Tuttle Capital Management, LLC (“TCM”, the “Firm” or the “Adviser”), a is a privately held limited liability company organized under the laws of Delaware that has been registered with the SEC since August 2012. Matthew (“Matt”) B. Tuttle is the founder, owner, Chief Executive Officer (“CEO”), Chief Investment Officer (“CIO”) and portfolio manager (“PM”) of TCM and, as such, the Adviser and its operations are solely under his control. As of March 15, 2024, TCM managed a total of approximately $680,855,217 in regulatory assets under management (“RAUM”). All of TCM’s RAUM is managed on a discretionary basis. At present, the Firm does not manage any RAUM on a non-discretionary basis. The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to TCM and the words "you," "your," and "Client" refer to you as either a client or prospective client of our firm. At present, TCM does not provide direct advisory services to any client defined under SEC rules as a “Retail Investor.” Portfolio Management Services Investment Management Services TCM, where applicable, offers primarily discretionary investment management services directly to pooled investment vehicles, namely, registered investment companies (“RICs”), including exchange traded funds (“ETFs”) for which the Firm sponsors/co-sponsors or through sub-advisory agreements with other SEC-registered investments. V. Where TCM is adviser or sub-adviser to RIC, it shall manage the portfolio in accordance with the prospectus and other applicable regulatory requirements, namely, those promulgated under the Investment Company Act of 1940 (“Company Act”). TCM also offers services directly to institutional investor clients through an investment advisory arrangement with other registered investment advisers (“RIAs”) and to other financial professionals through an investment management arrangement. TCM creates specialized portfolios that primarily utilize individual equities, bonds, special purpose acquisition companies (“SPACs”), security-based swaps, and exchange traded funds. The Adviser’s strategy programs range from conservative to aggressive and take an active approach to investing in several different equity and fixed income markets. Please see Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss – for a more in-depth discussion of TCM’s strategy programs. Sub­Advisory Services TCM offers sub-advisory investment management services to SEC and state-registered investment advisers, financial planning firms, broker-dealers, banks and other financial institutions (or the “primary investment adviser”) that maintain ongoing relationships with clients. When these arrangements exist, TCM will enter into an agreement with the primary investment adviser to provide investment management services to the clients it accepts from those firms (the “sub-advisory client”). TCM reserves the right, in its sole and absolute discretion, to not accept a client account under a sub-advisory arrangement. Tuttle Capital Management, LLC 2A Disclosure Brochure Page 5 Under the sub-advisory arrangement, the primary investment adviser remains responsible for determining sub-advisory clients’ investment objectives and whether one or more of the firm’s programs are suitable to meet such investment objectives. TCM is responsible for the discretionary management of the assets which the primary investment adviser has instructed be invested in one or more of the Adviser’s programs. Each program is designed to achieve particular investment goals. Accordingly, the tactical strategy programs are not tailored to accommodate the needs or objectives of specific clients, but rather, are designed to enable the investment adviser to match clients with a tactical strategy consistent with their investment goals. Separately Managed Accounts TCM offers investment advisory services to institutional investors f through separately managed accounts (“SMAs”). SMAs are advisory accounts managed by TCM and investors in the SMAs must take custody of their assets and monies at a qualified independent custodian, which is typically a broker-dealer/custodian organization. TCM will assist the investors in selection of custodian. TCM will typically exercise investment discretion including, but not limited to, the type and amount of securities and other financial instruments purchased and sold, subject to investment guidelines in the applicable client’s investment management agreement which may be periodically updated by the client. These guidelines would generally vary among clients with respect to investment objectives, strategies, policies, and limitations. WRAP Program Accounts TCM does not sponsor WRAP programs but may be engaged as a primary investment adviser or sub-adviser to furnish investment management services as a participant to WRAP programs sponsored by other RIAs. Other Services Outsourced Chief Investment Officer (OCIO) Services. TCM offers customized OCIO services for financial institutions, including registered investment advisers and other institutional investors. For more information, visit our website at https://tuttlecap.com/outsourced-cio- services. Outsourced Trading. TCM offers trading, portfolio management, operations, and capital markets services for ETFs and Mutual Funds. Our services are highly customizable and can range from intraday trading to annual rebalances. For more information,

visit our website at https://tuttlecap.com/white-label-etfs-outsourced-trading/ White Label ETFs. TCM is looking to partner with select issuers with innovative ideas. We are specifically looking for win/win relationships where nobody makes money unless a fund is profitable. For more information, visit our website at https://tuttlecap.com/white-label-etfs. Services Limited to Specific Types of Investments TCM does not limit its investment advice and/or money management to separately management accounts or other arrangements for which our Firm provides direct advisory services. TCM does generally limit the nature and scope of the investment recommendations Tuttle Capital Management, LLC 2A Disclosure Brochure Page 6 concerning our Firm’s investment management services, including, where TCM is primary investment adviser to its sponsored ETFs. In this regard, product recommendations generally include ETFs (including proprietary or non-proprietary ETFs), mutual funds, ), equities including exchange traded securities, fixed income (e.g., bonds, debt securities), swaps (i.e. security-based), master limited partnerships (“MLPs”), hedge funds, real estate investment trusts (“REITs”), insurance products including annuities, private placements, and securities issues by the U.S. government or agencies thereunder. TCM may use other securities (including derivatives) as well to help diversify a portfolio where necessary. Client Tailored Services and Client Imposed Restrictions TCM offers customized strategy programs as an investment option to institutional investors through the use of SMAs and WRAP Program Accounts sponsored by other RIAs. In situations where TCM is the primary investment adviser to the institutional investor, reasonable investment-related restrictions, guidelines or limitations sought by the investor must be, in writing, and will be considered by the CEO/CIO. TCM reserves the exclusive right to accept or decline such requests. If the restriction(s) is accepted at our Firm’s discretion, TCM will implement the attendant requirements into the management of the portfolio. A restriction or limitation request will not be honored if it is fundamentally inconsistent with TCM’s investment philosophy. It is in TCM’s sole and absolute discretion whether or not to accept such restrictions or limitations, Where TCM serves as sub-adviser to the SMA or WRAP Program Account, requests for reasonable restrictions on the portfolio must be made directed to the primary investment adviser and will be, in turn, memorialized in writing (preferably the sub-advisory agreement). Upon acceptance of the account relationship, TCM will abide by the restrictions imposed in fulfilling its sub-advisory services.. ETFs or other pooled investment vehicles for which TCM may act in the capacity of primary investment adviser or sub-adviser do not permit the investor to directly access customized investment solutions tailored to their individual investment objectives, financial considerations, and risk tolerance and/or permit requests of reasonable restrictions for the investment manager to follow. Conflicts of Interests Securities Transactions. TCM, in its capacity of portfolio manager (“PM”) for sponsored ETF offerings and as a sub-adviser to third party ETF offerings, may execute transactions for certain clients (i.e., registered investment companies) that may adversely impact the value of securities held by other clients. Specifically, due to inherent differences amongst account objectives, benchmarks, time horizons, and fees, a conflict exists whereupon the Firm’s execution of securities transactions for certain accounts may adversely impact securities values of other client portfolios resulting in varying performance results. Other Professional Responsibilities. As TCM’s CEO/CIO, Mr. Tuttle, serves as PM to multiple investment offerings, his responsibilities to devote time and resources to any one particular fund is limited. In addition, it is possible that the investment objectives and transactions executed in one or more funds may adversely affect the strategies and performance of other funds in which advisory services involving Mr. Tuttle are performed. Marketing and Distribution. TCM may maintain a responsibility to assist in the distribution of shares of ETFs it manages or sub-advises and, in fact, its compensation is indirectly linked to sale the fund shares thereby creating an incentive to devote time to marketing efforts. Tuttle Capital Management, LLC 2A Disclosure Brochure Page 7 Compensation Arrangements. TCM receives remuneration from other investment advisers, , which is based, in part, a portion of applicable management fees attendant to fund offerings sponsored by those firms in exchange for rendering services. As a result, TCM has a conflict of interest insofar as it receives a higher dollar amount in revenue based on growth of the assets under management for those offerings. TCM has mitigated this conflict through disclosure and implementation of a Code of Ethics (which is described in Item # 11). Multiple Advisory Services. Where TCM provides more than one of our Firm’s advisory services to institutional investors, such as where the investor allocates monies to TCM ETFs and an Institutional SMA that our Firm is investment manager or sub-adviser, could pose a conflict. For example, recommendations made on behalf of a TCM-managed ETF and TCM- advised SMA that the same investor allocates funds may result in an increase to the asset level of both investments thereby increasing the advisory fees paid to our Firm.