Advisory Firm Description Cultivar Capital, Inc. ("Cultivar" or the "Firm") is a fee-only registered investment advisory firm. The owner of the Firm, Thomas E. Muir, has over 25 years of financial industry experience, initially in accounting and then as a principal at a prior advisory firm starting in 1999 and subsequently forming Cultivar in December 2011. Types of Advisory Services PORTFOLIO MANAGEMENT SERVICES Cultivar provides investment supervisory services, including portfolio selection and portfolio management services. Investment advice is based on the individual needs and objectives of the client. Progress toward the client's goals is monitored periodically. When opening an investment management account, the advisory representative obtains the necessary information to assist the client in determining the suitability of an investment program. This includes helping the client assess his or her risk tolerance and setting appropriate investment objectives (e.g., lower volatility, medium volatility, higher volatility, etc.). An advisory representative of Cultivar then suggests investment portfolio alternatives to meet the client’s objectives, factoring in the current investment and economic conditions. Clients are under no obligation to accept recommendations by the advisor or authorize transactions through the advisor. FUND MANAGEMENT In December 2021, Cultivar became the investment adviser to the Cultivar ETF (the “Fund”). The Fund (Cboe Ticker: CVAR) is a non-diversified series of ETF Opportunities Trust, a Delaware statutory trust (the “Trust”). The Trust is registered as an open-end management investment company subject to the rules and regulations promulgated under the Investment Company Act of 1940 (“Company Act”). The Trust, of which the Cultivar ETF is a component, is governed by its Board of Trustees (the “Board” or “Trustees”). The investment adviser to the Fund is Cultivar Capital, Inc. (the “Adviser”), and the sub-adviser to the Fund is Toroso Investments, LLC. (the “Sub-Adviser”). The Sub-Adviser is not affiliated with Cultivar. The Fund may issue an unlimited number of shares of beneficial interest (“Shares”). All Shares have equal rights and privileges. Each Share is entitled to one vote on all matters as to which Shares are entitled to vote. In addition, each Share is entitled to participate equally with other Shares (i) in dividends and distributions declared by the Fund and (ii) on liquidation to its proportionate share of the assets remaining after satisfaction of outstanding liabilities. Shares are fully paid, non-assessable, and fully transferable when issued and have no pre-emptive, conversion, or exchange rights. Fractional Shares have proportionately the same rights, including voting rights, as are provided for a full Share. The Firm may recommend an investment in the Cultivar ETF, an exchange-traded fund, to certain Clients based on their financial situations and investment objectives. When this occurs, a potential conflict of interest exists since the Firm is the Adviser to the Cultivar ETF. However, the Firm will be waiving its current advisory fee on the assets invested in the Cultivar ETF to mediate this potential conflict of interest. Moreover, the Firm will conduct training of its personnel, perform periodic review of the investment selections, provide appropriate disclosures, and implement applicable policies and procedures. The Firm will provide investment advisory services to the Fund pursuant to an investment advisory agreement (the “Advisory Agreement”). Under the terms of the Advisory Agreement, the Firm manages the investment portfolio of the Fund, subject to the policies adopted by the Trust’s Board of Trustees. In addition, the Adviser: (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 Trust’s Board of Trustees; and (iii) is responsible for oversight of the Fund’s sub-adviser. Under the Advisory Agreement, Cultivar assumes and pays, at its own expense and without reimbursement from the Trust, all ordinary expenses of the Fund, except the fee paid to the Firm pursuant to the Advisory Agreement, interest expenses, taxes, acquired fund fees and expenses, brokerage commissions and any other portfolio transaction-related expenses and fees arising out of transactions effected on behalf of the Fund, 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. FINANCIAL PLANNING SERVICES Cultivar provides ongoing financial planning advice to clients as an integral part of its services. This is most often done during routine client meetings on a consultative basis as client issues and inquiries arise. It is a significant part of the overall client relationship, as Cultivar desires to be available for clients as they face life circumstances. During client consultations, a representative of Cultivar addresses various topics of concern

to clients, including all or selected topics from the following areas as they apply to each client’s situation:
• Retirement Planning
• Education Planning
• Investment Planning
• Portfolio Analysis
• Tax Planning
• Risk Management
• Estate Planning Should a client choose to implement recommendations discussed during this consultative process, Cultivar suggests a client work closely with his/her attorney, accountant, insurance agent, and other professionals that he/she may wish to consult. Implementation of recommendations is entirely at the client’s discretion. ERISA PLAN SERVICES Cultivar offers services to qualified and non-qualified retirement plans, including 401(k) plans and pension and profit- sharing plans. Cultivar may act as a 3(21): Limited Scope ERISA 3(21) Fiduciary. Cultivar acts as a limited scope ERISA 3(21) fiduciary that can advise, help, and assist plan sponsors with their investment decisions. As an investment advisor, Cultivar has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using Cultivar can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services may include:
• Provide investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Clients will make the final decision regarding the initial selection, retention, removal, and addition of investment options. Cultivar acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404© (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management, and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with the Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services may include:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands Cultivar’s assistance in the education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Cultivar is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Cultivar will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Cultivar may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Cultivar and Client. 3. Cultivar has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in the calculation of Fees paid to Cultivar on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. Tailored Advisory Services Each portfolio is tailored similarly by matching a client’s investment objective and risk tolerance, goals, and objectives to the appropriate asset allocation and mix of securities. Clients have the ability to restrict the Firm from buying or selling particular investments in their portfolios. Any client may change or add restrictions at any time by notifying Cultivar in writing or by phone. Client Assets Under Management As of December 31, 2023, the Firm had $299,238,668 of total assets under management, all of which is managed on a discretionary basis.