What changed in this filing

/stocks — the workspaceLOADING

Item 1B. Unresolved Staff Comments

2025-09-26 compared with 2024-09-27 · 31 added, 30 removed, 13 unchanged (82% of the section changed)

2 unchanged sentences

Cybersecurity.

The Sponsor recognizes the importance of managing

cybersecurity risks to protect its business operations, clients, and stakeholders.

The Sponsor has implemented a comprehensive Cybersecurity

Policies and Procedures Plan applicable to the Funds, which outlines the Sponsor’s approach to identifying, assessing, and mitigating

cybersecurity threats and vulnerabilities in alignment with industry standards and best practices.

The Sponsor recognizes the importance of managing cybersecurity risks

to protect its business operations, clients, and stakeholders.

The Sponsor has implemented a comprehensive Cybersecurity Policies and

Procedures Plan applicable to the Funds, which outlines the Sponsor’s approach to identifying, assessing, and mitigating cybersecurity

threats and vulnerabilities in alignment with industry standards and best practices.

Risk Management and Strategy

Cybersecurity Risk Assessment and Management :

The Sponsor has established a risk-based cybersecurity framework for the Funds to manage cybersecurity risks.

This framework includes

regular assessments of its information systems, physical and virtual infrastructure, and the data therein, to identify potential cybersecurity

threats and vulnerabilities.

This cybersecurity strategy is integrated into the Funds’ overall risk management processes, with specific

consideration given to the confidentiality, integrity, and availability of our information systems.

The Sponsor has

established a risk-based cybersecurity framework for the Funds to manage cybersecurity risks.

This framework includes regular assessments

of its information systems, physical and virtual infrastructure, and the data therein, to identify potential cybersecurity threats and

vulnerabilities.

This cybersecurity strategy is integrated into the Funds’ overall risk management processes, with specific consideration

given to the confidentiality, integrity, and availability of our information systems.

Third-Party Service Providers :

engages with various third-party service providers for critical operations and services.

The Sponsor conducts cybersecurity risk assessments

of all vendors and business partners with access to our networks or sensitive information.

These assessments ensure that third-party cybersecurity

policies align with our cybersecurity standards.

The Sponsor engages with various

third-party service providers for critical operations and services .

The Sponsor conducts cybersecurity risk assessments of all vendors

and business partners with access to our networks or sensitive information.

These assessments ensure that third-party cybersecurity policies

align with our cybersecurity standards.

Material Impact of Cybersecurity Threats :

To date, there have been no known material cybersecurity incidents that have significantly impacted the Funds’ business strategies,

results of operations, or financial condition.

The Sponsor continues to monitor systems and processes to mitigate potential cybersecurity

risks actively.

To date, there have

been no known material cybersecurity incidents that have significantly impacted the Funds’ business strategies, results of operations,

or financial condition.

The Sponsor continues to monitor systems and processes to mitigate potential cybersecurity risks actively.

Sponsor Oversight :

The Sponsor has a fundamental

role in overseeing the Funds’ cybersecurity risk management.

The Sponsor receives regular updates on cybersecurity matters from

management and third-party service providers, ensuring that cybersecurity risks are managed proactively at the highest level of the organization.

The Sponsor has a fundamental role in overseeing

the Funds’ cybersecurity risk management.

The Sponsor receives regular updates on cybersecurity matters from management and third-party

service providers, ensuring that cybersecurity risks are managed proactively at the highest level of the organization.

Management’s Role :

The Sponsor’s Chief Compliance Officer is responsible for overseeing the

development, implementation, and ongoing management of the Fund’s Cybersecurity Policies and Procedures including the monitoring

of our systems for potential cybersecurity events and the implementation of preventive and mitigative measures.

The Sponsor’s Chief Compliance

Officer is responsible for overseeing the development, implementation, and ongoing management of the Fund’s Cybersecurity Policies

and Procedures including the monitoring of our systems for potential cybersecurity events and the implementation of preventive and mitigative

Not applicable.

Legal Proceedings

Although the Funds may, from time to time, be

involved in litigation arising out of their operations in the normal course of business or otherwise, the Funds are currently not a party

to any pending legal proceedings.

Although the Funds may, from time to time, be involved in litigation

arising out of their operations in the normal course of business or otherwise, the Funds are currently not a party to any pending legal

Mine Safety Disclosures.

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 1B. Unresolved Staff Comments