Fees and Compensation — Form ADV Part 2A (1/25/2026)
[Brochure]
Item 5 – Fees and Compensation
The fees and compensation payable to TCM vary among the investment products or
institutional separately managed accounts (collectively, the “Clients”) it furnishes advisory
services or sub-advisory services.
Portfolio Management Services
TCM, as the primary investment adviser or sub-adviser to registered investment companies
(“RIC”), which include sponsored and co-sponsored exchange traded fund (“ETF”) offerings,
TCM (either independently or in collaboration with a Sub-Adviser)performs portfolio
management services for these ETFs in exchange for compensation that is owed to the Firm
(and Sub-Adviser, as applicable) as set forth in the fee table of the prospectus. The ETFs for
which TCM provides advisory services are administered through the Trust Sponsors. Each of
the Trust Sponsors has had filed a registration statement the Securities Act of 1933
(“Securities Act”) and Investment Company Act of 1940 (“Company Act”). The Board of
Trustees for those Trust Sponsors in which TCM serves as ETF adviser or sub-adviser provide
governance as does the Trust Chief Compliance Officer (“Trust CCO”). The Trust CCO is
appointed by each respective Trust’s Board of Trustees. ETFs are subject to applicable
requirements set forth in the Securities Act and Company Act, and therefore, TCM has policies
and procedures designed to comply with these regulations. For ETFs which TCM manages the
custodian deducts applicable management fees and pays TCM. TCM or the Trust Sponsor
generally shall provide a portion of the investment management fee to sub-advisors that
render services to TCM sponsored ETFs.
Tuttle Capital Strategies
• The SPAC and New Issue ETF
• Brendan Wood TopGun ETF
• The National Security Emerging Markets Index ETF
• Tuttle Capital 2X Inverse Regional Banks ETF
• Select STOXX® Europe Aerospace & Defense ETF
• Tuttle Capital IBIT 0DTE Covered Call ETF
• Tuttle Capital MSTR 0DTE Covered Call ETF
• Tuttle Capital Magnificent 7 Income Blast ETF
• Tuttle Capital Meme Stock Income Blast ETF
T-REX Strategies
• T-REX 2X Inverse MSTR Daily Target ETF
• T-REX 2X Long MSTR Daily Target ETF
• T-REX 2X Long Microsoft Daily Target ETF
• T-REX 2X Long Alphabet Daily Target ETF
• T-REX 2X Long Apple Daily Target ETF
• T-REX 2X Long NFLX Daily Target ETF
Tuttle Capital Management, LLC 2A Disclosure Brochure Page 8
• T-REX 2X Inverse NVIDIA Daily Target ETF
• T-REX 2X Long NVIDIA Daily Target ETF
• T-REX 2X Inverse TESLA Daily Target ETF
• T-REX 2X Long TESLA Daily Target ETF
• T-REX 2X Inverse Bitcoin Daily Target ETF
• T-REX 2X Long Bitcoin Daily Target ETF
• T-REX 2X Long Ether Daily Target Index ETF
• T-REX 2X Inverse Ether Daily Target Index ETF
• T-Rex 2X Long HOOD Daily Target ETF
• T-REX 2X Long RBLX Daily Target ETF
• T-REX 2X Long DJT Daily Target ETF
• T-REX 2X Long ARM Daily Target ETF
• T-REX 2X Long GLXY Daily Target ETF
• T-REX 2X Long GME Daily Target ETF
• T-REX 2X Long SNOW Daily Target ETF
• T-REX 2X Long CRWV Daily Target ETF
• T-REX 2X Long SMR Daily Target ETF
• T-REX 2X Long DKNG Daily Target ETF
• T-REX 2X Long BULL Daily Target ETF
• T-REX 2X Long CRCL Daily Target ETF
• T-REX 2X Long AXON Daily Target ETF
• T-REX 2X Long AFRM Daily Target ETF
• T-REX 2X Long KTOS Daily Target ETF
• T-REX 2X Long BKNG Daily Target ETF
• T-REX 2X Long UPXI Daily Target ETF
• T-REX 2X Long TTDU Daily Target ETF
• T-REX 2X Inverse CRWV Daily Target ETF
• T-REX 2X Inverse CRCL Daily Target ETF
• T-REX 2X Long BMNR Daily Target ETF
• T-REX 2X Long SBET Daily Target ETF
• T-REX 2X Long CIFR Daily Target ETF
• T-REX 2X Long SOL Daily Target ETF
• T-REX 2X Long XRP Daily Target ETF
• T-REX 2X Long EOSE Daily Target ETF
• The Laddered T-Bill ETF
Other Strategies
• Tapp Alpha SPY Growth & Daily Income ETF
• Rareview 2X Bull Cryptocurrency & Precious Metals ETF
• Opportunistic Trader ETF
• TappAlpha Innovation 100 Growth & Daily Income ETF
• Founder-Led ETF
• Truth Social American Red State REITs ETF
• Truth Social American Energy Security ETF
• Truth Social American Security & Defense ETF
• Truth Social American Next Frontiers ETF
• Truth Social American Icons ETF
• TDAQ LIFT ETF
Tuttle Capital Management, LLC 2A Disclosure Brochure Page 9
• TSPY LIFT ETF
For more information on TCM-sponsored/co-sponsored or sub-advised ETFs, including fees,
costs, and expenses, please visit our website at https://tuttlecap.com.
Separately Managed Accounts
In certain situations. TCM may be engaged as either a primary investment adviser or sub-
adviser to a Separately Managed Account or WRAP Program Account (i.e. advisory programs
in which the advisory fees and other expenses including transaction and/or custodial fees are
bundled into a pre-determined fee percentage) for Institutional Investor Clients sponsored
by an independent and unaffiliated registered investment adviser (“RIA”). In these
circumstances, the RIA, and not the underlying investor, is the client of TCM. As such, when
TCM does not maintain the underlying investor’s financial information, investment objectives
or risk tolerance as that detailed review is to be performed by the RIA. Accordingly, the RIA
maintains the fiduciary obligation to the underlying investor whereas TCM acts in the
capacity of an “Independent Manager” and provides advisory services to the institutional
SMA or institutional WRAP Program Account according to the portfolio model strategy
determined by the RIA. In our relationship as Independent Manager,
TCM does not deduct any investment management fees directly but will receive
...
Account Minimums and Types of Clients — Form ADV Part 2A (1/25/2026)
[Brochure]
Item 7 – Types of Clients
TCM provides investment management services through advisory or subadvisory
arrangement and on either a discretionary or non-discretionary basis to investment advisers
registered with the SEC or state jurisdictions, registered investment companies and
commodity pools. TCM also provides customized investment advice through separately
managed accounts on either a discretionary or non-discretionary basis to institutional
investors inclusive of charitable organizations, corporations and other types of business
entities.
TCM may also provide OCIO services, Outsourced Trading services and/or subadvisory
services to SEC and/or stateregistered investment advisers (“together “RIAs”), financial
planning firms, brokerdealers, banks and other financial institutions that maintain ongoing
relationships with clients. TCM also furnishes White Label ETFs to RIAs and/or other
financial institutions for which our Firm maintains business relationships.
Tuttle Capital Management, LLC 2A Disclosure Brochure Page 12
Engaging the Services of TCM
All financial institutions, including SEC and stateregistered investment advisers, must first
execute a subadvisory agreement that provides TCM with the authority to invest all or some
of the subadvisory client’s assets in one or more of the Adviser’s strategy programs.