What changed in this filing

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Item 9A. Controls and Procedures

2026-02-27 compared with 2025-02-28 · 27 added, 41 removed, 398 unchanged (15% of the section changed)

27 unchanged sentences

Chief Operating Officer and Portfolio Manager

Management Director

Management Director, Chief Marketing Officer

77 unchanged sentences

He also served as a Management Director of USCF from May 2005 to April 2023.

Ngim served as the portfolio manager for USCI and CPER since January 2013.

Ngim serves as the portfolio manager for USCI and CPER since January 2013.

Ngim also served as USCF’s Treasurer from June 2005 to February 2012.

In addition, he has been on the Board of Managers and has served as the Assistant Secretary and Assistant Treasurer of USCF Advisers since its inception in June 2013 and Chief Operating Officer of USCF Advisers since March 2021.

In addition, he has been on the Board of Managers and serves as the Assistant Secretary and Assistant Treasurer of USCF Advisers since its inception in June 2013 and Chief Operating Officer of USCF Advisers since March 2021.

Prior to and concurrent with his services to USCF and USCF Advisers, from January 1999 to January 2013, Mr.

2 unchanged sentences

Ngim also serves as the portfolio manager for the following series of the USCF ETF Trust:

(1) USCF SummerHaven Dynamic Commodity Strategy No K-1 Fund, from May 2018 to present, (2) the USCF Sustainable Battery Metals Strategy Fund from January 2023 to present, (3) the USCF Energy Commodity Strategy Absolute Return Fund from May 2023 to present, and (4) the USCF Sustainable Commodity Strategy Fund from August 9, 2023 to present.

(1) USCF SummerHaven Dynamic Commodity Strategy No K-1 Fund, from May 2018 to present, (2) the USCF Sustainable Battery Metals Strategy Fund from January 2023 to present, (3) the USCF Energy Commodity Strategy Absolute Return Fund from May 2023 to present, (4) the USCF Sustainable Commodity Strategy Fund from August 9, 2023 to present, and (5) the USCF Oil Plus Bitcoin Strategy Fund from December 9, 2025 to present.

Ngim served as a Management Trustee of the USCF ETF Trust from August 2014 to August 2023.

3 unchanged sentences

from the University of California at Berkeley.

Nguyen , 65, Management Director and principal since July 2015.

Nguyen served on the Board of USCF Investments from December 2014 to December 2016.

Nguyen co-founded USCF in 2005 and served as a Management Director until March 2012.

Nguyen was an Investment Manager with Ribera Investment Management, an investment adviser registered under the Investment Advisers Act of 1940, from January 2013 to March 2015.

Prior to and concurrent with his services to USCF, from January 2000 to January 2013, Mr.

Nguyen served as a Managing Principal for Ameristock Corporation, a California-based investment adviser registered under the Investment Advisers Act of 1940, which he co-founded in March 1995.

Nguyen was a principal of USCF listed with the CFTC and NFA from November 2005 through March 2012 and an associated person of USCF listed with the CFTC and NFA from November 2007 through March 2012.

Nguyen has been a principal of USCF listed with the CFTC and NFA since July 2015 and an associated person of USCF listed with the CFTC and NFA since December 2015.

As of February 2017, he also is an associated person of USCF Advisers.

USCF Advisers, an affiliate of USCF, is an investment adviser registered under the Investment Advisers Act of 1940, and, as of February 2017, is registered as a commodity pool operator, NFA member and swap firm.

Nguyen earned his B.S.

from California State University at Sacramento, and holds NFA Series 3 and FINRA Series 7 registrations.

Rooney , 53, Management Director of USCF since April 2023 and Chief Marketing Officer of USCF since January 2016.

Rooney also serves as a director of USCF Advisers since March 10, 2024 and was listed as a principal of USCF Advisers effective March 28, 2025.

She also served as a member of the Board of Directors of The Marygold Companies, which is the parent of USCF Investments, Inc., from January 2017 to April 2023.

43 unchanged sentences

Gerber, Melinda D.

Gerber, Andrew F Ngim, Robert L.

Nguyen, Peter M.

Gerber, Andrew F Ngim, Peter M.

Robinson, Kathryn D.

Rooney, Scott Schoenberger, Gordon L.

Rooney, Gordon L.

Ellis, Malcolm R.

5 unchanged sentences

Crumbaugh, Daphne G.

Frydman, Andrew F Ngim, Robert L.

Nguyen, Peter M.

Frydman, Andrew F Ngim, Peter M.

Robinson, Kathryn D.

8 unchanged sentences

In addition, John P.

Love, Robert L.

Nguyen, Ray W.

Allen, Kevin A.

Baum, Kathryn Rooney, and Maya Lowry are registered with the CFTC as Associated Persons of USCF and are NFA Associate Members.

Kathryn Rooney, and Maya Lowry are registered with the CFTC as Associated Persons of USCF and are NFA Associate Members.

Love, Kevin A.

16 unchanged sentences

Principals of SummerHaven

is the Chief Financial Officer of SummerHaven since October 2024.

He also has served as Chief Financial Officer of Basso Capital Management, L.P.

(“Basso”) since March 2006 where he continues to work concurrently with his role at SummerHaven.

Basso is an SEC registered investment advisor that managed a platform of hedge funds for nearly 30 years before transitioning to a multi-family office in 2018.

Prior to SummerHaven and Basso, Mr.

Bowley was a VP of Fund Accounting for DKR Capital Partners, an SEC registered investment advisor that managed various hedge funds and fund of fund offerings, from February 2000 to March 2006.

Bowley received a B.S.

in Actuarial Science and Mathematics from the University of Connecticut.

Bowley became listed as a principal of SummerHaven effective April 3, 2025.

Nelson has been employed by SummerHaven since August 2009 as a partner.

11 unchanged sentences

Nelson became listed as a principal of SummerHaven effective October 1, 2009, as an associated person of SummerHaven effective October 12, 2009 and as an associate member of the NFA effective October 12, 2009.

Nelson is 53 years old.

Geert Rouwenhorst has been employed by SummerHaven since April 2009 as a partner.

3 unchanged sentences

Rouwenhorst became listed as a principal of SummerHaven effective October 8, 2009, as an associated person of SummerHaven effective September 1, 2011 and as an associate member of the NFA effective September 1, 2011.

Rouwenhorst is 62 years old.

Robert Dieter has served as Chief Financial Officer of SummerHaven since May 2017 and also as Chief Operating Officer of SummerHaven since January 2020.

He also served as Chief Compliance Officer of SummerHaven from January 2020 to March 2024.

At SummerHaven he has responsibility for operations, corporate accounting, tax and financial reporting as well as compliance.

Prior to joining SummerHaven in May 2017, Mr.

Dieter founded a consulting practice focused on providing chief financial officer and compliance services to small and medium investment advisors where he worked from October 2009 to present.

Dieter co- founded Seacross Global Advisors, a hedge fund firm where he served as the Chief Financial Officer from April 2007 to September 2009.

Dieter received his M.B.A.

from Tuck School of Business at Dartmouth College in 1972 and a B.A.

from Tufts University in 1969.

Sonti of SummerHaven Investment Management is the Chief Technology Officer since June 2016, Chief Operating Officer since June 2021, and also the Chief Compliance Officer since March 2024.

2 unchanged sentences

Sonti was the Vice President and Chief Technology Officer of Ameritas Investment Partners, a registered investment adviser managing equity, fixed income and index derivatives, from January 2006 to August 2015 where he was responsible for developing, maintaining and researching infrastructure and trading technologies along with trading operations for equity, fixed income and index derivatives.

Sonti was part of the founding team at Summit Investment Partners from June 1988 where he worked until December 2005, when Summit Investment Partners was acquired by Ameritas.

Sonti was part of the founding team at Summit Investment Partners from June 1988 where he worked until December 2005, when Summit Investment Partners was acquired

Summit Investment Partners was a registered investment adviser that managed Summit Mutual Funds along with separate accounts with equity, fixed income and index derivatives for institutional investors.

Sonti’s application to be a principal of SummerHaven was submitted to the National Futures Association on March 17, 2022 and remains pending.

Sonti became listed as a principal of SummerHaven effective May 17, 2022.

Sonti received his M.A.

in Mathematics from the University of Maine and was the Assistant Professor of Mathematics & Computer Science at the College of Wooster.

Sonti is 67 years old.

Audit Committee

33 unchanged sentences

The Board’s responsibilities include:

(i) the selection, evaluation, retention and succession of the Chief Executive Officer and the oversight of the selection and performance of other executive officers, (ii) understanding, reviewing and monitoring the implementation of strategic plans, annual operating plans and budgets, (iii) the selection and oversight of each Trust Series’ independent auditors and the oversight of each Trust Series’ financial statements, (iv) advising management on significant issues, (v) the review and approval of significant company actions and certain other matters, (vi) nominating directors and committee members and overseeing effective corporate governance and (vii) the consideration of other constituencies, such as USCF’s and the Trust Series’ customers, employees, suppliers and the communities impacted by each Trust Series.

significant company actions and certain other matters, (vi) nominating directors and committee members and overseeing effective corporate governance and (vii) the consideration of other constituencies, such as USCF’s and the Trust Series’ customers, employees, suppliers and the communities impacted by each Trust Series.

The non-management directors have designated Gordon L.

24 unchanged sentences

Each of USCI and CPER is contractually obligated to pay USCF a fee, which is paid monthly, equal to 0.95% per annum of average daily total net assets.

From May 1, 2014 through December 31, 2024, USCF contractually lowered the management fee to 0.80% per annum of average daily total net assets for USCI and 0.65% per annum of average daily total net assets for CPER.

For the year ending December 31, 2025, USCF contractually lowered the management fee to 0.80% per annum of average daily total net assets for USCI and 0.65% per annum of average daily total net assets for CPER.

For 2025, each of USCI and CPER accrued aggregate management fees of $1,954,181 and $1,484,130, respectively.

7 unchanged sentences

Fobes serves as chairman of the audit committee of USCF and receives additional compensation from USCF, in recognition of the additional responsibilities he has undertaken in this role.

Nguyen served as a director of USCF until May 31, 2025.

This table reflects his compensation earned through that date.

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

48 unchanged sentences

Form of Fund Administration and Accounting Agreement with Administrative Agency Agreement with The Bank of New York Mellon.

Amended and Restated Licensing Agreement.

First Amendment to the Amended and Restated Licensing Agreement

Amended and Restated Advisory Agreement.

29 unchanged sentences

Incorporated by reference to Registrant’s Annual Report on Form 10-K, for the year ended December 31, 2023, filed on February 29, 2024.

Incorporated by reference to Registrant’s Form 8-K, filed on April 29, 2025.

Incorporated by reference to Registrant’s Annual Report on Form 10-K, for the year ended December 31, 2024, filed on February 28, 2025.

Filed herewith.

21 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 9A. Controls and Procedures