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Item 9A. Controls and Procedures

2024-09-27 compared with 2023-09-27 · 300 added, 252 removed, 84 unchanged (87% of the section changed)

Controls and Procedures.

Controls and Procedures

Trust and the Funds maintain disclosure controls and procedures that are designed to ensure that material information required to be

disclosed in the Trust’s periodic reports filed or submitted under the Securities Exchange Act of 1934, as amended, is recorded,

processed, summarized and reported within the time period specified in the SEC’s rules and forms.

duly appointed officers of the Sponsor, including its principal executive officer and principal financial officer, have evaluated the

effectiveness of the Trust’s and the Funds’ disclosure controls and procedures and have concluded that the disclosure controls

and procedures of the Trust and the Funds have been effective as of the end of the period covered by this annual report on Form 10-K.

Annual Report on Internal Control Over Financial Reporting

of the Sponsor, on behalf of the Trust and the Funds are responsible for establishing and maintaining adequate internal control over

financial reporting.

The Trust and the Funds’ internal control system is designed to provide reasonable assurance to the Sponsor

regarding the preparation and fair presentation of published financial statements.

All internal control systems, no matter how well designed,

have inherent limitations.

Therefore, even those systems determined to be effective can provide only reasonable assurance with respect

to financial statement preparation and presentation.

of the Sponsor, including Matthew Bromberg, Principal Executive Officer of the Sponsor, and John A.

Flanagan, Principal Financial Officer

of the Sponsor, who perform functions equivalent to those of a principal executive officer and principal financial officer of the Trust

if the Trust had any officers, assessed the effectiveness of the Trust’s and the Funds’ internal control over financial reporting

as of June 30, 2023.

In making this assessment, it used the criteria in the Internal Control - Integrated framework issued by the Committee

of Sponsoring Organizations of the Treadway Commission in 2013.

Based on the assessment, Management believes that, as of June 30, 2023,

the internal control over financial reporting is effective for the Trust and the Funds.

in Internal Control Over Financial Reporting

were no changes in the Trust’s or the Funds’ internal control over financial reporting during the last fiscal quarter that

have materially affected, or are reasonably likely to materially affect, the Trust’s or the Funds’ internal control over

financial reporting.

Disclosure Controls and Procedures

The Trust and each of BDRY and BWET maintain disclosure

controls and procedures that are designed to ensure that material information required to be disclosed in the Trust’s periodic reports

filed or submitted under the Securities Exchange Act of 1934, as amended, is recorded, processed, summarized and reported within the time

period specified in the SEC’s rules and forms.

The duly appointed officers of the Sponsor, including

its principal executive officer and principal financial officer, have evaluated the effectiveness of the Trust’s , BRDY’s

and BWET’s controls and procedures and have concluded that the disclosure controls and procedures of the Trust and each of BRDY

and BWET have been effective as of the end of the period covered by this annual report on Form 10-K.

Management’s Annual Report on Internal

Control Over Financial Reporting

Management of the Sponsor, on behalf of the Trust

and each of BRDY and BWET, are responsible for establishing and maintaining adequate internal control over financial reporting.

control system for each of the Trust, BRDY and BWET is designed to provide reasonable assurance to the Sponsor regarding the preparation

and fair presentation of published financial statements.

All internal control systems, no matter how well designed, have inherent limitations.

Therefore, even those systems determined to be effective can provide only reasonable assurance with respect to financial statement preparation

and presentation.

Management of the Sponsor, including Christian

Magoon, Principal Executive Officer of the Sponsor, and Bradley H.

Bailey, Principal Financial Officer of the Sponsor, who perform functions

equivalent to those of a principal executive officer and principal financial officer of the Trust if the Trust had any officers, assessed

the effectiveness of each of the internal control over financial reporting for each of the Trust, BRDY and BWET as of June 30, 2024.

In making this assessment, it used the criteria in the Internal Control - Integrated framework issued by the Committee of Sponsoring Organizations

of the Treadway Commission in 2013.

Based on the assessment, Management believes that, as of June 30, 2024, the internal control

over financial reporting is effective for the Trust and each of BRDY and BWET.

The Trust confirms that the certifications of

the principal executive officer and principal financial officer filed with this annual report on Form 10-K are applicable to the Trust

and each of BRDY and BWET.

Change in Internal Control Over Financial Reporting

There were no changes in the Trust’s or

the Funds’ internal control over financial reporting during the last fiscal quarter that have materially affected, or are reasonably

likely to materially affect, the Trust’s or each of the Funds internal control over financial reporting.

Other Information.

of the Sponsor’s officers have adopted, modified or terminated trading plans under either a Rule 10b5-1 or non-Rule 10b5-1 trading

arrangement (as such terms are defined in Item 408 of Regulation S-K of the Securities Act of 1933) for the Trust or the Funds for the

three months ended June 30, 2023.

Disclosure Regarding Foreign Jurisdictions that Prevent Inspections.

Directors, Executive Officers and Corporate Governance.

Sponsor and its Management

the Trust nor the Funds have executive officers.

Pursuant to the terms of the Trust Agreements for the Funds, the Fund’s affairs

are managed by the Sponsor.

The business and affairs of the Sponsor are managed by its chief executive officer, Matthew J.

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

Masucci, III, Bernard

Karol, Matthew J.

Bromberg, John A.

Bromberg and Mr.

Flanagan are principals due to their positions.

and Karol are principals due to their ownership stakes in ETFMG.

Flanagan serves as the Principal Financial Officer of the Sponsor and the Trust.

Flanagan was listed as

a principal, as that term is defined in CFTC Rule 3.1, of the Sponsor on January 8, 2015.

Since June 2014, Mr.

Flanagan has served as

an Independent Trustee of Absolute Shares Trust, a multi-series exchange traded fund.

Flanagan has been the President and sole owner

Flanagan CPA, LLC since December 2010.

Flanagan was Chief Financial Officer of MacroMarkets LLC, an exchange traded fund

issuer from January 2007 to December 2010.

Bromberg has been General Counsel of Exchange Traded Managers Group LLC (“ETFMG”), the parent of

the Sponsor, since April 1, 2020, Chief Operating Officer of ETFMG since September 1, 2022, Chief Compliance Officer of the Sponsor since

October 26, 2022, and Interim Chief Executive Officer of the Sponsor since July 17, 2023.

He was listed as a principal, as that term

None of the Sponsor’s officers have adopted ,

modified or terminated trading plans under either a Rule 10b5-1 or non-Rule 10b5-1 trading arrangement (as such terms are defined in Item

408 of Regulation S-K of the Securities Act of 1933) for the Trust or the Funds for the three months ended June 30, 2024.

Disclosure Regarding Foreign Jurisdictions

that Prevent Inspections.

Not applicable.

Directors, Executive Officers and

Corporate Governance.

The Sponsor and its Management

Neither the Trust nor the Funds have executive

Pursuant to the terms of the Trust Agreements for the Funds, the Fund’s affairs are managed by the Sponsor.

and affairs of the Sponsor are managed by its chief executive officer, Christian Magoon.

The following are individual Principals, as that

term is defined in CFTC Rule 3.1, for the Sponsor:

Magoon, Bradley H.

Bailey, David F.

Wilding, Edward H.

Keiley III and

William Belden III.

These individuals are principals due to their positions;

Magoon is also a principal due to his controlling

stake in Amplify.

Amplify also was listed as a principal of the Sponsor, due to its controlling stake, on June 14, 2023.

has been the Chief Executive Officer and President of the Sponsor since January 2015.

Magoon was listed as a principal, as that term

is defined in CFTC Rule 3.1, of the Sponsor on October 3, 2023.

He has also served as Chief Executive Officer and President, and Chair

of the Board of Trustees, of Amplify ETF Trust, including the seventeen series thereof (the “Amplify Funds”).

served as Chief Executive Officer of YieldShares, LLC since April 2013, and of Magoon Capital since January 2010.

In these roles, Mr.

Bromberg has general and active management and control

of the business and affairs of the Sponsor, and he has responsibilities for all legal affairs of ETFMG’s and the Sponsor’s

business, as well as implementation of the Sponsor’s compliance program.

Bromberg has been General Counsel of ETF Managers

Group LLC, an investment adviser affiliate of ETFMG and the Sponsor, since April 1, 2020, and Chief Compliance Officer of ETF Managers

Group LLC since October 26, 2022.

He was listed as a principal of ETF Managers Group LLC from March 10, 2022 to December 14, 2022.

was a Partner at the law firm Dorsey & Whitney LLP from September 2019 through March 2020, where he counseled clients on investment

management and financial services matters.

He was also General Counsel of Millington Securities, Inc.

and WBI Investments, Inc., registered

investment advisers, from February 2016 to September 2019 and a Partner at the law firm Reed Smith LLP from August 2015 through January

Trading Advisor

Sponsor has also entered into a Licensing and Services Agreement with Breakwave.

Under this agreement, Breakwave has agreed to compose

and maintain the BDRY and BWET Benchmark Portfolios and license to the Sponsor the use of the BDRY and BWET Benchmark Portfolios.

is a limited liability company.

The following individual is the President, sole investment professional and Principal, as that term is

defined in CFTC Rule 3.1:

John Kartsonas is the Principal and Managing Partner of Breakwave Advisors LLC., a Commodity Trading Advisory firm

based in New York.

Kartsonas was listed as a principal of the Sponsor on May 17, 2017.

He has been a registered associated person

and an NFA associate member of Breakwave since May 17, 2017.

Magoon has general and active management and control of the business and affairs of the firm.

been Chief Financial Officer of the Sponsor since March 2016, and Chief Financial Officer of Amplify Funds since March 2016.

He was listed

as a principal, as that term is defined in CFTC Rule 3.1, of the Sponsor on September 21, 2023.

Bailey has primary responsibility

for the financial management and reporting of the Sponsor and Amplify Funds and is in charge of its books of account and accounting records,

and its accounting procedures.

serves as the Chief Operating Officer of the Sponsor since February 2023.

Wilding was listed as a principal, as that term is defined

in CFTC Rule 3.1, of the Sponsor on August 8, 2023.

Wilding is overseeing and managing the implementation of all elements of operations

Wilding has served as the Secretary of the Amplify Funds since February 2023 and as General Counsel and Chief Compliance

Officer of Performance Trust Capital Partners LLC (investment adviser and broker-dealer) and PT Asset Management, LLC (investment adviser)

from August 1996 to June 2022.

He was listed as a principal of Performance Trust Capital Partners LLC from October 2020 to March 2022.

has been Chief Compliance Officer of the Sponsor since August 2015.

Keiley was listed as a principal of the Sponsor on July 13, 2023,

and has been a registered associated person and a swap associated person, and an NFA associate member of the Sponsor, since October 25,

Keiley is responsible for overseeing and managing the implementation of all elements of the regulatory compliance requirements

and reporting pursuant to SEC, FINRA and NYSE Arca rules and regulations.

Keiley has served as the Chief Compliance Officer of the

Amplify Funds since January 2015 and as a Compliance Consultant for R.J.

O’Brien Securities LLC (futures broker) from December 2007

to June 2023.

He has been Chief Compliance Officer of OASIS Investment Strategies, LLC from October 2009 to December 2023, and was listed

as a principal of OASIS Investment Strategies, LLC (investment adviser and commodity pool operator) from December 19, 2022 to January

William Belden III .

been President of the Sponsor since November 2018.

Belden was listed as a principal, as that term is defined in CFTC Rule 3.1, of

the Sponsor on September 21, 2023.

Belden manages the day-to-day operations of the firm.

Belden has also served as the Vice President

of the Amplify Funds since October 2020.

Commodity Trading Advisor

The Sponsor has also entered into a Licensing

and Services Agreement with Breakwave.

Under this agreement, Breakwave has agreed to compose and maintain the BDRY and BWET Benchmark

Portfolios and license to the Sponsor the use of the BDRY and BWET Benchmark Portfolios.

Breakwave is a limited liability company.

following individual is the President, sole investment professional and Principal, as that term is defined in CFTC Rule 3.1:

John Kartsonas .

John Kartsonas is

the Principal and Managing Partner of Breakwave Advisors LLC., a Commodity Trading Advisory firm based in New York.

Kartsonas was

listed as a principal of the Sponsor on May 17, 2017.

He has been a registered associated person and an NFA associate member of Breakwave

since May 17, 2017.

From 2017 to the present Mr.

Kartsonas has also served as a Director of

Seanergy Maritime, an international shipping company listed in the Nasdaq Capital Market.

Kartsonas has also served as a Director of Seanergy Maritime, an international shipping

company listed in the Nasdaq Capital Market.

Prior to that, Mr.

Kartsonas was a Senior Portfolio

Manager at Carlyle Commodity Management from October 2012 to January 2017, a commodity-focused investment firm based in New York and

part of the Carlyle Group.

He was responsible for the firm’s Shipping and Freight investments.

During his tenure, he managed one

of the largest freight futures funds globally.

Kartsonas was a Senior Portfolio Manager at Carlyle Commodity Management

from October 2012 to January 2017, a commodity-focused investment firm based in New York and part of the Carlyle Group.

responsible for the firm’s Shipping and Freight investments.

During his tenure, he managed one of the largest freight futures funds

Kartsonas received his MBA from the Simon 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;

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

Managers Group Commodity Trust I

ETF Managers Capital LLC

Code of Ethics

The 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:

Amplify Commodity Trust

c/o Amplify Investments LLC

3333 Warrenville Road

Lisle, IL 60532

Executive Compensation.

Funds have no employees, officers or directors and are managed by the Sponsor.

None of the directors or officers of the Sponsor receive

compensation from the Funds.

Sponsor receives a management fee from BDRY, monthly in arrears, in an amount equal to the greater of 0.15% per annum on the daily NAV

of BDRY or $125,000.

The Sponsor receives a management fee from BWET, monthly in arrears, in an amount equal to the greater of 0.30%

per annum on the daily NAV of BWET or $50,000.

The Sponsor has contractually agreed to assume the Funds’ expenses (excluding brokerage

fees, interest expense, and extraordinary expenses) in order to cap each Funds’ total annual expenses at 3.50% per annum through March 31, 2025.

The management fees paid to the Sponsor by BDRY amounted to $128,597 and $131,335 for the years ended June 30, 2023 and

2022, respectively.

The management fees paid to the Sponsor by BWET amounted to $8,083 for the period from May 3, 2023 (commencement of

operations) to June 30, 2023.

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

The fees for each service provided to BDRY for the year ended June 30, 2023, all of which had been paid, or accrued, at June 30,

2023, were as follows:

The Funds have no employees, officers or directors

and are managed by the Sponsor.

None of the directors or officers of the Sponsor receive compensation from the Funds.

The Sponsor receives a management fee from BDRY,

monthly in arrears, in an amount equal to the greater of 0.15% per annum on the daily NAV of BDRY or $125,000.

The Sponsor receives a

management fee from BWET, monthly in arrears, in an amount equal to the greater of 0.30% per annum on the daily NAV of BWET or $50,000.

The Sponsor has contractually agreed to assume the Funds’ expenses (excluding brokerage fees, interest expense, and extraordinary

expenses) in order to cap each Funds’ total annual expenses at 3.50% per annum through March 31, 2025.

The management fees

paid to the Sponsor by BDRY amounted to $125,001 and $128, for the years ended June 30, 2024 and 2023, respectively.

The management fees

paid to the Sponsor by BWET amounted to $50,001 and $8,083 for year ended June 30, 2024, and the period from May 3, 2023 (commencement

of operations) to June 30, 2023.

The Sponsor also provides Principal Financial

Officer, Chief Compliance Officer, Regulatory Reporting and Wholesale Support services to the Funds.

The fees for each service provided

to BDRY for the year ended June 30, 2024, all of which had been paid, or accrued, at June 30, 2024, were as follows:

Principal Financial Officer

2 unchanged sentences

Wholesale Support

fees for the above services provided to BWET for the period from May 3, 2023 (commencement of operations) to June 30, 2023, all of which

had been paid, or accrued, at June 30, 2023, were as follows:

The fees for the above services provided to BWET

for the year ended June 30, 2024, all of which had been paid, or accrued, at June 30, 2024, were as follows:

Principal Financial Officer

2 unchanged sentences

Wholesale Support

addition to the above, the Distributor provides Distribution services to the Funds.

The fees for Distribution services paid to the Distributor

were $15,707 for BDRY for the year ended June 30, 2023 and $2,539 for BWET for the period from May 3, 2023 (commencement of operations)

to June 30, 2023.

Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters.

Ownership of Certain Beneficial Owners.

The following table sets forth shares as of June 30, 2023, information with respect to each person

known to own beneficially more than 5% of the outstanding shares of any series in the Trust:

In addition to the above, the Distributor provides

Distribution services to the Funds.

The fees for Distribution services paid to the Distributor were $15,193 for BDRY for the year ended

June 30, 2024 and $11,339 for BWET for the year ended June 30, 2024.

Security Ownership of Certain Beneficial

Owners and Management and Related Stockholder Matters.

Security Ownership of Certain Beneficial Owners.

The following table sets forth shares as of June 30, 2024, information with respect to each person known to own beneficially more

than 5% of the outstanding shares of any series in the Trust:

Series of the Trust

Street Group LLC

250 Vesey Street

New York, NY 10281

of Beneficial

Citibank 3801 Citibank Center

B/3RD Floor/Zone 12

Tampa, Florida 33610

585,183 shares

Ownership of Management.

of the directors or executive officers of the Sponsor owns any shares of the Funds.

Sponsor intends to withdraw as sponsor of the Trust and the Funds and appoint Amplify Investments LLC, or an affiliate (“Amplify”), to

serve as sponsor of the Trust, commencing upon the resignation of the Sponsor (the “Sponsor Replacement”).

Amplify will thereafter serve

as sole sponsor of the Trust and intends to carry on the business of the Trust and the Funds.

It is expected that the Sponsor Replacement

will occur during the fourth quarter of 2023, subject to certain conditions, including, but not limited to, the registration of Amplify

as a CPO with the CFTC.

It is not expected that the Sponsor Replacement will affect the Trust, its shareholders or an investment in the

Funds’ shares in any way.

Certain Relationships and Related Transactions, and Director Independence.

Relationships and Related Transactions

Items 11 and 12.

the Trust nor the Funds entered into any transaction in excess of $120,000 in which any related person had a direct or indirect material

interest and the Trust and the Funds do not propose to enter into any such transaction.

an unincorporated entity, the registrant does not have a Board of Directors.

Charles Schwab & Co Inc.

211 Main Street San Francisco,

California 94105-1905

501,856 shares

Interactive Brokers LLC

One Pickwick Plaza,

Greenwich, CT 06830

National Financial Services LLC

499 Washington Boulevard

Jersey City, New Jersey

368,184 shares

Morgan Stanley Smith Barney LLC

1300 Thames Street, 6th Floor

Baltimore, Maryland 21231

225,538 shares

National Financial Services LLC

499 Washington Boulevard

Jersey City, New Jersey

28,317 shares

Interactive Brokers LLC

One Pickwick Plaza,

Greenwich, CT 06830

28,217 shares

Charles Schwab & Co Inc.

211 Main Street San Francisco,

California 94105-1905

13,957 shares

Citibank 3801 Citibank Center

B/3RD Floor/Zone 12

Tampa, Florida 33610

11,955 shares

Morgan Stanley & Co International PLC

35 Cabot Square

Canary Wharf, London

11,900 shares

JP Morgan Chase Bank, National Association

14201 Dallas Parkway,

Chase International Plaza

Dallas, TX 75254-2916

Davidson & Co.

Monroe Street, #5250

Chicago, Illinois 60606

Security Ownership of Management.

None of the directors or executive officers of

the Sponsor owns any shares of the Funds.

Change in Control.

Effective after the close of trading on February

14, 2024, ETF Managers Capital LLC, as the prior sponsor and commodity pool operator (the “Former Sponsor”) of the Trust,

entered into an agreement (the “Transfer Agreement”) to resign as Sponsor to the Trust and transfer its role as the Trust’s

sponsor to Amplify Investments LLC (“the Sponsor”) Under the terms of the Transfer Agreement, the Former Sponsor no longer

has any involvement in the operations, management or marketing of the Fund.

In connection with this change of Sponsor, Trust changed

its name from the ETF Managers Group Commodity Trust I to the Amplify Commodity Trust.

This change in control did not affect the Trust,

its shareholders or an investment in the Funds’ shares in any way.

Certain Relationships and Related

Transactions, and Director Independence.

Certain Relationships and Related Transactions

See Items 11 and 12.

Neither the Trust nor the Funds entered into any

transaction in excess of $120,000 in which any related person had a direct or indirect material interest and the Trust and the Funds do

not propose to enter into any such transaction.

Director Independence

As an unincorporated entity, the registrant does

not have a Board of Directors.

Principal Accountant Fees and Services.

fees for services accrued and/or billed to BDRY and to BWET by its independent auditors for the year ended June 30, 2023 and 2022 were

The fees for services accrued and/or billed to

BDRY and to BWET by its independent auditors for the year ended June 30, 2024 and 2023 were as follows:

Audit-Related Fees

All Other Fees

of Independent Registered Public Accounting Firm Services and Fees

Sponsor approved all of the services provided by WithumSmith+Brown, PC to the Funds described above.

The Sponsor pre-approves all audit

and allowed non-audit services of the Funds’ independent registered public accounting firm, including all engagement fees and terms.

Approval of Independent Registered Public Accounting

Firm Services and Fees

The Sponsor approved all of the services provided

by WithumSmith+Brown, PC to the Funds described above.

The Sponsor pre-approves all audit and allowed non-audit services of the Funds’

independent registered public accounting firm, including all engagement fees and terms.

Exhibits and Financial Statement Schedules.

See Index to Financial

Statements on page 33.

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 statements.

Exhibits 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 to them

in Item 601 of Regulation S-K):

Amended and Restated Declaration of Trust and Trust Agreement of the Registrant.

(Incorporated by reference to Pre-Effective Amendment No.

See Index to Financial Statements on page 33.

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 statements.

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

Exhibit Index

Listed below are the exhibits which are filed

or furnished as part of this annual report on Form 10-K (according to the number assigned to them in Item 601 of Regulation S-K):

Second Amended and Restated Declaration of Trust and Trust Agreement (Incorporated by reference to Post-Effective Amendment No.

3 to Registration Statement No.

333-199190, filed on January 12, 2015.)

333-263425, filed on February 15, 2024)

Instrument Establishing the Fund.

12 unchanged sentences

1 to Registration Statement No.

333-218453, filed on October 6, 2017.

333-2199190, filed on November 26, 2014).

Certificate of Amendment to Certificate of Trust (Incorporated by reference to Post-Effective Amendment No.

3 to Registration Statement No.

333-263425, filed on February 15, 2024)

Description of the Trust’s securities.

4 unchanged sentences

333-199190, filed on January 28, 2015.)

Marketing Agent Agreement.

(Incorporated by reference to the Trust’s Current Report on Form 8-K, filed on April 12, 2017.)

Amendment No.

1 to Marketing Agent Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

3 to Registration Statement No.

333-218453, filed on March 6, 2018.)

Amendment No.

2 to Marketing Agent Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

3 to Registration Statement No.

333-218453, filed on March 6, 2018.)

Amendment No.

3 to Marketing Agent Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

1 to Registration Statement No.

333-266945, filed on March 30, 2023.)

Market Agent Agreement.

(Incorporated by reference to Post-Effective Amendment No.

3 to Registration Statements No.

333-263425, filed on February 15, 2024)

Licensing and Services Agreement with respect to BDRY.

2 unchanged sentences

333-218453, filed on March 7, 2018.)

Licensing and Services Agreement with respect to BWET.

(Incorporated by reference to Pre-Effective Amendment No.

1 to Registration Statement No.

333-266945, filed on March 30, 2023.)

Custody Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

Assignment and Assumption of Licensing Services Agreement with respect to BDRY.

(Incorporated by reference to Post-Effective Amendment No.

2 to Registration Statement No.

333-199190, filed on January 28, 2015.)

Amendment No.

1 to Custody Agreement.

333-263425, filed on February 2, 2024.)

Licensing and Services Agreement with respect to BWET.

(Incorporated by reference to Pre-Effective Amendment No.

1 unchanged sentence

333-266945, filed on March 30, 2023.)

Amendment No.

3 to Custody Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

Assignment and Assumption of Licensing Services Agreement with respect to BWET.

(Incorporated by reference to Post-Effective Amendment No.

2 to Registration Statement No.

333-266945, filed on March 30, 2023.)

333-266945, filed on February 2, 2024.)

Custody Agreement.

(Incorporated by reference to Post-Effective Amendment No.

3 to Registration Statements No.

333-263425, filed on February 15, 2024)

Fund Administration Servicing Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

3 to Registration Statement No.

333-199190, filed on January 28, 2015.)

Amendment No.

1 to Fund Administration Servicing Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

3 to Registration Statement No.

333-218453, filed on March 6, 2018.)

Amendment No.

3 to Fund Administration Servicing Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

1 to Registration Statement No.

333-266945, filed on March 30, 2023.)

( Incorporated by reference to Post-Effective Amendment No.

3 to Registration Statements No.

333-263425, filed on February 15, 2024)

Fund Accounting Servicing Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

3 to Registration Statement No.

333-199190, filed on January 28, 2015.)

Amendment No.

1 to Fund Accounting Servicing Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

3 to Registration Statement No.

333-218453, filed on March 6, 2018.)

Amendment No.

3 to Fund Accounting Servicing Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

1 to Registration Statement No.

333-266945, filed on March 30, 2023.)

(Incorporated by reference to Post-Effective Amendment No.

3 to Registration Statements No.

333-263425, filed on February 15, 2024)

Transfer Agent Servicing Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

3 to Registration Statement No.

333-199190, filed on January 28, 2015.)

Amendment No.

1 to Transfer Agent Servicing Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

3 to Registration Statement No.

333-218453, filed on March 6, 2018.)

Amendment No.

3 to Transfer Agent Servicing Agreement.

(Incorporated by reference to Pre-Effective Amendment No.

1 to Registration Statement No.

333-266945, filed on March 30, 2023.)

(Incorporated by reference to Post-Effective Amendment No.

3 to Registration Statements No.

333-263425, filed on February 15, 2024)

Fee Waiver Agreement with respect to BDRY.

(Incorporated by reference to the Trust’s Current Report on Form 8-K, filed on September 6, 2022.)

(Incorporated by reference to Post-Effective Amendment No.

2 to Registration Statement No.

333-263425, filed on February 2, 2024.)

Expense Limitation Agreement with respect to BDRY.

(Incorporated by reference to the Trust’s Current Report on Form 8-K, filed on September 6, 2022.)

(Filed herewith.)

Fee Waiver Agreement with respect to BWET.

(Incorporated by reference to Pre-Effective Amendment No.

(Incorporated by reference to Post-Effective Amendment No.

2 to Registration Statement No.

333-266945, filed on March 30, 2023.)

333-266945, filed on February 2, 2024.)

Expense Limitation Agreement with respect to BWET.

(Incorporated by reference to Pre-Effective Amendment No.

(Filed herewith) .

Sponsor Transfer Agreement (Incorporated by reference to Post-Effective Amendment No.

2 to Registration Statements No.

333-263425, filed on February 2, 2024)

Amendment No.

1 to the Sponsor Transfer Agreement (Incorporated by reference to Post-Effective Amendment No.

3 to Registration Statements No.

333-263425, filed on February 15, 2024)

Consent of Potter Anderson & Corroon LLP.

(Incorporated by reference to Post-Effective Amendment No.

3 to Registration Statement No.

333-266945, filed on March 30, 2023.)

Consent of Sullivan & Worcester LLP.

(Incorporated by reference to Form S-1 Registration Statement No.

333-254634, filed on March 23, 2021.)

333-263425, filed on February 15, 2024)

Consent of Eversheds Sutherland (US) LLP.

(Incorporated by reference to Pre-Effective Amendment No.

(Incorporated by reference to Post-Effective Amendment No.

3 to Registration Statement No.

333-266945, filed on March 30, 2023.)

333-263425, filed on February 15, 2024)

Consent of WithumSmith & Brown, P.C.

15 unchanged sentences

Inline XBRL Taxonomy Extension Schema Document.

Inline XBRL Taxonomy Extension Calculation Linkbase

Inline XBRL Taxonomy Extension Definition Linkbase

Inline XBRL Taxonomy Extension Calculation Linkbase Document.

Inline XBRL Taxonomy Extension Definition Linkbase Document.

Inline XBRL Taxonomy Extension Label Linkbase Document.

Inline XBRL Taxonomy Extension Presentation Linkbase

Cover Page Interactive Data File (formatted as Inline

XBRL and contained in Exhibit 101).

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

ETF Managers Capital, LLC

Inline XBRL Taxonomy Extension Presentation Linkbase Document.

Cover Page Interactive Data File (formatted as Inline XBRL and contained in Exhibit 101).

Pursuant 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.

Amplify Commodity Trust

Amplify Investments LLC

/s/ Christian Magoon

Christian Magoon

Principal Executive Officer

/s/ Bradley H.

Principal Financial Officer

1 unchanged sentence

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