)

628

25,842

Ventas, Inc. (C)

1,036

53,105

Weyerhaeuser Co. (C)

914

25,948

1,374,599

9

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Schedule of Investments - continuedJune 30, 2024 (unaudited)

See Notes to Financial Statements

Security Description

Shares

Value

0.13%

UTILITIES

Atmos Energy Corp.

247

$

28,812

Consolidated Edison, Inc.

528

47,214

NRG Energy, Inc.

1,274

99,194

Public Service Enterprise Group, Inc.

628

46,284

221,504

99.52%

TOTAL COMMON STOCKS

(Cost:$152,060,172)

166,867,012

0.00%

WARRANTS

0.00%

HEALTH CARE

Abiomed, Inc. - CVR (A)(B)

2

-

0.00%

TOTAL WARRANTS

(Cost: $ - )

-

99.52%

TOTAL INVESTMENTS

(Cost:$152,060,172)

166,867,012

0.48%

Other assets, net of liabilities

812,196

100.00%

NET ASSETS

$

167,679,208

(A)Non-income producing

(B)The warrant is a Level 3 security. See Note 1.

(C)Real Estate Investment Trust ("REIT").

ADR - Security represented is held by the custodian in the form of American Depositary Receipts.

CVR - Contingent Value Right

10

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Statement of Assets and LiablitiesJune 30, 2024 (unaudited)

See Notes to Financial Statements

ASSETS

Investments at value (cost of $152,060,172) (Note 1)

$

166,867,012

Cash

790,909

Dividends and interest receivable

86,587

TOTAL ASSETS

167,744,508

LIABILITIES

Accrued advisory fees

65,300

TOTAL LIABILITIES

65,300

NET ASSETS

$

167,679,208

Net Assets Consist of:

Paid-in capital

$

146,224,427

Distributable earnings (accumulated deficit)

21,454,781

Net Assets

$

167,679,208

NET ASSET VALUE PER SHARE

Net Assets

$

167,679,208

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

4,925,000

Net Asset Value and Offering Price Per Share

$

34.05

11

FINANCIAL STATEMENTS | JUNE 30, 2024

See Notes to Financial Statements

Applied Finance Valuation Large Cap ETF

Statement of OperationsFor the Six Months Ended June 30, 2024 (unaudited)

INVESTMENT INCOME

Dividends (net of foreign tax withheld of $379)

$

817,467

Total investment income

817,467

EXPENSES

Investment advisory fees (Note 2)

276,330

Total expenses

276,330

Net investment income (loss)

541,137

REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS

Net realized gain (loss) on investments(1)

7,472,321

Net increase (decrease) in unrealized appreciation (depreciation)
of investments

7,350,679

Net realized and unrealized gain (loss) on investments

14,823,000

INCREASE (DECREASE) IN NET ASSETS FROM OPERATIONS

$

15,364,137

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

12

FINANCIAL STATEMENTS | JUNE 30, 2024

See Notes to Financial Statements

Applied Finance Valuation Large Cap ETF

Statements of Changes in Net Assets

For the Six Months
Ended
June 30, 2024
(unaudited)

For the Year
Ended
December 31, 2023

INCREASE (DECREASE) IN NET ASSETS FROM

OPERATIONS

Net investment income (loss)

$

541,137

$

449,620

Net realized gain (loss) on investments

7,472,321

165,881

Net increase (decrease) in unrealized appreciation (depreciation) of investments

7,350,679

8,870,727

Increase (decrease) in net assets from operations

15,364,137

9,486,228

DISTRIBUTIONS TO SHAREHOLDERS

Distributions to shareholders

-

(454,193

)

Decrease in net assets from distributions

-

(454,193

)

CAPITAL STOCK TRANSACTIONS (NOTE 5)

Shares sold

100,750,431

54,626,033

Shares redeemed

(24,207,554

)

(3,234,417

)

Increase (decrease) in net assets from capital stock transactions

76,542,877

51,391,616

NET ASSETS

Increase (decrease) during period

91,907,014

60,423,651

Beginning of period

75,772,194

15,348,543

End of period

$

167,679,208

$

75,772,194

13

FINANCIAL STATEMENTS | JUNE 30, 2024

See Notes to Financial Statements

Applied Finance Valuation Large Cap ETF

Financial HighlightsSelected Per Share Data Throughout Each Period

For the Six
Months
Ended
June 30,
2024
(unaudited)

For the Years Ended
December 31,

April 29, 2021(1)
through
December 31, 2021

2023

2022

Net asset value, beginning
of period

$

29.71

$

23.61

$

28.33

$

25.00

Investment activities

Net investment
income (loss)
(2)

0.15

0.32

0.29

0.18

Net realized and unrealized gain (loss)
on investments

4.19

5.96

(4.79

)

3.31

Total from investment activities

4.34

6.28

(4.50

)

3.49

Distributions

Net investment income

-

(0.18

)

(0.22

)

(0.16

)

Return of Capital

-

-

-

(3)

-

Total distributions

-

(0.18

)

(0.22

)

(0.16

)

Net asset value, end of period

$

34.05

$

29.71

$

23.61

$

28.33

Total Return(4)

14.57

%

26.59

%

(15.82

%)

13.95

%

Ratios/Supplemental Data

Ratios to average net assets(5)

Expenses, gross

0.49

%

0.49

%

0.49

%

0.49

%

Net investment
income (loss)

0.96

%

1.18

%

1.19

%

1.01

%

Portfolio turnover rate(6)

16.70

%

23.01

%

24.94

%

30.04

%

Net assets, end of
period (000's)

$

167,679

$

75,772

$

15,349

$

9,915

(1)Commencement of Operations.

(2)Per share amounts calculated using the average number of shares outstanding during the period.

(3)Less than $0.005 per share.

(4)Total return is for the period indicated and has not been annualized for periods less than one year.

(5)Ratios to average net assets have been annualized for the periods less than one year.

(6)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.

14

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Notes to Financial StatementsJune 30, 2024 (unaudited)

NOTE 1 - ORGANIZATION AND SIGNIFICANT ACCOUNTING POLICIES

The Applied Finance Valuation Large Cap ETF (the "Fund") is a non-diversified series of ETF Opportunities Trust (the "Trust"), a Delaware statutory 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 April 29, 2021.

The Fund's objective is to seek to achieve long-term capital appreciation.

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

Generally, the Fund's domestic securities (including underlying ETFs which hold portfolio securities primarily listed on foreign (non-U.S.) exchanges) are valued each day at the last quoted sales price on each security's primary exchange. Securities traded or dealt in upon one or more securities exchanges for which market quotations are readily available and not subject to restrictions against resale shall be 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. Warrants which are traded on an exchange are valued at their last quoted price as of the valuation date. If market quotations are not readily available, securities will be valued at their fair market value as determined in good faith under procedures set by the Board of Trustees of the Trust (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 Applied Finance Advisors, LLC (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

15

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Notes to Financial Statements - continuedJune 30, 2024 (unaudited)

are readily available generally shall be valued at the last sale price or, in the absence of a sale, at the mean between the current bid and ask price on such over-the-counter market.

The Fund has a policy that contemplates the use of fair value pricing to determine the net asset value ("NAV") per share of the Fund when market prices are unavailable as well as under special circumstances, such as: (i) if the primary market for a portfolio security suspends or limits trading or price movements of the security; and (ii) when an event occurs after the close of the exchange on which a portfolio security is principally traded that is likely to have changed the value of the security. Since most of the Fund's investments are traded on U.S. securities exchanges, it is anticipated that the use of fair value pricing will be limited.

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 Board 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 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.

16

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Notes to Financial Statements - continuedJune 30, 2024 (unaudited)

The following is a summary of the level of inputs used to value the Fund's investments as of June 30, 2024:

Level 1
Quoted
Prices

Level 2
Other
Significant
Observable
Inputs

Level 3
Significant
Unobservable
Inputs

Total

Common Stocks

$

166,867,012

$

-

$

-

$

166,867,012

Warrants

-

-

-

*

-

$

166,867,012

$

-

$

-

$

166,867,012

*The Level 3 security has zero value.

Refer to the Fund's Schedule of Investments for a listing of the securities by type and sector.

There were no transfers into or out of any levels during the six months ended June 30, 2024. On June 30, 2024, the Fund held assets in which significant unobservable inputs were used determining fair value (Level 3). These assets were valued at $ - (0.00% of net assets). As the value of the Level 3 security is not material to the financial statements, no additional Level 3 disclosures are presented.

Security Transactions and Income

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

Warrants

The Fund may invest in warrants. Warrants are options to purchase equity securities at a specific price, or receive contingent payments, for a specific period of time. They do not represent ownership of the securities, but only the right to buy them. Hence, warrants have no voting rights, pay no dividends and have no rights with respect to the assets of the corporation issuing them. The value of warrants is derived solely from capital appreciation of the underlying equity securities. Warrants differ from call options in that the underlying corporation issues warrants, whereas call options may be written by anyone.

17

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Notes to Financial Statements - continuedJune 30, 2024 (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 disclosure of contingent assets and liabilities at the date of the financial statements, as well as the reported amounts of increase (decrease) in net assets from operations 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 reasonable possible thatthe total amounts of unrecognized tax benefits will significantly change in the next twelve months. Interest and penalties, if any, associated with any federal or state income tax obligations are recorded as income tax expense as incurred.

Reclassification of Capital Accounts

GAAP requires that certain components of net assets relating to permanent differences be reclassified between financial and tax reporting. For the six months ended June 30, 2024, 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.

18

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Notes to Financial Statements - continuedJune 30, 2024 (unaudited)

Creation Units

The Fund issues and redeems shares to certain institutional investors (typically market makers or other broker-dealers) only in large blocks of at least 25,000 shares known as "Creation Units." Purchasers of Creation Units ("Authorized Participants") will be required to pay 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 $750. 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 $750.

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 ("Participant Agreement"). Most retail investors will not qualify as Authorized Participants or have the resources to buy and sell whole Creation Units. Therefore, they will be unable to purchase or redeem the shares directly from the Fund. Rather, most retail investors will purchase shares in the secondary market with the assistance of a broker and will be subject to customary brokerage commissions or fees. The following table discloses the Creation Unit breakdown based on the NAV as of June 30, 2024:

Creation
Unit
Shares

Creation
Transaction
Fee

Value

Applied Finance Valuation
Large Cap ETF

25,000

$750

$851,250

To the extent contemplated by a Participant Agreement, in the event an Authorized Participant has submitted a redemption request in proper form but is unable to transfer all or part of the shares comprising a Creation Unit to be

19

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Notes to Financial Statements - continuedJune 30, 2024 (unaudited)

redeemed to the Distributor, on behalf of the Fund, by the time as set forth in the Participant Agreement, the Distributor may nonetheless accept the redemption request in reliance on the undertaking by the Authorized Participant to deliver the missing shares as soon as possible, which undertaking shall be secured by the Authorized Participant's delivery and maintenance of collateral equal to a percentage of the value of the missing shares as specified in the participant agreement. A Participant Agreement may permit the Fund to use such collateral to purchase the missing shares, and could subject an Authorized Participant to liability for any shortfall between the cost of the Fund acquiring such shares and the value of the collateral. Amounts are disclosed as Segregated Cash Balance from Authorized Participants for Deposit Securities and Collateral Payable upon Return of Deposit Securities on the Statement of Assets and Liabilities, when applicable.

Officers and Trustees Indemnification

Under the Trust's organizational documents, its officers and trustees are indemnified against certain liabilities arising out of the performance of their duties to the Fund. In addition, in the normal course of business, the Fund enters into contracts with its vendors and others that provide for general indemnifications. The Fund's maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Fund. However, based on experience, the Fund expects that risk of loss to be remote.

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

The Advisor currently provides investment advisory services pursuant to an investment advisory agreement (the "Advisory Agreement"). Under the terms of the Advisory Agreement, the Advisor manages the investment portfolio of the Fund, subject to the policies adopted by the Board. In addition, the Advisor: (i) furnishes office space and all necessary office facilities, equipment and executive personnel necessary for managing the assets of the Fund; (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, at its own expense and without reimbursement from the Trust, assumes and pays all ordinary expenses of the Fund, except the fee paid to the Advisor pursuant to the Advisory Agreement, distribution fees or expenses under the Fund's 12b-1 plan (if any), interest expenses, taxes, acquired fund fees and expenses, brokerage commissions and any other portfolio transaction related

20

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Notes to Financial Statements - continuedJune 30, 2024 (unaudited)

expenses and fees arising out of transactions effected on behalf of the Fund, credit facility fees and expenses, including interest expenses, and litigation and indemnification expenses and other extraordinary expenses not incurred in the ordinary course of the Fund's business.

For its services with respect to the Fund, the Advisor is entitled to receive an annual management fee, calculated daily and payable monthly as a percentage of the Fund's daily net assets, at the rate of 0.49%.

The Advisor has retained Tidal Investments LLC 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, which fee is calculated daily and paid monthly, at an annual rate based on the daily net assets of the Fund at the following rate: 0.0350% on the first $500 million in net assets; 0.0325% on the next $500 million in net assets; and 0.0300% on any net assets in excess of $1 billion (subject to a minimum of $25,000 per year).

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. The Advisor pays these fees.

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

Custodian and Transfer Agent

Citibank, N.A. serves as the Fund's Custodian and Transfer Agent 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.

21

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Notes to Financial Statements - continuedJune 30, 2024 (unaudited)

Fund Accountant

Citi Fund Services, Ohio, Inc. serves as the Fund's Fund Accountant pursuant to a Services Agreement. The Advisor pays the fees for these services monthly.

Distributor

Foreside Fund Services, LLC, serves as the Fund's principal underwriter pursuant to an ETF Distribution Agreement. The Advisor pays these fees monthly.

NOTE 3 - INVESTMENTS

The costs of purchases and proceeds from the sales of securities other than in-kind transactions and short-term notes for the six months ended June 30, 2024 were as follows:

Purchases

Sales

$22,224,545

$19,149,676

The costs of purchases and proceeds from the sales of in-kind transactions associated with creations and redemptions for the six months ended June 30, 2024 were as follows:

Purchases

Sales

Realized Gain

$96,993,612

$23,678,657

$7,935,453

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.

22

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Notes to Financial Statements - continuedJune 30, 2024 (unaudited)

The tax character of the distributions during the six months ended June 30, 2024 and the year ended December 31, 2023, were as follows:

Six Months
ended
June 30, 2024

Year ended
December 31,
2023

Distributions paid from:

Ordinary income

$

-

$

454,193

$

-

$

454,193

As of June 30, 2024, the components of distributable earnings (accumulated deficits) on a tax basis were as follows:

Accumulated undistributed net investment income (loss)

541,137

Accumulated net realized gain (loss) on investments

6,106,804

Net unrealized appreciation (depreciation) on investments

14,806,840

$

21,454,781

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

Cost

Gross Unrealized Appreciation

Gross Unrealized Depreciation

Total Unrealized Appreciation (Depreciation)

$152,060,172

$18,027,721

$(3,220,881)

$14,806,840

NOTE 5 - TRANSACTIONS IN SHARES OF BENEFICIAL INTEREST

Shares of the Fund are listed for trading on NYSE Arca, Inc. (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 its shares at NAV only in large blocks of 25,000 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 Fund's shares are not redeemable securities of the Fund.

All orders to create Creation Units must be placed with the Distributor either (1) through Continuous Net Settlement System of the NSCC ("Clearing Process"), a clearing agency that is registered with the Securities and Exchange Commission, 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 a Participant Agreement; such parties are collectively referred to as "APs" or

23

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Notes to Financial Statements - continuedJune 30, 2024 (unaudited)

"Authorized Participants." Investors should contact the Distributor for the names of Authorized Participants. All Fund shares, whether created through or outside the Clearing Process, will be entered on the records of DTC for the account of a DTC Participant.

Shares of beneficial interest transactions for the Fund were:

Six Months
ended
June 30, 2024

Year ended
December 31,
2023

Shares sold

3,125,000

2,025,000

Shares redeemed

(750,000

)

(125,000

)

Net increase (decrease)

2,375,000

1,900,000

NOTE 6 - SECTOR RISK

If a Fund has significant investments in the securities of issuers in industries within a particular sector, any development affecting that sector will have a greater impact on the value of the net assets of that Fund than would be the case if the Fund did not have significant investments in that sector. In addition, this may increase the risk of loss of an investment in the Funds and increase the volatility of the Funds' NAV per share. From time to time, circumstances may affect a particular sector and the companies within such sector. For instance, economic or market factors, regulation or deregulation, and technological or other developments may negatively impact all companies in a particular sector and therefore the value of a Fund's portfolio will be adversely affected. As of June 30, 2024, 35.01% of the value of the net assets of the Fund were invested in securities within the Information Technology sector.

NOTE 7 - RISKS OF INVESTING IN THE FUND

It is important that you closely review and understand the risks of investing in the Funds. The Funds' NAV and investment return will fluctuate based upon changes in the value of their portfolio securities. You could lose money on your investment in the Funds, and the Funds could underperform other investments. There is no guarantee that the Funds will meet their investment objective. An investment in the Funds 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 Funds' prospectus under the heading "Principal Risks."

24

FINANCIAL STATEMENTS | JUNE 30, 2024

Applied Finance Valuation Large Cap ETF

Notes to Financial Statements - continuedJune 30, 2024 (unaudited)

NOTE 8 - SUBSEQUENT EVENTS

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

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.

(1)       The amount of regular compensation paid for all trustees for the period covered by the report was $4,095.

(2)       Not applicable.

(3)       The registrant's Chief Compliance Officer and Assistant Chief Compliance Officer are not compensated directly by the registrant 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 registrant, including the provision of the Chief Compliance Officer and the Assistant Chief Compliance Officer.  The Assistant Chief Compliance Officer is the Managing Member of Watermark, and 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.  Payments for Watermark's services were made by the investment adviser to each fund included in this report.

(4)       During the period covered by this report, registrant paid Watermark $5,167 for the services described in Item 10 (3) above.

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

Approval of Investment Advisory Agreement

At a meeting held on February 21-22, 2024 (the "Meeting"), the Board of Trustees (the "Board") of the ETF Opportunities Trust (the "Trust") considered the approval of the continuation of the Investment Advisory Agreement (the "Applied Finance Advisory Agreement") between the Trust and Applied Finance Advisors, LLC ("Applied Finance"), with respect to the Applied Finance Valuation Large Cap ETF ("Applied Finance ETF"). The Board reflected on its discussions with the representatives from Applied Finance at the Meeting regarding the manner in which the Applied Finance Valuation Large Cap ETF is to be managed and the roles and responsibilities of Applied Finance under the Applied Finance Advisory Agreement.

The Trustees reviewed the responses of Applied Finance to a request for information from counsel to the Trust ("Counsel") on behalf of the Board. The Trustees observed Applied Finance's representation that their responses to the information requested are identical to the responses provided in its response letter of November 27, 2023, except that financial information has been updated and the firm is providing its most recently updated Code of Ethics. The Trustees noted that the responses included financial information for Applied Finance, an expense comparison analysis for the Applied Finance ETF and comparable ETFs, and the Applied Finance Advisory Agreement. 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 Applied Finance Advisory Agreement, including the following material factors: (i) the nature, extent, and quality of the services provided by Applied Finance; (ii) the investment performance of the Applied Finance ETF and Applied Finance; (iii) the costs of the services to be provided and profits to be realized by Applied Finance from the relationship with the Applied Finance ETF; (iv) the extent to which economies of scale would be realized if the Applied Finance ETF grows and whether advisory fee levels reflect those economies of scale for the benefit of their investors; and (v) possible conflicts of interest and other benefits.

In assessing these factors and reaching its decisions, the Board took into consideration information specifically prepared or presented at this Meeting, and at previous Board meetings. The Board requested or was provided with information and reports relevant to the approval of the Applied Finance Advisory Agreement, including: (i) information regarding the services and support provided by Applied Finance to the Applied Finance ETF and its shareholders; (ii) reports by management of Applied Finance addressing the investment strategy, personnel and operations utilized in managing the Applied Finance ETF; (iii) information pertaining to the compliance structure of Applied Finance; and (iv) a memorandum from Trust Counsel that summarized the fiduciary duties and responsibilities of the Board in reviewing and approving the Applied Finance Advisory Agreement, 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 received various informational materials including, without limitation: (i) documents containing information about Applied Finance, including financial information, information on personnel and the services to be provided by Applied Finance to the Applied Finance ETF, the firm's compliance program, information on any current legal matters, and other general information; (ii) expenses of the Applied Finance ETF and comparative expense and performance information for other ETFs with investment strategies similar to the Applied Finance ETF prepared by an independent third party; (iii) the anticipated effect of size on the Applied Finance ETF's performance and expenses; and (iv) benefits anticipated to be realized by Applied Finance from its relationship with the Applied Finance ETF. The Board did not identify any particular information that was most relevant to its consideration to approve the Applied Finance Advisory Agreement and each Trustee may have afforded different weight to the various factors. In deciding whether to approve the Applied Finance Advisory Agreement, the Trustees considered numerous factors, including:

(1) The nature, extent, and quality of the services provided by Applied Finance.

In this regard, the Board considered the responsibilities of Applied Finance under the Applied Finance Advisory Agreement. The Board reviewed the services provided by Applied Finance to the Applied Finance ETF, including, without limitation, Applied Finance's process for formulating investment recommendations and the processes for assuring compliance with the Applied Finance ETF's investment objective and limitations; and the efforts of Applied Finance to promote the Applied Finance ETF and grow its assets. The Board considered the staffing, personnel, and methods of operating of Applied Finance; the education and experience of their personnel; and information provided on their compliance programs, policies and procedures. The Board considered the services provided by Tidal Investments, LLC as sub-adviser to the Applied Finance ETF and the relationship between services provided by Applied Finance. After considering the foregoing, the Board concluded that the nature, extent and quality of the services provided by Applied Finance was satisfactory and adequate for the Applied Finance ETF.

(2) The investment performance of the Applied Finance ETF and Applied Finance.

The Board reviewed the Applied Finance ETF's performance. The Trustees considered that Applied Finance does not have any clients other than the Applied Finance ETF and three Applied Finance Funds, the Applied Finance Dividend Fund, Applied Finance Select Fund, and Applied Finance Explorer Fund, for which the Trust's independent trustees also serve as independent trustees. In considering the investment performance of the Applied Finance ETF, the Trustees compared the performance of the Applied Finance ETF with the performance of its benchmark index, the Russell 1000 TR Index, funds in its Morningstar category, Large Blend Funds ("Category"), and a peer group selected from its Category ("Peer Group"). The Trustees noted that the Applied Finance ETF outperformed the Russell 1000 TR Index, the median of funds in its Category and the median of Fund's in its Peer Group for the one-year period ended October 31, 2023. The Trustees also considered the experience of the portfolio management team.

After a detailed discussion of the Applied Finance ETF's performance, the Board concluded, in light of all the facts and circumstances, that the investment performance of the Applied Finance ETF was satisfactory.

(3) The costs of services to be provided and profits to be realized by Applied Finance from the relationship with the Applied Finance ETF.

In this regard, the Board considered the financial condition of Applied Finance and the level of commitment to the Applied Finance ETF by Applied Finance. The Board also considered the assets and expenses of the Applied Finance ETF, including the nature and frequency of advisory payments. The Board noted the information on profitability provided by Applied Finance. The Trustees considered the Applied Finance ETF's unitary fee structure, and compared the unitary fee of the Applied Finance ETF to the fees of the Category and the Peer Group. The Trustees noted that the Applied Finance ETF's gross and net expense ratio and gross and net advisory fee were each less than the Category median and equal to the Peer Group median. The Board also considered the fees paid to Tidal by Applied Finance for sub-advising the Applied Finance ETF. After further consideration, the Board concluded that the profitability and fees to be paid to Applied Finance (who in turn would pay Tidal) were within an acceptable range in light of the services to be rendered by Applied Finance.

(4) The extent to which economies of scale would be realized as the Applied Finance ETF grows and whether advisory fee levels reflect these economies of scale for the benefit of the Applied Finance ETF's investors.

The Trustees considered that the Applied Finance ETF is not of sufficient size to achieve economies of scale and that there are no break points in the Applied Finance Advisory Agreement. However, they noted that the unitary fee structure limits the shareholders' exposure to fee increases.

(5) 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 personnel assigned to the Applied Finance ETF; the basis of decisions to buy or sell securities for the Applied Finance ETF; the substance and administration of the Code of Ethics and other relevant policies of Applied Finance. The Board noted that Applied Finance has represented that it has not and does not anticipate utilizing soft dollars or commission recapture with regard to the Applied Finance ETF. The Board also considered the affiliations of Applied Finance, including its affiliate that produces and sells investment research, and that it manages the Applied Finance Funds. It was noted that Applied Finance represented that the Applied Finance Funds may invest in the Applied Finance ETF from time to time for the same reasons they would invest in other non-affiliated mutual funds or ETFs and that Applied Finance does not believe such investments will raise issues of conflict or duplicative services. The Board also considered potential benefits for Applied Finance in managing the Applied Finance ETF. Following further consideration and discussion, the Board indicated that the standards and practices of Applied Finance relating to the identification and mitigation of potential conflicts of interest, as well as the benefits to be derived by Applied Finance from managing the Applied Finance ETF were satisfactory.

After additional consideration of the factors delineated in the memorandum provided by Counsel and further discussion and careful review by the Trustees, the Board determined that the compensation payable under the Applied Finance Advisory Agreement was fair, reasonable and within a range of what could have been negotiated at arms-length in light of all the surrounding circumstances, and they approved the Applied Finance Advisory Agreement.

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

Not applicable.

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


Not applicable.

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

Not applicable.

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.

ITEM 18. RECOVERY OF ERRONEOUSLY AWARDED COMPENSATION.

Not applicable.

ITEM 19. EXHIBITS.
(a)(1) Code of Ethics in response to Item 2 of this Form N-CSR: Not applicable.
(a)(2) Any policy required by the listing standards adopted pursuant to Rule 10D-1 under the Exchange Act of 1934: Not applicable.
(a)(3) Certifications pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto.

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

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

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

SIGNATURES

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

Registrant: ETF Opportunities Trust

By (Signature and Title)*: /s/ Karen Shupe

Karen Shupe

Principal Executive Officer

Date: September 19, 2024

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

By (Signature and Title)*: /s/ Karen Shupe

Karen Shupe

Principal Executive Officer

Date: September 19, 2024
By (Signature and Title)*: /s/ Ann MacDonald

Ann MacDonald

Principal Financial Officer

Date: September 19, 2024

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