What changed in this filing

/stocks — the workspaceLOADING

Item 9A. Controls and Procedures

2020-09-28 compared with 2019-09-30 · 100 added, 73 removed, 354 unchanged (33% of the section changed)

34 unchanged sentences

over financial reporting.

The Sponsor has contractually

agreed to waive its receipt of the management fee from RISE and/or assume the Fund's expenses (excluding brokerage fees, interest

expenses, and extraordinaiy expenses) so that the Fund's total annual expenses do not exceed 1.00% per annum through September

The foregoing is a

summary description of the Expense Limitation Agreement, which is filed with this Annual Report on Form 10-K as Exhibit 10.18

and is incorporated by reference.

Breakwave has agreed to waive its

license and services fee and the Sponsor has agreed to correspondingly assume the remaining expenses of BDRY so that

the Fund's total annual expenses (excluding brokerage commissions, interest expense, and extraordinaiy expenses) do not

exceed 3.50% per annum through September 30, 2020.

The foregoing is a summary

description of the Fee Waiver Agreement and the Expense Limitation Agreement, which are filed with this Annual Report on Form 10-K

as Exhibits 10.16 and 10.17, respectively, and are incorporated by reference.

Other Information.

Sponsor has contractually agreed to waive its receipt of the management fee from RISE and/or assume the Fund's expenses (excluding

brokerage fees, interest expenses, and extraordinary expenses) so that the Fund's total annual expenses do not exceed 1.00% per

annum through September 30, 2021.

foregoing is a summary description of the Expense Limitation Agreement, which is filed with this Annual Report on Form 10-K as

Exhibit 10.18 and is incorporated by reference.

has agreed to waive its license and services fee and the Sponsor has agreed to correspondingly assume the remaining expenses of

BDRY so that the Fund's total annual expenses (excluding brokerage commissions, interest expense, and extraordinary expenses)

do not exceed 3.50% per annum through September 30, 2021.

foregoing is a summary description of the Fee Waiver Agreement and the Expense Limitation Agreement, which are filed with this

Annual Report on Form 10-K as Exhibits 10.16 and 10.17, respectively, and are incorporated by reference.

Directors, Executive Officers and Corporate Governance.

6 unchanged sentences

following are individual Principals, as that term is defined in CFTC Rule 3.1, for the Sponsor:

Masucci, III, John A.

Flanagan, Reshma A.

Masucci, III, John

Flanagan, Matthew J.

Bromberg, Reshma A.

Tanczos and Devin L.

These individuals are principals due to their positions;

is also a principal due to his controlling stake in ETFMG.

These individuals are principals due to their

Masucci is also a principal due to his controlling stake in ETFMG.

Masucci, III .

66 unchanged sentences

an exchange traded fund issuer from January 2007 to December 2010.

Bromberg serves as the General Counsel of the Sponsor.

Bromberg was listed as a principal of the Sponsor in September 2020.

Prior to joining the Sponsor, from 2019 to 2020, Mr.

Bromberg was an investment management partner at the law firm Dorsey & Whitney

where he provided counsel to investment advisers relating to private investment funds, ETFs and mutual funds, as well as to separately

managed account and wrap fee program sponsors.

From 2016 to 2019, Mr.

Bromberg served as General Counsel of WBI Investments, Inc.,

a registered investment adviser and ETF sponsor.

During the same period, Mr.

Bromberg also served as General Counsel to Millington

Securities, Inc., a broker-dealer affiliate of WBI Investments, Inc.

From 2014 to 2015 Mr.

Bromberg was an investment management

partner at the law firm of Reed Smith.

From 2014 to 2015 and 2006 to 2013, Mr.

Bromberg served as Senior Managing Counsel to the

Asset Servicing Division of BNY Mellon.

Bromberg was in private practice, at the law firm of King & Spalding between 2013

and 2014, where he represented financial institutions in transactional and regulatory matters with a focus on investment advisers,

registered public funds, private investment funds, banks, and broker-dealers.

Bromberg received his B.A.

in English Literature

from The State University of New York at Albany and a J.D.

from Brooklyn Law School.

Tanczos serves as the Chief Compliance Officer of the Sponsor and the Trust.

23 unchanged sentences

following are individual Principals, as that term is defined in CFTC Rule 3.1, for Sit:

Jungquist, Paul E.

Jungquist, Paul

Rasmussen, Carla J.

2 unchanged sentences

Doty, and Chris M.

These individuals

are principals due to their positions.

The following individuals will serve as investment professionals and senior management

in regards to RISE:

These individuals are principals due to their

The following individuals will serve as investment professionals and senior management in regards to RISE:

Roger Sit is the Chairman and Chief Executive Officer.

47 unchanged sentences

School of Business, University of Rochester.

Sponsor has adopted a Code of Business Conduct and Ethics (the

“Code of Ethics”) which applies to all of its officers (including senior financial officers) and employees;

Sponsor’s Code of Ethics covers all officers and employees that manage the Trust and the Funds.

A printed copy of the

Code of Ethics is available to any person free of charge, upon request, by contracting the Sponsor at:

Sponsor has adopted a Code of Business Conduct and Ethics (the “Code of Ethics”) which applies to all of its officers

(including senior financial officers) and employees;

the Sponsor’s Code of Ethics covers all officers and employees that

manage the Trust and the Funds.

A printed copy of the Code of Ethics is available to any person free of charge, upon request,

by contracting the Sponsor at:

Managers Group Commodity Trust I

c/o ETF Managers Capital LLC

ETF Managers Capital LLC

Executive Compensation.

3 unchanged sentences

The Sponsor receives a management fee from RISE, monthly in arrears, in an amount equal to

the greater of 0.15% per annum of the value of the Fund’s average daily net assets or $75,000 effective January 1, 2018.

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

daily net assets or, $18,750 for the period from January 1, 2017 through December 31, 2017.

The Sponsor has contractually agreed

to waive the Sponsor Fee and/or assume the Fund’s Other Expenses (which term excludes brokerage fees, interest expense,

the greater of 0.15% per annum of the value of the Fund’s average daily net assets or $75,000.

The Sponsor has contractually

agreed to waive the Sponsor Fee and/or assume the Fund’s Other Expenses (which term excludes brokerage fees, interest expense,

and extraordinary expenses) so that the Fund’s Total Annual Fund Expenses do not exceed 1.00% per annum through September

5 unchanged sentences

expenses, and extraordinary expenses) in order to cap BDRY’s total annual expenses at 3.50% per annum through September 30,

The management fees paid to the Sponsor by BDRY amounted to $124,997 and $ 34,246

for the year ended June 30, 2019 and for the period from March 22, 2018 to June 30, 2018, respectively.

Sponsor also provides Tax, Principal Financial Officer, Chief Compliance Officer, Regulatory Reporting and Wholesale Support services

The management fees paid to the Sponsor by BDRY amounted to $124,997 and $124,997 for the years ended June 30, 2020 and

2019, respectively.

Sponsor also provides Principal Financial Officer, Chief Compliance Officer, Regulatory Reporting and Wholesale Support services

to the Funds.

13 unchanged sentences

Series of the Trust

Name and Address of Beneficial Owner

Amount and nature of

Name and Address of Beneficial

Beneficial Ownership

Percent of Class

Mayo Clinic Foundation

200 First St SW

Rochester, MN 55905-0001

147,900 Shares

Sit Investment Associates

Sit Fixed Income Advisors II LLC

Sit Fixed Income Advisors

3300 IDS Center

2 unchanged sentences

61,200 Shares

Mercy Investment Services, Inc.

2039 North Geyer Road

Saint Louis, MO 63131-3332

Jane Street Capital LLC

250 Vesey Street - 5 th Floor

New York, NY 10281

54,630 Shares

Not Applicable

G-1 Execution Services LLC

175 West Jackson Blvd

Chicago, IL 60604

28,060 Shares

Baslerstrasse 100

Olten, CH-4601

605,221 Shares

Jane Street Capital LLC

250 Vesey Street - 5 th Floor

New York, NY 10281

505,987 Shares

Credit Suisse Schweiz AG

Paradeplatz 8

Zurich, 8001 Switzerland

369,136 Shares

Ownership of Management.

18 unchanged sentences

Exhibits and Financial Statement Schedules.

See Index to Financial Statements

No financial statement schedules are filed herewith

because (i) such schedules are not required or (ii) the information required has been presented in the aforementioned financial

Exhibits required to be filed by Item 601 of

Regulation S-K.

Index to Financial Statements on page 34.

financial statement schedules are filed herewith because (i) such schedules are not required or (ii) the information required

has been presented in the aforementioned financial statements.

required to be filed by Item 601 of Regulation S-K.

below are the exhibits which are filed or furnished as part of this annual report on Form 10-K (according to the number assigned

12 unchanged sentences

333-218453, filed on October 6, 2017.)

Certificate of Trust of the Registrant.

of Trust of the Registrant.

(Incorporated by reference to Pre-Effective Amendment No.

2 unchanged sentences

Description of the Trust’s securities.

(Filed herewith.)

(Incorporated by reference to the Trust’s Annual Report on Form 10-K, filed on September 30, 2019.)

Form of Authorized Participant Agreement.

63 unchanged sentences

Fee Waiver Agreement with respect to BDRY.

(Filed herewith.)

(Incorporated by reference to the Trust’s Annual Report on Form 10-K, filed on September 30, 2019.)

Expense Limitation Agreement with respect to BDRY.

(Filed herewith.)

(Incorporated by reference to the Trust’s Annual Report on Form 10-K, filed on September 30, 2019.)

Expense Limitation Agreement with respect to RISE.

(Filed herewith.)

(Incorporated by reference to the Trust’s Annual Report on Form 10-K, filed on September 30, 2019.)

Consent of Sullivan & Worcester LLP with respect to RISE.

8 unchanged sentences

(Filed herewith.)

Consent of Connolly & Company, P.C.

of Connolly & Company, P.C.

as to the Sponsor.

(Incorporated by reference to the Trust’s Current Report on Form 8-K, filed on April 30, 2019.)

(Incorporated by reference to Amendment No.

1 to the Trust’s Current

Report on Form 8-K, filed on June 4, 2020.)

Certification by the Principal Executive Officer of the Registrant pursuant to Rules 13a-14 and 15d-14 of the Exchange Act.

8 unchanged sentences

(Filed herewith.)

XBRL Instance Document.

XBRL Taxonomy Extension Schema.

XBRL Taxonomy Extension Calculation Linkbase.

XBRL Taxonomy Definition Linkbase.

XBRL Taxonomy Extension Label Linkbase.

XBRL Taxonomy Extension Presentation Linkbase.

Instance Document.

Taxonomy Extension Schema.

Taxonomy Extension Calculation Linkbase.

Taxonomy Definition Linkbase.

Taxonomy Extension Label Linkbase.

Taxonomy Extension Presentation Linkbase.

to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the Registrant has duly caused this report

to be signed on its behalf by the undersigned, thereunto duly authorized.

ETF Managers Group Commodity

Trust I (Registrant)

ETF Managers Capital, LLC

Principal Executive Officer

Principal Financial Officer

Managers Group Commodity Trust I

Managers Capital, LLC

Executive Officer

Financial Officer

September 28, 2020

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 9A. Controls and Procedures