What changed in this filing

/stocks — the workspaceLOADING

Item 1. Business

2020-09-28 compared with 2019-09-30 · 338 added, 311 removed, 941 unchanged (41% of the section changed)

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to RISE commencing operations, SIT made an initial investment of $5,000,000 in exchange for 200,000 shares of RISE.

June 30, 2019, Sit had redeemed 70,000 shares, thereby reducing its investment in RISE to 130,000 shares.

2020, Sit had redeemed 138,800 shares, thereby reducing its investment in RISE to 61,200 shares.

Investing Strategy

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Component Instruments currently constituting the RISE Benchmark Portfolio as of June 30, 2020 include:

STATES TREASURY BILLS

UNITED STATES TREASURY BILLS

5 YR FUTR OPTN SEP 20 C $125.50

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2 YR NOTE (CBT) SEP 20

(10,158,094 )

10 YR FUT OPTN SEP 20 P $139.50

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EXCHANGE PANAMAX T/C AVERAGE SHIPPING ROUTE INDEX - JUL 20

EXCHANGE PANAMAX T/C AVERAGE SHIPPING ROUTE INDEX - AUG 19

EXCHANGE PANAMAX T/C AVERAGE SHIPPING ROUTE INDEX - SEP 19

EXCHANGE SUPRAMAX T/C AVERAGE SHIPPING ROUTE - JUL 19

S58FM N19 SSYF

EXCHANGE SUPRAMAX T/C AVERAGE SHIPPING ROUTE - AUG 19

EXCHANGE SUPRAMAX T/C AVERAGE SHIPPING ROUTE - SEP 19

CAPESIZE TIME CHARTER - JUL 19

CAPESIZE TIME CHARTER - AUG 19

CAPESIZE TIME CHARTER - SEP 19

BFFAP N20 Index

BALTIC EXCHANGE

PANAMAX T/C AVERAGE SHIPPING ROUTE INDEX - AUG 20

BFFAP Q20 Index

BALTIC EXCHANGE

PANAMAX T/C AVERAGE SHIPPING ROUTE INDEX - SEP 20

BFFAP U20 Index

BALTIC EXCHANGE

SUPRAMAX T/C AVERAGE SHIPPING ROUTE INDEX - JUL 20

S58FM N20 Index

BALTIC EXCHANGE

SUPRAMAX T/C AVERAGE SHIPPING ROUTE INDEX - AUG 20

BALTIC EXCHANGE

SUPRAMAX T/C AVERAGE SHIPPING ROUTE INDEX - SEP 20

BALTIC CAPESIZE

TIME CHARTER - JUL 20

BFFATC N20 Index

BALTIC CAPESIZE

TIME CHARTER - AUG 20

BFFATC Q20 Index

BALTIC CAPESIZE

TIME CHARTER - SEP 20

BFFATC U20 Index

value of the Capesize 5TC Index is disseminated at 11:00 a.m., London Time and the value of the Panamax 4TC Index and the Supramax

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Futures Commission Merchant

Currently, SG

Americas Securities, LLC, a Delaware limited liability company, serves as RISE’s clearing broker to execute and clear RISE’s

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January 2, 2015, Newedge USA, LLC (“Newedge USA”

or “NUSA”) merged with and into SGAS, with the latter as the

surviving entity.

or “NUSA”) merged with and into SGAS, with the latter

as the surviving entity.

following disclosure is intended to provide information that may be material to an FCM customer regarding administrative, civil,

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regulatory, civil and arbitration proceedings involving SGAS or legacy Newedge USA is available through FINRA’s BrokerCheck

(which can be accessed electronically at www.finra.org ), the National Futures Association’s

Background Affiliation Status Information Center (which can be accessed electronically at www.nfa.futures.org/basicnet ).

In addition, proceedings that are material to SGAS’s ultimate corporate parent Societe Generale are described under

the caption “Compliance, Reputational and Legal Risks”

in Societe Generale’s annual Registration Document and

associated updates (which are available through the Societe Generale website at www.societegenerale.com) .

Regulatory Proceedings

February 2015, SGAS, as successor to Newedge USA, settled, without admitting or denying the allegations, a matter brought by

the CME Group alleging that on multiple occasions between 2010 and 2012, Newedge USA employees executed certain

customers’

orders as EFRPs, instead of on CME Group’s GLOBEX platform.

The settlement also included allegations

that EFRPs were non bona fide and/or inadequately documented.

In connection with this matter, SGAS paid a fine of $1,100,000

to Comex and $650,000 to NYMEX.

(which can be accessed electronically at www.finra.org ), the National Futures Association’s Background Affiliation

Status Information Center (which can be accessed electronically at www.nfa.futures.org/basicnet ).

In addition, proceedings

that are material to SGAS’s ultimate corporate parent Societe Generale are described under the caption “Compliance,

Reputational and Legal Risks”

in Societe Generale’s annual Registration Document and associated updates (which are

available through the Societe Generale website at www.societegenerale.com) .

In October 2015, SGAS,

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of the exchange over a period of approximately twenty-two business days in May and June 2014.

In connection with this matter,

SGAS paid a fine of $100,000.

October 2015, SGAS, as successor to Newedge USA, settled, without admitting or denying the allegations, a matter brought by

FINRA for failing to report certain short interest positions in 2010-2012.

In connection with this matter, SGAS paid a fine

in the amount of $120,000.

Beginning in late 2013,

the SEC reviewed transactions by SGAS’s Non-Agency Mortgage Desk in which SGAS bought baskets of securities from a counterparty

and sold the securities back to the same counterparty, and also reviewed communications with counterparties regarding certain riskless

In connection with this matter, SGAS

paid a fine of $100,000.

In October 2015, SGAS,

as successor to Newedge USA, settled, without admitting or denying the allegations, a matter brought by FINRA for failing to report

certain short interest positions in 2010-2012.

In connection with this matter, SGAS paid a fine in the amount of $120,000.

Beginning in late 2013, the SEC reviewed

transactions by SGAS’s Non-Agency Mortgage Desk in which SGAS bought baskets of securities from a counterparty and sold

the securities back to the same counterparty, and also reviewed communications with counterparties regarding certain riskless

principal trades.

The SEC reviewed transactions that occurred between approximately December 2011 and June 2013.

SGAS cooperated

with the investigation and disciplined the trader involved and her supervisor.

In December 2015, SGAS paid $1,011,093 to settle

the matter, consisting of a $800,000 fine and $211,093 in disgorgement

including interest.

cooperated with the investigation and disciplined the trader involved and her supervisor.

In December 2015, SGAS paid $1,011,093

to settle the matter, consisting of a $800,000 fine and $211,093 in disgorgement including interest.

In December 2015, SGAS,

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this settlement, SGAS paid a fine of $650,000.

In June 2016, SGAS, as

successor to Newedge USA, settled, without admitting or denying the allegations, a matter brought by the Chicago Board of Trade

In June 2016, SGAS,

as successor to Newedge USA, settled, without admitting or denying the allegations, a matter brought by the Chicago Board of Trade

(CBOT) alleging that on six days between November 2013 and January 2014, three traders for Newedge (one employed by Newedge and

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of profits in the amount of $19,502.50.

In September 2016, SGAS,

as successor to Newedge USA, settled, without admitting or denying the allegations, a matter brought by the CFTC alleging Newedge

USA violated Section 4C(A) of the Commodity Exchange Act and Regulations 1.38 and 166.3 by executing and confirming numerous exchange

for physical transactions in agricultural and soft commodities for and on behalf of its clients that were for the same contract,

quantity and same or similar price with the buyer and seller for each transaction under the same common control and ownership.

In September 2016,

SGAS, as successor to Newedge USA, settled, without admitting or denying the allegations, a matter brought by the CFTC alleging

Newedge USA violated Section 4C(A) of the Commodity Exchange Act and Regulations 1.38 and 166.3 by executed and confirming numerous

exchange for physical transactions in agricultural and soft commodities for and on behalf of its clients that were for the same

contract, quantity and same or similar price with the buyer and seller for each transaction under the same common control and ownership.

The settlement includes a $750,000 civil penalty and an undertaking to implement policies, procedures and training programs reasonably

designed to prevent the execution, clearing and reporting to an exchange of non-bona fide exchange of futures for physical transactions.

April 2017, SGAS settled, without admitting or denying the allegations, a matter brought by the Chicago Board of Options

Exchange and NYSE ARCA, Inc, for failing to report, or accurately report, “reportable positions”

option position report in violation of Exchange Rules 4.2 and 4.13.

In connection with this matter, SGAS paid a fine of

$100,000 to each of the Cboe and NYSE ARCA, Inc.

In April 2017, SGAS, as

successor to Newedge USA settled, without admitting or denying the findings, a matter brought by FINRA for failing to establish

In April 2017, SGAS

settled, without admitting or denying the allegations, a matter brought by the Chicago Board of Options Exchange and NYSE ARCA,

for failing to report, or accurately report, “reportable positions”

on its large option position report in violation

of Exchange Rules 4.2 and 4.13.

In connection with this matter, SGAS paid a fine of $100,000 to each of the Cboe and NYSE ARCA,

In April 2017, SGAS,

as successor to Newedge USA settled, without admitting or denying the findings, a matter brought by FINRA for failing to establish

and maintain a supervisory system reasonably designed to ensure that customers were sent account statements, notified of availability

of statements on its customer portal, agreed to receive statements and confirmations electronically, and were sent confirmations

which contained all of the required information, The settlement included payment of a fine in

the amount of $100,000.

In July 2017, SGAS settled,

without admitting or denying the findings, a matter with the CME Group where the CME alleged SGAS violated CME Rules 9.70.A., 971.A.2.A.,

which contained all of the required information.

The settlement included payment of a fine in the amount of $100,000.

In July 2017, SGAS

settled, without admitting or denying the findings, a matter with the CME Group where the CME alleged SGAS violated CME Rules 9.70.A.,

971.A.2.A., B.

and C., 980.A.

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The settlement related to two separate CME exam findings:

1) balances were not consistently

identifiable in the general ledger and 2) procedures for resolving the general ledger suspense balances were not sufficient.

connection with this matter, SGAS paid a fine of $150,000.

January 2018, SGAS, without admitting or denying the findings, settled a matter with FINRA in which FINRA alleged SGAS

failed to meet certain FINRA trade reporting requirements and also disclosed the incorrect capacity on certain customer

confirmations, in violation of various FINRA and NASD rules.

In connection with this matter, SGAS paid a fine of $200,000 and also undertook to re-report certain trades, pay associated

transaction fees not previously paid due to the reporting issues, and revise certain of its written supervisory

March 2018, SGAS settled, without admitting or denying the findings, a matter brought by FINRA in connection with SGAS’s

over-submissions of shares in certain tender offers.

1) balances were not

consistently identifiable in the general ledger and 2) procedures for resolving the general ledger suspense balances were not sufficient.

In connection with this matter, SGAS paid a fine of $150,000.

In January 2018, SGAS,

without admitting or denying the findings, settled a matter with FINRA in which FINRA alleged SGAS failed to meet certain FINRA

trade reporting requirements and also disclosed the incorrect capacity on certain customer confirmations, in violation of various

FINRA and NASD rules.

In connection with this matter, SGAS paid a fine of $200,000 and also undertook to re-report certain trades,

pay associated transaction fees not previously paid due to the reporting issues, and revise certain of its written supervisory

In March 2018, SGAS

settled, without admitting or denying the findings, a matter brought by FINRA in connection with SGAS’s over-submissions

of shares in certain tender offers.

The settlement included payment of a fine in the amount of $50,000 plus disgorgement

of profits in the amount of $469,130.

In September 2018, SGAS

settled, without admitting or denying the findings, a matter brought by the SEC alleging that in 2012-2015 Newedge USA (and then

SGAS) engaged in transactions in pre-released American Depositary Receipts (ADRs) without complying with certain obligations of

the Securities Act of 1933, and failed to supervise borrowing and lending of pre-released ADRs by its personnel in violation of

certain provisions of the Exchange Act of 1934.

The settlement included payment of a $250,000 fine, $486,672 in disgorgement, and

$82,657 in pre-judgment interest.

October 2018, SGAS settled, without admitting or denying the findings, a matter brought by FINRA on behalf of Cboe BZX, Cboe EDGA,

Cboe EDGX, Nasdaq and Nasdaq PHLX regarding incorrect use of capacity codes on exchange orders in 2014-2016.

The settlement included

payment of fines totaling $175,000.

In April 2019, SGAS settled,

without admitting or denying the findings, a matter brought by FINRA on behalf of NYSE Arca and Cboe regarding deficiencies

In September 2018,

SGAS settled, without admitting or denying the findings, a matter brought by the SEC alleging that in 2012-2015 Newedge USA (and

then SGAS) engaged in transactions in pre-released American Depositary Receipts (ADRs) without complying with certain obligations

of the Securities Act of 1933, and failed to supervise borrowing and lending of pre-released ADRs by its personnel in violation

of certain provisions of the Exchange Act of 1934.

The settlement included payment of a $250,000 fine, $486,672 in disgorgement,

and $82,657 in pre-judgment interest.

In October 2018, SGAS

settled, without admitting or denying the findings, a matter brought by FINRA on behalf of Cboe BZX, Cboe EDGA, Cboe EDGX, Nasdaq

and Nasdaq PHLX regarding incorrect use of capacity codes on exchange orders in 2014-2016.

The settlement included payment of fines

totaling $175,000.

In April 2019, SGAS

settled, without admitting or denying the findings, a matter brought by FINRA on behalf of NYSE Arca and Cboe regarding deficiencies

in large option position reporting at NUSA.

The settlement included payment of a fine totaling $600,000.

In April 2019, SGAS settled,

without admitting or denying the findings, a matter brought by NYSE Regulation Enforcement which concerned an equity trade error

in 2015 allegedly improperly offset by an affiliate trade.

The settlement also alleged inadequate market access controls, testing,

and supervisory failures associated with the cause of the trade error.

The settlement included payment of a fine in the amount

In April 2019, SGAS

settled, without admitting or denying the findings, a matter brought by NYSE Regulation Enforcement which concerned an equity trade

error in 2015 allegedly improperly offset by an affiliate trade.

The settlement also alleged inadequate market access controls,

testing, and supervisory failures associated with the cause of the trade error.

The settlement included payment of a fine in the

amount of $380,000.

In May 2019, SGAS settled,

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The settlement included payment of fines totaling $115,000.

In July 2019, SGAS settled,

without admitting or denying the findings, two matters brought by the CBOT and the New York Mercantile Exchange (“NYMEX”),

In July 2019, SGAS

settled, without admitting or denying the findings, two matters brought by the CBOT and the New York Mercantile Exchange (“NYMEX”),

which alleged impermissible pre-hedging of block trades as well as late and inaccurate block trade reporting in 2014-2016.

settlement included payment of fines totaling $350,000 and disgorgement of profits totaling $152,625.

In October 2019, SGAS

settled, without admitting or denying the findings, a matter brought by NYSE Regulation Enforcement regarding alleged violations

of SEC Regulation SHO and trading through National Best Bid or Offer in two instances, as well as a locate latency issue.

The settlement

included payment of a fine of $325,000.

In December 2019, SGAS

settled, without admitting or denying the findings, a matter brought by FINRA on behalf of Cboe Exchange, Inc.

concerning late

submissions of options orders into Cboe’s monthly pricing process for its volatility index (VIX).

The settlement included

payment of a fine totaling $135,000.

In December 2019, SGAS

settled, without admitting or denying the findings, a matter brought by NYSE Regulation Enforcement regarding alleged violations

of NYSE Rules 132 and 7.33, by transmitting orders with discontinued account type indicators between 2016 and 2019.

The settlement

included payment of a fine totaling $100,000.

The Official Committee

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AllianceBernstein L.P., et al.

lawsuits arising from the bankruptcy of the Tribune Company, which was the subject of a leveraged buyout in 2007.

The suits generally

allege that the LBO left the company overleveraged, thus leading to its bankruptcy, and seek to recover payments made to holders

of Tribune shares under various federal and state law theories of liability.

The lawsuits have been dismissed and are now on appeal.

are lawsuits arising from the bankruptcy of the Tribune Company, which was the subject of a leveraged buyout in 2007.

suits generally allege that the LBO left the company overleveraged, thus leading to its bankruptcy, and seek to recover payments

made to holders of Tribune shares under various federal and state law theories of liability.

The lawsuits have been dismissed

and are now on appeal.

SGAS is defending the cases.

Opportunity Fund LLC v.

Newedge USA, LLC is a FINRA arbitration filed by a former NUSA customer alleging claims of fraud,

deceptive trade practices, breach of fiduciary duty, breach of contract, and violation of Illinois Securities Law.

NUSA is alleged

to be responsible for capital losses due to false representations of risk management by NUSA.

SGAS is defending the case.

Global Investors GmbH, et al.

Vega Opportunity

Newedge USA, LLC is a FINRA arbitration filed by a former NUSA customer alleging claims of fraud, deceptive trade

practices, breach of fiduciary duty, breach of contract, and violation of Illinois Securities Law.

NUSA is alleged to be

responsible for capital losses due to false representations of risk management by NUSA.

This matter has been settled and

the matter is now over.

Allianz Global Investors

Bank of America Corporation, et al.

is a litigation filed on behalf of entities that decided

to opt out of the class action settlement in the action In re Foreign Exchange Benchmark Rates Antitrust Litigation, which alleged

conspiracy to fix prices in the FX market beginning in 2003.

is a litigation filed on behalf of entities that decided to opt out of

the class action settlement in the action In re Foreign Exchange Benchmark Rates Antitrust Litigation , which alleged conspiracy

to fix prices in the FX market beginning in 2003.

SGAS is defending the case.

In re ProShares Trust

II Securities Litigation is a putative class action brought by investors in ProShares Short VIX Short-Term Futures ETFs, which

lost significant value in February 2018.

In re ProShares

Trust II Securities Litigation is a putative class action brought by investors in ProShares Short VIX Short-Term Futures ETFs,

which lost significant value in February 2018.

In addition to claims against the issuer, the action asserts claims under the Securities

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based upon purported misstatements or omissions by the issuer in the offering documents.

The complaint was dismissed in January

2020 and the matter is now on appeal.

SGAS is defending the case.

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SG and SGAS are defending the cases.

re GSE Bonds Antitrust Litigation is a putative class action asserting antitrust claims under the Sherman Act against

SGAS and other financial institutions based upon alleged anti-competitive behavior in the trading of bonds issued by U.S.

Sponsored Enterprises (GSEs), i.e., Federal Home Loan Bank (FHLB), Federal Home Loan Mortgage Corporation (Freddie Mac), and

Federal National Mortgage Association (Fannie Mae).

SGAS is defending the case.

SGAS has also been named

in purported class and individual actions in connection with its role in underwriting various debt and equity securities offerings.

Currently pending matters relate to the offerings of TerraForm Global, Southwestern Energy, Plains All American and Altice USA.

Claims in all these cases are asserted under the Securities Act of 1933 and/or state law against SGAS in its role as a member of

the underwriting syndicate, and are based upon purported misstatements or omissions by the issuers in the offering documents.

is defending the cases.

Neither SGAS nor any affiliate,

officer, director or employee thereof have passed on the merits of this Memorandum or offering, or give any guarantee as to the

performance or any other aspect of the Fund.

In re GSE Bonds

Antitrust Litigation is a putative class action asserting antitrust claims under the Sherman Act against SGAS and other financial

institutions based upon alleged anti-competitive behavior in the trading of bonds issued by U.S.

Government Sponsored Enterprises

(GSEs), i.e., Federal Home Loan Bank (FHLB), Federal Home Loan Mortgage Corporation (Freddie Mac), and Federal National Mortgage

Association (Fannie Mae).

In January 2020, a global class action settlement involving multiple banks, including SGAS, was preliminarily

approved by the court.

State of Louisiana v.

Bank of America, N.A., et al.

City of Baton Rouge v.

Bank of America, N.A.,

and Louisiana Asset Management Pool v.

Bank of America Corporation, et al.

are pending individual lawsuits containing

similar allegations.

SGAS is defending the cases.

SGAS has also been

named in purported class and individual actions in connection with its role in underwriting various debt and equity securities

Currently pending matters relate to the offerings of Southwestern Energy and Altice USA.

Claims in these

cases are asserted under the Securities Act of 1933 against SGAS in its role as a member of the underwriting syndicate and are

based upon purported misstatements or omissions by the issuers in the offering documents.

SGAS is defending the cases.

Neither SGAS nor any

affiliate, officer, director or employee thereof have passed on the merits of this Memorandum or offering, or give any guarantee

as to the performance or any other aspect of the Fund.

Futures Commission Merchant

Futures USA LLC (“Macquarie”) serves as BDRY’s broker clearing broker to execute and clear BDRY’s futures

and options transactions and provide other brokerage-related services.

Futures USA LLC (“Macquarie”) serves as BDRY’s broker clearing broker to execute and clear BDRY’s

futures and options transactions and provide other brokerage-related services.

Macquarie is an FCM registered with the CFTC.

estimated that, on an annual basis, it will pay 0.76% of BDRY’s NAV in brokerage fees for execution and clearing services

on behalf of BDRY.

BDRY has estimated that, on an annual basis, it will pay approximately 0.40% (excluding the impact on the Fund of

creation and/or redemption activity) of BDRY’s NAV in brokerage fees for execution and clearing services on behalf of

Macquarie’s

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(the “CTA Fee”).

pays the Sponsor Fee monthly in arrears, in an amount equal to the greater of 0.15% per annum of the value of RISE’s average

daily net assets or $75,000 effective January 1, 2018.

The Sponsor Fee is paid in consideration of the Sponsor’s management

services to RISE.

Prior to January 1, 2018, RISE’s Sponsor Fee was calculated as the greater of 0.15% per annum of the value

of RISE’s average daily net assets or, $18,750 for the year ended December 31, 2018.

RISE also pays Sit a CTA Fee monthly

in arrears, for the use of the RISE Benchmark Portfolio in an amount equal to 0.20% effective January 1, 2018 (0.50% prior to

January 1, 2018) per annum of RISE’s average daily net assets.

of January 1, 2018, the Sponsor has contractually agreed to waive RISE’s Sponsor Fee and/or assume RISE’s remaining

expenses so that RISE’s expenses do not exceed an annual rate of 1.00%, excluding brokerage commissions, interest expense,

and extraordinary expenses, of the value of RISE’s average daily net assets (the “RISE Expense Cap”).

The assumption

of expenses and waiver of RISE’s Sponsor fee are contractual on the part of the Sponsor, through September 30, 2020.

that date, the Sponsor no longer assumed expenses or waived RISE’s Sponsor Fee, RISE could be adversely impacted, including

in its ability to achieve its investment objective.

to January 1, 2018, Sit had agreed to waive the CTA fee and the Sponsor agreed to correspondingly assume the remaining expenses

of RISE so that RISE expenses did not exceed an annual fee of 1.50%, excluding brokerage commissions, interest expense, and extraordinary

expenses, of the value of RISE’s average daily net assets.

waiver of RISE’s Sponsor Fee, pursuant to the contractual RISE Expense Cap, amounted to $24,657 for the year ended June

The waiver of RISE’s CTA fee amounted to $49,453 for the year ended June 30, 2018.

RISE currently accrues its

daily expenses up to the RISE Expense Cap.

At the end of each month, the accrued amount is remitted to the Sponsor as the Sponsor

is responsible for the payment of the routine operational, administrative and other ordinary expenses of RISE.

RISE’s total

expenses amounted to $693,783 and $606,334, for the years ended June 30, 2019 and 2018, respectively, of which $184,268 and $87,625,

respectively, was absorbed by the Sponsor pursuant to the RISE Expense Cap.

pays the Sponsor Fee monthly in arrears, in an amount equal to the greater of 0.15% per annum of the value of RISE’s

average daily net assets or $75,000.

The Sponsor Fee is paid in consideration of the Sponsor’s management services to

RISE also pays Sit a CTA Fee monthly in arrears, for the use of the RISE Benchmark Portfolio in an amount equal to

0.20% per annum of RISE’s average daily net assets.

The Sponsor has contractually agreed to

waive RISE’s Sponsor Fee and/or assume RISE’s remaining expenses so that RISE’s expenses do not exceed an annual

rate of 1.00%, excluding brokerage commissions, interest expense, and extraordinary expenses, of the value of RISE’s average

daily net assets (the “RISE Expense Cap”).

The assumption of expenses and waiver of RISE’s Sponsor fee are contractual

on the part of the Sponsor, through September 30, 2021.

If after that date, the Sponsor no longer assumed expenses or waived RISE’s

Sponsor Fee, RISE could be adversely impacted, including in its ability to achieve its investment objective.

currently accrues its daily expenses up to the RISE Expense Cap.

At the end of each month, the accrued amount is remitted to the

Sponsor as the Sponsor is responsible for the payment of the routine operational, administrative and other ordinary expenses of

RISE’s total expenses amounted to $456,460 and $693,783, for the years ended June 30, 2020 and 2019, respectively,

of which $389,041 and $184,268, respectively, was absorbed by the Sponsor pursuant to the RISE Expense Cap.

pays the Sponsor Fee, monthly in arrears, in an amount equal to the greater of 0.15% per year of BDRY’s average daily net

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of BDRY’s CTA Fee are contractual on the part of the Sponsor and Breakwave, respectively, through September 30, 2021.

after that date, the Sponsor and/or Breakwave no longer assumed expenses or waived the CTA Fee, respectively, BDRY could be adversely

that date, the Sponsor and/or Breakwave no longer assumed expenses or waived the CTA Fee, respectively, BDRY could be adversely

impacted, including in its ability to achieve its investment objective.

assumption of expenses by the Sponsor for BDRY, pursuant to the BDRY Expense Cap, amounted to $284,850 and $477,429 for the year

ended June 30, 2019 and for the period from March 22, 2018 to June 30, 2018, respectively, as disclosed in the Combined Statements

of Operations.

The waiver of Breakwave’s CTA fees, pursuant to the undertaking, amounted to $45,460 and $14,567 for the

year ended June 30, 2019 and for the period from March 22, 2018 to June 30, 2018, respectively, as disclosed in the Combined Statements

of Operations.

ended June 30, 2020 and 2019, respectively, as disclosed in the Combined Statements of Operations.

The waiver of Breakwave’s

CTA fees, pursuant to the undertaking, amounted to $60,769 and $45,460 for the year ended June 30, 2020 and 2019, respectively,

as disclosed in the Combined Statements of Operations.

BDRY currently accrues its daily expenses up to the BDRY Expense Cap.

At the end of each month, the accrued amount

is remitted to the Sponsor as the Sponsor is responsible for the payment of the routine operational, administrative and other

ordinary expenses of the Fund.

BDRY’s total expenses amounted to $667,238 and $231,538 for the year ended June 30, 2019

and for period from March 22, 2018 to June 30, 2018.

the end of each month, the accrued amount is remitted to the Sponsor as the Sponsor is responsible for the payment of the routine

operational, administrative and other ordinary expenses of the Fund.

BDRY’s total expenses amounted to $847,729 and $667,238

for the year ended June 30, 2020 and 2019, respectively.

Administrator,

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its administrative, accounting and transfer agent services and 0.01% of AUM, with an annual minimum of $4,800 for custody services.

March 22, 2018, BDRY has agreed to pay U.S.

Bank 0.05% of AUM, with a $45,000 minimum annual fee payable for its administrative,

accounting and transfer agent services and 0.01% of AUM, with an annual minimum of $4,800 for custody services.

has agreed to pay U.S.

Bank 0.05% of AUM, with a $45,000 minimum annual fee payable for its administrative, accounting and transfer

agent services and 0.01% of AUM, with an annual minimum of $4,800 for custody services.

and BDRY each pay the Distributor an annual fee for statutory and wholesaling distribution services and related administrative

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incurred $15,539 and $17,496 in distribution and related administrative services for the year ended June 30, 2020 and 2019, respectively.

BDRY incurred $16,497 and $4,520 in distribution and related administrative services for the year ended June 30, 2019 and for

the period from March 22, 2018 to June 30, 2018, respectively, as disclosed in the Combined Statements of Operations.

BDRY incurred $15,821 and $16,497 in distribution and related administrative services for the year ended June 30, 2020 and 2019,

respectively, as disclosed in the Combined Statements of Operations.

also pays the Sponsor an annual fee for wholesale support services equal to 0.1% of RISE’s average daily net assets, payable

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BDRY incurred $35,622

$28,762 and $9,680 in wholesale support fees for the year ended June 30, 2019 and for the period from March 22, 2018 to June 30,

2018, respectively, as disclosed in the Combined Statements of Operations.

and $28,762 in wholesale support fees for the year ended June 30, 2020 and 2019, respectively, as disclosed in the Combined Statements

of Operations.

Commission Merchant Fees

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Brokerage commissions on futures contracts are recognized on a half-turn basis.

Sponsor does not expect brokerage commissions and fees, on an annual basis, to exceed 0.08% for RISE, and 0.76% for BDRY, of the

NAV of the applicable Fund for execution and clearing services on behalf of the applicable Fund, although the actual amount of

brokerage commissions and fees in any year or any part of any year may be greater.

The effects of trading spreads, financing costs

associated with financial instruments, and costs relating to the purchase of Treasury Instruments or similar high credit quality

short-term fixed-income or similar securities are not included in the foregoing analysis.

RISE incurred $52,348 and $42,798 in

brokerage commissions and fees for the year ended June 30, 2019 and 2018, respectively, as disclosed in the Combined Statements

of Operations.

BDRY incurred $34,610 and $16,135 in brokerage commissions and fees for the year ended June 30, 2019 and for the

period from March 22, 2018 to June 30, 2018, respectively, as disclosed in the Combined Statements of Operations.

and BDRY are each responsible for certain other expenses, including professional services (e.g., outside auditor’s

fees and legal fees and expenses), shareholder Form K-1’s, tax return preparation, regulatory compliance, and other

services provided by affiliated and non-affiliated service providers.

The fees for Principal Financial Officer and Chief

Compliance Officer services provided to the Funds by the Sponsor amount to $25,000 per annum.

Certain additional fees paid to

the Sponsor by the Funds for tax return preparation and regulatory reporting fees amount to $50,000 ($100,000 prior to April

1, 2019) and $25,000, respectively, per annum.

Sponsor does not expect brokerage commissions and fees, on an annual basis, to exceed 0.08% for RISE, and 0.40% (excluding the

impact on the Fund of creation and/or redemption activity) for BDRY, of the NAV of the applicable Fund for execution and clearing

services on behalf of the applicable Fund, although the actual amount of brokerage commissions and fees in any year or any part

of any year may be greater.

The effects of trading spreads, financing costs associated with financial instruments, and costs relating

to the purchase of Treasury Instruments or similar high credit quality short-term fixed-income or similar securities are not included

in the foregoing analysis.

RISE incurred $4,961 and $52,348 in brokerage commissions and fees for the year ended June 30, 2020

and 2019, respectively, as disclosed in the Combined Statements of Operations.

BDRY incurred $208,650 and $34,610 in brokerage

commissions and fees for the year ended June 30, 2020 and 2019, respectively, as disclosed in the Combined Statements of Operations.

and BDRY are each responsible for certain other expenses, including professional services (e.g., outside auditor’s fees

and legal fees and expenses), shareholder Form K-1’s, tax return preparation, regulatory compliance, and other services

provided by affiliated and non-affiliated service providers.

The fees for Principal Financial Officer and Chief Compliance Officer

services provided to the Funds by the Sponsor amount to $25,000 per annum.

Certain additional fees paid to the Sponsor by the

Funds for tax return preparation and regulatory reporting fees amount to $30,000 and $50,000,

respectively, per annum.

Extraordinary

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the current market value of its total assets;

● Subtracting

any liabilities;

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Arca or 4.00 p.m New York time, in the case of RISE, and as of the close of the NYSE Arca (typically 4:00 p.m.

E.T.), in the

case of BDRY, in accordance with the current applicable Administrative Agency Agreement among U.S.

Bancorp Fund Services, the

Sponsor and RISE or BDRY, respectively.

E.T.), in the case

of BDRY, in accordance with the current applicable Administrative Agency Agreement among U.S.

Bancorp Fund Services, the Sponsor

and RISE or BDRY, respectively.

For purposes of calculating the NAV of RISE, “other information”

used in determining fair value includes information consisting of market data in the relevant market supplied by one or more third

customarily used

in determining fair value includes information consisting of market data in the relevant market supplied by one or more third

parties including, without limitation, relevant rates, prices, yields, yield curves, volatilities, spreads, correlations or other

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in respect of those liabilities.

any business day, an Authorized Participant may place an order with the Transfer Agent, and accepted by the Distributor, to

create one or more baskets.

any business day, an Authorized Participant may place an order with the Transfer Agent, and accepted by the Distributor, to create

one or more baskets.

For purposes of processing purchase and redemption orders, a “business day”

day other than a day when any of the NYSE Arca, the New York Stock Exchange or the CME, in the case of RISE, or the Baltic

Exchange, in the case of BDRY, is closed for regular trading.

means any day other

than a day when any of the NYSE Arca, the New York Stock Exchange or the CME, in the case of RISE, or the Baltic Exchange, in

the case of BDRY, is closed for regular trading.

Purchase orders must be placed by 12:00 p.m.

of the NYSE Arca core trading session, whichever is earlier.

The day on which a valid purchase order is received in

accordance with the terms of the applicable “Authorized Participant Agreement”

is referred to as the purchase

or the close of the NYSE Arca

core trading session, whichever is earlier.

The day on which a valid purchase order is received in accordance with the terms of

the applicable “Authorized Participant Agreement”

is referred to as the purchase order date.

Purchase orders are irrevocable.

Prior to the delivery of baskets for a purchase order, the

Authorized Participant will be charged a non-refundable transaction fee due for the purchase order.

Prior to the delivery of baskets for a purchase order, the Authorized Participant will be charged a non-refundable transaction

fee due for the purchase order.

manner by which creations are made is dictated by the terms of the applicable Authorized Participant Agreement.

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of Required Deposits (RISE only)

Authorized Participant who places a purchase order is responsible for transferring to the Fund’s account with

the Custodian the required amount of U.S.

Treasuries and cash by the end of the second business day following the purchase

Upon receipt of the deposit amount, the Administrator directs DTC to credit the number of shares represented by

the baskets ordered to the Authorized Participant’s DTC account on the second business day following the purchase order

The expense and risk of delivery and ownership of U.S.

Authorized Participant who places a purchase order is responsible for transferring to the Fund’s account with the Custodian

the required amount of U.S.

Treasuries and cash by the end of the second business day following the purchase order date.

receipt of the deposit amount, the Administrator directs DTC to credit the number of shares represented by the baskets ordered

to the Authorized Participant’s DTC account on the second business day following the purchase order date.

The expense and

risk of delivery and ownership of U.S.

Treasuries until such U.S.

Treasuries have been received by

the Custodian on behalf of the Fund is borne solely by the Authorized Participant.

Treasuries have been received by the Custodian on behalf of

the Fund is borne solely by the Authorized Participant.

orders to purchase baskets must be placed by 12:00 p.m., E.T., but the total payment required to create a basket during the continuous

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orders must be placed by 12:00 p.m.

or the close of the core trading

session on the NYSE Arca, whichever is earlier.

A redemption order so received will be effective on the date it is received in

satisfactory form by the Distributor.

The redemption procedures allow Authorized Participants to redeem baskets and do not entitle

an individual shareholder to redeem any shares in an amount less than a Redemption Basket, or to redeem baskets other than through

an Authorized Participant.

or the close of the core trading session on the NYSE Arca, whichever is earlier.

order so received will be effective on the date it is received in satisfactory form by the Distributor.

The redemption procedures

allow Authorized Participants to redeem baskets and do not entitle an individual shareholder to redeem any shares in an amount

less than a Redemption Basket, or to redeem baskets other than through an Authorized Participant.

Redemption orders are irrevocable.

manner by which redemptions are made is dictated by the terms of the Authorized Participant Agreement.

By placing an order

for Redemption Baskets of RISE, an Authorized Participant agrees to (1) deliver the Redemption Basket to be redeemed through

DTC’s book-entry system to the Fund’s account with the Custodian not later than 3:00 p.m.

on the second business day following the effective date of the redemption order, and (2) if required by the Sponsor in its sole

discretion, enter into or arrange for a block trade, an exchange for related position, or any other transaction (through

itself or a designated acceptable broker) with the Fund for the sale of a number and type of futures contracts at the closing

settlement price for such contracts on the redemption order date.

If an Authorized Participant fails to consummate (1) and

(2) above, the order shall be cancelled.

The number and type of contracts specified shall be determined by the Sponsor, in

its sole discretion, to meet the Fund’s investment objective and shall be sold as a result of the Authorized

Participant’s redemption of shares.

By placing an order for Redemption Baskets of BDRY, an Authorized Participant

agrees to deliver the Redemption Baskets to be redeemed through DTC’s book-entry system to the Fund not later than 12:00

By placing an order for

Redemption Baskets of RISE, an Authorized Participant agrees to (1) deliver the Redemption Basket to be redeemed through DTC’s

book-entry system to the Fund’s account with the Custodian not later than 3:00 p.m.

on the second business day following

the effective date of the redemption order, and (2) if required by the Sponsor in its sole discretion, enter into or arrange for

a block trade, an exchange for related position, or any other transaction (through itself or a designated acceptable broker) with

the Fund for the sale of a number and type of futures contracts at the closing settlement price for such contracts on the redemption

If an Authorized Participant fails to consummate (1) and (2) above, the order shall be cancelled.

The number and type

of contracts specified shall be determined by the Sponsor, in its sole discretion, to meet the Fund’s investment objective

and shall be sold as a result of the Authorized Participant’s redemption of shares.

By placing an order for Redemption Baskets

of BDRY, an Authorized Participant agrees to deliver the Redemption Baskets to be redeemed through DTC’s book-entry system

to the Fund not later than 12:00 p.m.

E.T., on the next business day immediately following the redemption order date.

Prior to the delivery of redemption

distribution or proceeds, the Authorized Participant will be charged a non-refundable transaction fee due for the redemption

the delivery of redemption distribution or proceeds, the Authorized Participant will be charged a non-refundable transaction fee

due for the redemption order.

Determination

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redemption distribution due from the Fund will be delivered to the Authorized Participant by 3:00 p.m.

second business day following the redemption order date if, by 3:00 p.m.

on such second business day, the

Fund’s DTC account has been credited with the shares represented by the baskets to be redeemed.

If the Fund’s DTC

account has not been credited with all of the shares represented by the baskets to be redeemed by such time, the redemption

distribution will be delivered to the extent of whole baskets received.

Any remainder of the redemption distribution will be

delivered on the next business day to the extent of remaining shares represented by the whole baskets received if the Fund

receives the fee applicable to the extension of the redemption distribution date which the Sponsor may, from time to time,

determine and the remaining baskets to be redeemed are credited to the Fund’s DTC account by 3:00 p.m.

next business day.

Any further outstanding amount of the redemption order will be cancelled.

Pursuant to information from the

Sponsor, the Custodian will also be authorized to deliver the redemption distribution notwithstanding that the baskets to be

redeemed are not credited to the Fund’s DTC account by 3:00 p.m.

on the second business day following the

redemption order date if the Authorized Participant has collateralized its obligation to deliver the baskets through

DTC’s book entry-system on such terms as the Sponsor may from time to time determine.

on the second business

day following the redemption order date if, by 3:00 p.m.

on such second business day, the Fund’s DTC account has been

credited with the shares represented by the baskets to be redeemed.

If the Fund’s DTC account has not been credited with

all of the shares represented by the baskets to be redeemed by such time, the redemption distribution will be delivered to the

extent of whole baskets received.

Any remainder of the redemption distribution will be delivered on the next business day to the

extent of remaining shares represented by the whole baskets received if the Fund receives the fee applicable to the extension

of the redemption distribution date which the Sponsor may, from time to time, determine and the remaining baskets to be redeemed

are credited to the Fund’s DTC account by 3:00 p.m.

on such next business day.

Any further outstanding amount of the

redemption order will be cancelled.

Pursuant to information from the Sponsor, the Custodian will also be authorized to deliver

the redemption distribution notwithstanding that the baskets to be redeemed are not credited to the Fund’s DTC account by

on the second business day following the redemption order date if the Authorized Participant has collateralized

its obligation to deliver the baskets through DTC’s book entry-system on such terms as the Sponsor may from time to time

of Redemption Proceeds (BDRY only)

35 unchanged sentences

The Sponsor may also reject a redemption order if the number of shares being redeemed would reduce the remaining outstanding

shares to 50,000 shares (minimum NYSE Arca listing requirement) or less, unless the Sponsor has reason to believe that the placer

of the redemption order does in fact possess all the outstanding shares and can deliver them.

shares to 50,000 shares (minimum NYSE Arca maintenance listing requirement ) or less,

unless the Sponsor has reason to believe that the placer of the redemption order does in fact possess all the outstanding shares

and can deliver them.

and Redemption Transaction Fee

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suspension of trading.

regulation of commodity interest transactions in the United States is an evolving area of law and is subject to ongoing modification

by governmental and judicial action.

Considerable regulatory attention has been focused on non-traditional investment pools that

are publicly distributed in the United States.

There is a possibility of future regulatory changes within the United States altering,

perhaps to a material extent, the nature of an investment in the Funds, or the ability of the Funds to continue to implement its

investment strategy.

The effect of any future regulatory change on the Funds is impossible to predict but could be substantial

regulation of commodity interest transactions in the United States is an evolving area of law and is subject to ongoing

modification by governmental and judicial action.

Considerable regulatory attention has been focused on non-traditional

investment pools that are publicly distributed in the United States.

There is a possibility of future regulatory changes

within the United States altering, perhaps to a material extent, the nature of an investment in the Funds, or the ability of

the Funds to continue to implement its investment strategy.

In addition, various national governments outside of the United

States have expressed concern regarding the disruptive effects of speculative trading in the commodities markets and the need

to regulate the derivatives markets in general.

The effect of any future regulatory change on the Funds is impossible to

predict but could be substantial and adverse.

CFTC possesses exclusive jurisdiction to regulate the activities of commodity pool operators and commodity trading advisors with

66 unchanged sentences

Dodd-Frank Act was intended to reduce systemic risks that may have contributed to the 2008/2009 financial crisis.

first draft of what became the Dodd-Frank Act, opponents have criticized the broad scope of the legislation and, in

particular, the regulations implemented by federal agencies as a result.

Since 2010, and most notably in 2015 and 2016,

Republicans have proposed comprehensive legislation both in the House and the Senate of the US Congress.

These bills are

intended to pare back some of the provisions of the Dodd-Frank Act of 2010 that critics view as overly broad, unnecessary to

the stability of the U.S.

financial system, and inhibiting the growth of the U.S.

Further, the administration has

promised and issued several executive orders intended to relieve the financial burden created by the Dodd-Frank Act,

although these executive orders only set forth several general principles to be followed by the federal agencies and do not

mandate the wholesale repeal of the Dodd-Frank Act.

The scope of the effect that passage of new financial reform legislation

could have on U.S.

securities, derivatives and commodities markets is not clear at this time because each federal regulatory

agency would have to promulgate new regulations to implement such legislation.

Nevertheless, regulatory reform may have

a significant impact on U.S.

first draft of what became the Dodd-Frank Act, supporters and opponents have debated the scope of the legislation.

administrations of the U.S.

change, the interpretation and implementation will change along with them.

Nevertheless, regulatory reform of any kind may have a significant impact on U.S.

regulated entities.

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bodies outside the U.S.

have also passed or proposed, or may propose in the future, legislation similar to that proposed by the

Dodd-Frank Act or other legislation containing other restrictions that could adversely impact the liquidity of and increase costs

of participating in the commodities markets.

For example, the European Union (“EU”) Markets in Financial Instruments

Directive (Directive 2014/65/EU) and Markets in Financial Instruments Regulation (Regulation (EU) No 600/2014) (together “MiFID

II”), which has applied since January 3, 2018, governs the provision of investment services and activities in relation to,

as well as the organized trading of, financial instruments such as shares, bonds, units in collective investment schemes and derivatives.

In particular, MiFID II requires EU Member States to apply position limits to the size of a net position which a person can hold

at any time in commodity derivatives traded on trading EU trading venues and in “economically equivalent”

over-the-counter

(“OTC”) contracts.

By way of further example, the European Market Infrastructure Regulation (Regulation (EU) No 648/2012)

(“EMIR”) introduced certain requirements in respect of OTC derivatives including:

(i) the mandatory clearing of OTC

derivative contracts declared subject to the clearing obligation;

(ii) risk mitigation techniques in respect of un-cleared OTC

derivative contracts, including the mandatory margining of un-cleared OTC derivative contracts;

and (iii) reporting and recordkeeping

requirements in respect of all derivatives contracts.

In the event that the requirements under EMIR and MiFID II apply, these

are expected to increase the cost of transacting derivatives.

have also passed or proposed, or may propose in the future, legislation similar to that proposed by

the Dodd-Frank Act or other legislation containing other restrictions that could adversely impact the liquidity of and

increase costs of participating in the commodities markets.

For example, the European Union Markets in Financial Instruments

Directive (Directive 2014/65/EU) and Markets in Financial Instruments Regulation (Regulation (EU) No 600/2014) (together

“MiFID II”), which has applied since January 3, 2018, governs the provision of investment services and activities

in relation to, as well as the organized trading of, financial instruments such as shares, bonds, units in collective

investment schemes and derivatives.

In particular, MiFID II requires EU Member States to apply position limits to the size of

a net position which a person can hold at any time in commodity derivatives traded on EU trading venues and in

“economically equivalent”

over-the-counter (“OTC”) contracts.

By way of further example, the European

Market Infrastructure Regulation (Regulation (EU) No 648/2012, as amended) (“EMIR”) introduced certain

requirements in respect of OTC derivatives including:

(i) the mandatory clearing of OTC derivative contracts declared subject

to the clearing obligation;

(ii) risk mitigation techniques in respect of un-cleared OTC derivative contracts, including the

mandatory margining of un-cleared OTC derivative contracts;

and (iii) reporting and recordkeeping requirements in respect of

all derivatives contracts.

In the event that the requirements under EMIR and MiFID II apply, these are expected to increase

the cost of transacting derivatives.

addition, considerable regulatory attention has been focused on non-traditional publicly distributed investment pools such as

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it is subject.

Each Fund makes available, free of

charge, on its website (www.risingrateetf.com.

Fund makes available, free of charge, on its website (www.risingrateetf.com.

for RISE and www.drybulketf.com.

for BDRY), its annual reports on Form 10-K,

its quarterly reports on Form 10-Q, its current reports on Form 8-K and amendments to these reports filed or furnished

pursuant to Section 13(a) or 15(d) of the Exchange Act as soon as reasonably practicable after these forms are filed with,

or furnished to, the SEC.

for BDRY), its annual

reports on Form 10-K, its quarterly reports on Form 10-Q, its current reports on Form 8-K and amendments to these reports filed

or furnished pursuant to Section 13(a) or 15(d) of the Exchange Act as soon as reasonably practicable after these forms are filed

with, or furnished to, the SEC.

These reports are also available from the SEC though its website at:

8 unchanged sentences

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1. Business