General Information Aptus Capital Advisors LLC (“ACA”) was formed in 2013 and provides innovative investment management services that include Behavioral Finance, Model Portfolios and Sub-Advisory Services, and Exchange Traded Funds. John David Gardner is the majority owner of ACA. Please see Brochure Supplements, at the end of this brochure for more information on the Managing Principals of ACA. As of December 31, 2023, ACA managed approximately $4,698,399,791 on a discretionary basis, and $586,677,898 on a non-discretionary basis. SERVICES PROVIDED Portfolio Management ACA provides portfolio management services employing its specialized investment strategies, either in isolation or in conjunction with asset allocation strategies. Exposure to these strategies is normally achieved through allocating client funds to Exchange Traded Funds managed by ACA (described below). In addition to collecting a management fee for traditional portfolio management services, ACA also collects a management fee as advisor to the Aptus ETFs. Traditional Portfolio Management ACA also offers Traditional Portfolio Management services. Such services are tailored to the overall investment needs of a client instead of a segment of the investment portfolio. Each portfolio is tailored to the client’s individual goals, risk tolerance and investment horizon. ACA spends time with clients seeking Traditional Portfolio Management services, asking questions, discussing the client’s investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, ACA generally develops:
• a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile” or “Profile”); and
• the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”). ACA gathers information and performs research and analysis as necessary to develop the client’s Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by ACA based on updates to the client’s financial or other circumstances. Accounts are generally driven by model portfolio allocations and reviewed quarterly to monitor alignment with the Investment Plan. ACA’s Specialized Investment Strategies and Traditional Portfolio Management services are provided on a discretionary basis. In some instances, the client will hold discretion over their account and execute trades on their own. As a discretionary investment adviser, ACA will have the authority to supervise and direct the portfolio without prior consultation with the client. Notwithstanding the foregoing, clients may impose certain written restrictions on ACA in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of ACA. Financial Planning In some cases, ACA will provide financial planning services to clients in conjunction with Portfolio Management services. ACA’s financial planning services normally address areas such as general cash flow planning, retirement planning, and insurance analysis. The goal of this service is to assess the financial circumstances of the client in order to more effectively develop the client’s investment plan. Retirement Plan Advisory Services Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. ACA will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, ACA will be considered a fiduciary under ERISA. Also, to the extent that the Plan Fiduciaries retain ACA to act as an investment manager within the meaning of ERISA § 3(38), ACA will provide discretionary investment management services to the Plan. With respect to any account for which ACA meets the definition of a fiduciary under Department of Labor rules, ACA acknowledges that both ACA and its Related Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between ACA and Client. Fiduciary Consulting Services
• Investment Selection Services ACA will provide Plan Fiduciaries with recommendations of investment options consistent with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c).
• Non-Discretionary Investment Advice ACA provides Plan Fiduciaries and Plan Participants general, non-discretionary investment advice regarding asset classes and investments.
• Investment Monitoring ACA will assist in monitoring the plan’s investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and ACA will make recommendations to maintain or remove and replace investment options. The details of this aspect of service will be enumerated in the engagement agreement between the parties. Fiduciary Management Services
• Discretionary Management Services When retained as an investment manager within the meaning of ERISA § 3(38), ACA provides continuous and ongoing supervision over the designated retirement plan assets. ACA will actively monitor the designated retirement plan assets and provide ongoing management of the assets. When applicable, ACA will have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with the Plan Fiduciaries. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.
• Discretionary Investment Selection Services ACA will monitor the investment options of the Plan and add or remove investment options for the Plan without prior consultation with the Plan Fiduciaries. ACA will have discretionary authority to make and implement all decisions regarding the investment options that are available to Plan Participants.
• Investment Management via Model Portfolios. ACA will provide discretionary management of Model Portfolios among which the participants may choose to invest as Plan options. Plan Participants will also have the option of investing only in options that do not include Model Portfolios (i.e., the Plan Participants may elect to invest in one or more of the mutual funds or exchange traded fund options made available in the Plan and choose not to invest in the Model Portfolios at all). Non-Fiduciary Services
• Participant Education ACA will provide education services to Plan Participants about general investment principles and the investment alternatives available under the Plan. Education presentations will not take into account the individual circumstances of each Plan Participant and individual recommendations will not be provided unless a Plan Participant separately engages ACA for such services. Plan Participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment ACA will assist with group enrollment meetings designed to increase retirement Plan participation among employees and investment and financial understanding by the employees. Aptus Exchange Traded Funds Aptus Drawdown Managed Equity ETF (Ticker: ADME) ACA serves as the investment advisor to the Aptus Drawdown Managed Equity ETF (the “Fund”). The Fund is an actively managed exchange-traded fund (“ETF”) that seeks to achieve its objective principally by investing in a portfolio of U.S.-listed equity securities, while limiting downside risk by purchasing exchange- listed put options on one or more of such equity securities or on broad-based indexes or ETFs that track the performance of the U.S. equity market. Under normal circumstances, at least 80% of the Fund’s net assets (plus borrowings for investment purposes) will be invested in equity securities. Please see the Fund’s Prospectus and Statement of Additional Information (“SAI”) for additional information about the investment strategy and disclosures relating to the fund. Prior to making any investment in the Fund, clients should carefully review these documents for comprehensive understanding of the terms and conditions applicable for investment. Aptus Collared Income Opportunity ETF (Ticker: ACIO) ACA serves as the investment advisor to the Aptus Collared Income Opportunity ETF (the “Fund”). The Fund is an actively-managed exchange-traded fund (“ETF”) that seeks to achieve its investment objective principally by investing in a portfolio of U.S.-listed equity securities of any market capitalization and buying put options or an options collar (i.e., a mix of written (sold) call options and long (bought) put options) on the same underlying equity securities, U.S. Equity ETF or on an index tracking a portfolio of U.S. equity securities (a “U.S. Equity Index”). The U.S. Equity Index, U.S. equity ETF, and the underlying equity securities may be of any market capitalization. The equity securities and options held by the Fund must be listed on a U.S.-exchange, and the equity securities may include common stocks of U.S. companies, American Depositary Receipts (“ADRs”) (i.e., receipts evidencing ownership of foreign equity securities), and real estate investment trusts (“REITs”). The Fund will typically limit investments in ADRs to approximately 20% of the Fund’s net assets. Please see the Fund’s Prospectus and Statement of Additional Information (“SAI”) for information about the investment strategy and additional disclosures relating to the fund. Prior to making any investment in the Fund, clients should carefully review these documents for comprehensive understanding of the terms and conditions applicable for investment. Aptus Defined Risk ETF (Ticker: DRSK) ACA serves as the investment advisor to the Aptus Defined Risk ETF (the “Fund”). The Fund is an

actively managed exchange-traded fund (“ETF”) that seeks to achieve its objective through a hybrid fixed income and equity strategy. The Fund typically invests approximately 75% to 95% of its assets to obtain exposure to investment-grade corporate bonds (the “Fixed Income Strategy”) and invests the remainder of its assets to obtain exposure to U.S. stocks, while limiting downside risk (the “Equity Strategy”). Please see the Fund’s Prospectus and Statement of Additional Information (“SAI”) for additional information about the investment strategy and disclosures relating to the fund. Prior to making any investment in the Fund, clients should carefully review these documents for comprehensive understanding of the terms and conditions applicable for investment. Aptus International Enhanced Yield ETF (Ticker: IDUB) ACA serves as the investment advisor to the Aptus International Enhanced Yield ETF (the “FUND”). The Fund is an actively managed exchange-traded fund (“ETF") that seeks to achieve its objective through a hybrid equity and equity linked note (“ELN”) strategy. The Fund invests primarily in a portfolio of other ETFs that invest in equity securities of non-U.S. (international) companies in developed and emerging markets throughout the world (the “Equity Strategy”) and invests the remainder of its assets in ELNs to generate income (the “ELN Strategy”). The Fund may also invest in depositary receipts representing individual equity securities of non-U.S. companies of any size, although such depositary receipts will generally comprise less than 20% of the Fund’s net assets. Please see the Fund’s Prospectus and Statement of Additional Information (“SAI”) for additional information about the investment strategy and disclosures relating to the fund. Prior to making any investment in the Fund, clients should carefully review these documents for comprehensive understanding of the terms and conditions applicable for investment. Aptus Enhanced Yield ETF (Ticker: JUCY) ACA serves as the investment advisor to the Aptus Enhanced Yield ETF (the “FUND”). The Fund is an actively managed exchange-traded fund (“ETF”) that seeks to achieve its investment objectives through a hybrid fixed income and equity-linked note strategy. The Fund invests primarily in U.S. Treasury Bills, U.S. Treasury Notes, and the securities of U.S. government-sponsored entities (“GSEs”) (the “Fixed Income Strategy”) and invests the remainder of its assets in Equity-Linked Notes (“ELNs”) (the “ELN Strategy”). Please see the Fund’s Prospectus and Statement of Additional Information (“SAI”) for additional information about the investment strategy and disclosures relating to the fund. Prior to making any investment in the Fund, clients should carefully review these documents for comprehensive understanding of the terms and conditions applicable for investment. Aptus Large Cap Enhanced Yield ETF (Ticker: DUBS) ACA serves as the investment advisor to the Aptus Large Cap Enhanced Yield ETF (the “FUND”). The Fund is an actively managed exchange-traded fund (“ETF”) that seeks to achieve its investment objective through a hybrid equity and equity-linked note (“ELN”) strategy. The Fund invests primarily in U.S.-listed large cap equity securities (the “Equity Strategy”) and invests the remainder of its assets in ELNs to generate income (the “ELN Strategy”). The Fund considers a large cap company to be one with a market capitalization that, at the time of purchase, is within with the capitalization range of the S&P 500 Index. As of May 31, 2023, the market capitalization range represented by companies in the S&P 500 Index was approximately $1.88 billion to $2.80 trillion. Please see the Fund’s Prospectus and Statement of Additional Information (“SAI”) for additional information about the investment strategy and disclosures relating to the fund. Prior to making any investment in the Fund, clients should carefully review these documents for comprehensive understanding of the terms and conditions applicable for investment. Opus Small Cap Value Plus ETF (Ticker: OSCV) ACA serves at the investment adviser to the Opus Small Cap Value Plus ETF (the “Fund”). The Fund is an actively managed exchange-traded fund (“ETF”) that invests under normal circumstances at least 80% of its net assets (plus any borrowings for investment purposes) in equity securities of small-capitalization U.S. companies. The Fund defines small capitalization companies as those that, at the time of investment, fall within the lowest 15% of the total U.S. equity market capitalization (excluding, for purposes of this calculation, companies with market capitalizations of less than $10 million), as calculated annually. As of April 30, 2023, there were approximately 4,372 small-capitalization companies, and those companies had market capitalizations ranging up to approximately $12.87 billion. The Fund’s equity securities primarily include common stocks, real estate investment trusts (“REITs”), and American Depositary Receipts (“ADRs”) representing the stock of a foreign company. The Fund will generally limit its investments in ADRs to 20% of its total assets. The Fund may invest in securities offered in an initial public offering (“IPO”) or in companies that have recently completed an IPO. Please see the Fund’s Prospectus and Statement of Additional Information (“SAI”) for additional information about the investment strategy and disclosures relating to the Fund. Prior to making any investment in the Fund, clients should carefully review these documents for comprehensive understanding of the terms and condition applicable for investment. Aptus Model Portfolio Service (The Impact Series)– Subscription Service ACA provides model portfolios to other Registered Investment Advisers and Broker- Dealers. This model portfolio service involves ACA creating, managing, and maintaining investment models and updating Subscribers as adjustments occur within the models. Initial and ongoing delivery of the models to subscribers occurs through direct communication with advisers or through delivery of the models to model manager platforms (“Third Party Platforms”). If Subscribers choose to follow the Impact Series Models, they are responsible to trade client accounts to bring the portfolios in line with The Impact Series Model Portfolios. Subscribers to the Models are responsible for handling all matters pertaining to their client accounts, including suitability, trading, reporting, and custody. The Impact Series Models are not customized to any individual client of the subscriber and Aptus has no advisory relationship with any “end-client” under this arrangement. Sub-Advisory Services ACA acts as a sub-advisor to Advisors that select ACA for its asset management and back office services. In these instances, an Advisor selects ACA to provide these services for its clients, and for this service the Advisor either shares a portion of their stated fees with ACA, or the Advisor discloses a separate fee for ACA. The allocation of a total stated advisory fee, or the separate fee charged by ACA, is disclosed in the Advisor’s brochure. The compensation for ACA depends on the negotiated agreement between the Advisor and ACA. ACA’s fee may be lower when acting as a sub-advisor for an Advisor than if a client worked directly with ACA because the services ACA provides as a sub- advisor are limited in scope and do not include the entire realm of advisory services as provided to direct clients of ACA. Consulting Services ACA acts as a consultant to Advisors that select ACA for OCIO support services. Aptus as consultant, provides research, investment recommendations and ongoing monitoring of investment strategies. Aptus has no discretion over client investment portfolios, does not have access to any non-public personal information about clients, and does not vote on the Investment Committee. In these instances, an Advisor selects ACA to provide these services and for this service the Advisor is charged a separate fee for ACA. The consulting services are disclosed in the Advisor’s brochure. The compensation for ACA depends on the negotiated agreement between the Advisor and ACA. ACA’s fee varies based on the scope and complexity of the advisors services being supported. Advisor Agent Services ACA acts as an Advisor agent to Advisors that select ACA for trade and back office support or execution. Aptus as Advisor agent provides trade execution and billing services per instruction from the advisor. Aptus has no discretion over client investment portfolios and is directed via Advisor instructions. In these instances, an Advisor selects ACA to provide these services and for this service the Advisor is charged a separate fee for ACA. The Advisory Agent services are disclosed in the Advisor’s brochure. The compensation for ACA depends on the negotiated agreement between the Advisor and ACA. ACA’s fee varies based on the scope and complexity of the advisors services being supported. Private Label ETF Advisor ACA provides private-label ETF services and has obtained active and passive exemptive relief from the Securities and Exchange Commission under the Investment Company Act of 1940 to assist investment managers and independent advisors in bringing investment strategies to market as Exchange Traded Funds. In these arrangements ACA serves as investment adviser to the Exchange Traded Fund and another firm serves as subadvisor to execute the investment strategy. Compensation for ACA for such services may come from a flat fee, a shared percentage of the stated management fee of the Exchange Traded Fund, or a combination of the two. Fund Specialist Platform Services ACA provides asset management and investment services through its investment management platform (the “Platform”). Among other things, the Platform enables independent investment advisers (each, a “User”) to outsource chief investment officer services to manage their client accounts. The Platform enables Users to create investment proposals, build and implement model portfolios, and create content. The Platform also enables Users to leverage ACA to trade client accounts according to the models and proposals that the User has created or adopted. The specific services available to any User are determined by the agreement that they have entered with ACA. ACA receives compensation from one or more investment managers that offer their investment strategies or products on the Platform (each, a “Fund Specialist”). The financial services industry often refers to these revenue sharing payments as “shelf space” payments because the payments compensate a financial intermediary (in this case ACA) for including strategies, funds, or investment managers on its Platform. Fund Specialists may pay a Platform fee based on: (a) a percentage of the amount of the assets that the Fund Specialist is providing services to on the Platform, or (b) a percentage of revenue generated by the Fund Specialist through its services attributable to the Platform from all sources, including but not limited to any underlying investment company management fees. ACA does not require every Fund Specialist on the Platform to pay a Platform fee and ACA may agree to negotiate different compensation structures than those set forth above. As part of its services on the Platform, ACA may recommend Fund Specialists or include them in investment proposals or model portfolios. These agreements that ACA has with Fund Specialists create a conflict of interest as it creates an incentive for ACA to promote and favor Fund Specialists that compensate ACA or that compensate ACA more than other Fund Specialists. ACA seeks to mitigate this conflict of interest by disclosing its existence to clients and prospective clients of the Platform and allowing them to make an informed decision about the materiality of the conflict. ACA also maintains a list of Fund Specialists for which it maintains a shelf space agreement, which is available upon request.