DESCRIPTION OF FIRM
Syntax Advisors, LLC (“Syntax Advisors,” “us” or “we”) is a SEC-registered investment adviser
with its principal place of business in New York, New York. In 2009, predecessors of Syntax
Advisors began conducting the business currently conducted by us. Rory B. Riggs serves as the
firm’s CEO. Rory B. Riggs is the sole owner member of Syntax Advisors.
Syntax Advisors provides advisory services to Exchange Traded Funds (“ETFs”) registered under
the Investment Company Act of 1940, subject to the supervision of the Board of the Syntax ETF
Trust, (the “Trust”), and a limited number of Separately Managed Accounts (“SMAs”).
Collectively, the ETFs, and SMAs are Syntax Advisors’ clients (our “clients”).
Syntax Advisors provides investors with rules-based, diversified exposure to business risks via
products that track Syntax Stratified Weight Indices. Syntax Indices are a new class of indices
that reweight the most widely-used benchmarks, including but not limited to the S&P 500®
Index, S&P MidCap 400® Index, S&P SmallCap 600® Index, Russell 1000 Index and MSCI
EAFE Index using the Stratified Weight methodology.
Syntax’s Stratified-Weight™ is the weighting method by which Syntax diversifies its indices by
hierarchically grouping and distributing the weight of an index’s constituent companies that share
“Related Business Risks.” Related Business Risk occurs when two or more companies provide
similar products and/or services or share economic relationships such as having common suppliers,
customers or competitors. The process of identifying, grouping, and diversifying holdings across
Related Business Risk groups within an index is called “stratification.” Stratified Weight seeks to
provide investors with more balanced exposure than other weighting methodologies, which can
concentrate in particular sectors and industries, such as those that have seen high recent momentum
or those that have many constituents.
Syntax products were developed in conjunction with Functional Information System (FIS), a
patented business classification system that provides the technology used to identify business risks
in a portfolio. FIS makes it possible to control for risks shared by groups of related companies by:
1) organizing companies that share related business risks into well-defined functional groups; and
2) weighting these groups to spread exposure across these underlying risks. Other commonly used
industry and sector classifications lack codified definitions and instead simply group together
companies that seem similar. FIS-based industries are engineered to reduce performance
distortions caused by the uncontrolled risk exposures that are present
in cap-weighted and equal-
weighted indices. Stratified Weight uses FIS-based sectors to group and limit weighting in
companies that have shared business functions that can make them perform similarly when events
happen to change expectations in a given part of the economy.
As of December 31, 2022, Syntax Advisors had $130,264,303 of collective assets under
management.
Syntax Advisors does not participate in wrap fee programs.
THE TRUST
Syntax Advisors serves as the investment adviser to exchange-traded funds (“ETFs”), subject to
the supervision of the Board of the Trust and is responsible for the investment management of the
ETFs, executed through the selection of the Sub-Adviser for portfolio management and other
agreed upon activities. As the ETFs’ investment adviser, Syntax provides an investment
management program for the ETFs and manages the investment of the ETF assets through sub-
advisory relationships.
Pursuant to an investment sub-advisory agreement with Syntax, Vantage Consulting Group
(“Vantage” or the “Sub-Adviser”) serves as the sub-adviser to the ETFs and performs the day to
day management of the ETFs and places orders for the purchase and sale of securities for the ETFs
(equity portfolio only for SHUS). For its services to the ETFs, the Sub-Adviser is compensated by
Syntax.
Pursuant to an investment sub-advisory agreement with Syntax, Swan Global Investments, LLC
(“Swan”) serves as the options sub-adviser for Syntax Stratified U.S. Total Market Hedged
ETF(“SHUS”). It performs the day to day management of the options strategy for SHUS and
places orders for the purchase and sale of options for SHUS. Swan is compensated by Syntax.
Additional information regarding the services provided by Syntax Advisors to the Trust can be
found in the ETFs’ prospectuses and Statement of Additional Information, which are publicly
available at www.syntaxadvisors.com, on the EDGAR Database on the SEC’s website
(www.sec.gov) or by contacting Foreside Fund Services, LLC at Three Canal Plaza, Suite 100,
Portland, ME 04101 or by calling (866) 972-4492. Foreside Fund Services, LLC is the distributor
of the Syntax ETF Trust, and not affiliated with Syntax Advisors, LLC.
SEPARATELY MANAGED ACCOUNTS
The Syntax Separately Managed Accounts (“SMAs”) provides investment services include, but
are not limited to, interpreting investment objectives and risk tolerance, asset selection and
allocation, organizing, administering to and regular monitoring of portfolio assets, developing
and documenting an individualized investment policy and investment strategy; and managing the
investment process.