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Item 7. Management’s Discussion and Analysis

2025-02-28 compared with 2024-02-29 · 65 added, 80 removed, 549 unchanged (21% of the section changed)

Management’s Discussion and Analysis of Financial Condition and Results of Operations.

The following discussion should be read in conjunction with the financial statements and the notes thereto of the Trust included elsewhere in this annual report on Form 10-K.

The following discussion should be read in conjunction with the financial statements and the notes thereto of the United States Commodity Index Funds Trust (the “Trust”) included elsewhere in this annual report on Form 10-K.

Forward-Looking Information

This annual report on Form 10-K, including this “Management’s Discussion and Analysis of Financial Condition and Results of Operations,” contains forward-looking statements regarding the plans and objectives of management for future operations.

This information may involve known and unknown risks, uncertainties and other factors that may cause each Trust Series’ actual results,

performance or achievements to be materially different from future results, performance or achievements expressed or implied by any forward-looking statements.

This information may involve known and unknown risks, uncertainties and other factors that may cause each Trust Series’ actual results, performance or achievements to be materially different from future results, performance or achievements expressed or implied by any forward-looking statements.

Each Trust Series believes these factors include, but are not limited to, the following:

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USCI seeks to achieve its investment objective by investing primarily in the Benchmark Component Futures Contracts.

Then, if constrained by regulatory requirements, risk mitigation measures, liquidity requirements or in view of market conditions, USCI will invest next in other Futures Contracts based on the same commodity as the futures contracts subject to such regulatory constraints or market conditions, and finally, to a lesser extent, in other exchange-traded futures contracts that are economically identical or substantially similar to the Benchmark Component Futures Contracts if one or more other Futures Contracts is not available.

Then, if constrained by regulatory requirements, risk mitigation measures (including those that may be taken by USCI, USCI’s FCMs, counterparties or other market participants), liquidity requirements, or in view of market conditions, USCI will invest next in other Futures Contracts based on the same commodity as the futures contracts subject to such regulatory constraints or market conditions, and finally, to a lesser extent, in other exchange-traded futures contracts that are economically identical or substantially similar to the Benchmark Component Futures Contracts if one or more other Futures Contracts is not available.

When USCI has invested to the fullest extent possible in exchange-traded futures contracts, USCI may then invest in other contracts and instruments based on the Benchmark Component Futures Contracts, other Futures Contracts or the commodities included in the SDCI, such as cash-settled options, forward contracts, cleared swap contracts and swap contracts other than cleared swap contracts.

“Other Commodity-Related Investments,” and together with Benchmark Component Futures Contracts and other Futures Contracts, “Commodity Interests.”

Other exchange-traded futures contracts that are economically identical or substantially similar to the Benchmark Component Futures Contracts and other contracts and instruments based on the Benchmark Component Futures Contracts are collectively referred to as “Other Commodity-Related Investments,” and together with Benchmark Component Futures Contracts and other Futures Contracts, “Commodity Interests.”

USCI seeks to achieve its investment objective by investing so that the average daily percentage change in USCI’s NAV for any period of 30 successive valuation days will be within plus/minus ten percent (10%) of the average daily percentage change in the price of the SDCI over the same period.

As a result, investors should be aware that USCI would meet its investment objective even if there are significant deviations between changes in its daily NAV and changes in the daily price of the SDCI, provided that the average daily percentage change in USCI’s NAV over 30 successive valuation days is within plus/minus ten percent (10%) of the average daily percentage change in the price of the SDCI over the same period.

USCF believes that the market arbitrage opportunities will cause the daily changes in USCI’s share price on the NYSE Arca on a percentage basis to closely track the daily changes in USCI’s per share NAV on a percentage basis.

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Other factors that may impact CPER’s investments in other Eligible Copper Futures Contracts, other exchange-traded futures contracts, or Other Copper-Related Investments include allowing CPER to obtain greater liquidity or to execute transactions with more favorable pricing.

In addition, CPER may need to hold significant portions of its portfolio in cash beyond what it has historically held for reasons including (but not limited to) the need to address the changes in market conditions, regulatory requirements or risk mitigation measures or the need to satisfy

potential margin requirements.

For convenience and unless otherwise specified, Benchmark Component Copper Futures Contracts, other Eligible Copper Futures Contracts and Other Copper-Related Investments collectively are referred to as “Copper Interests.”

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Investors should be aware that CPER’s investment objective is not for its NAV or market price of shares to equal, in dollar terms, the spot prices of the commodities underlying the Benchmark Component Copper Futures Contracts or the prices of any particular group of futures contracts.

CPER will not seek to achieve its stated investment objective over a time period of greater than one day.

CPER will not seek to achieve its stated investment objective over a period of time greater than one day.

This is because natural market forces called contango and backwardation have impacted the total return on an investment in CPER’s shares during the past year relative to a hypothetical direct investment in various commodities and, in the future, it is likely that the relationship between the market price of CPER’s shares and changes in the spot prices of the underlying commodities will continue to be so impacted by contango and backwardation.

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Accordingly, the Position Limits Rule could inhibit the Trust Series’ ability to invest in the Applicable Benchmark Component Futures Contracts and thereby could negatively impact the ability of the Trust Series to meet its investment objective.

No Trust Series has limited the size of its offering and each Trust Series intends to utilize substantially all of its proceeds to purchase Applicable Benchmark Component Futures Contracts and Other Commodity-Related Investments to the extent possible.

If a Trust Series encounters accountability levels, position limits, or price fluctuation limits for Applicable Benchmark Component Futures Contracts, it may purchase commodity futures on other exchanges that trade listed commodity futures or enter into swaps or other transactions to meet its investment objective.

In addition, if a Trust Series exceeds accountability levels on an exchange, and is required by the exchange to reduce its holdings, such reduction could potentially cause a tracking error between the price of the shares of a Trust Series and the prices of the Applicable Benchmark Component Futures Contracts.

Margin for OTC Swaps

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Currently, swap dealers, major swap participants, commodity pools, certain private funds and entities predominantly engaged in activities that are financial in nature are required to execute on a swap execution facility, and clear, certain interest rate swaps and index-based credit default swaps.

if a Trust Series enters into an interest rate or index-based credit default swap that is subject to these requirements, such swap will be required to be executed on a swap execution facility and centrally cleared.

As a result, if a Trust Series enters into an interest rate or index-based credit default swap that is subject to these requirements, such swap will be required to be executed on a swap execution facility and centrally cleared.

Mandatory clearing and “made available to trade” determinations with respect to additional types of swaps may be issued in the future, and, when finalized, could require each Trust Series to electronically execute and centrally clear certain OTC instruments presently entered into and settled on a bi-lateral basis.

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exchanges to be offered and sold in the United States.

Infectious disease outbreaks like COVID-19 could negatively affect the valuation and performance of a Trust Series’ investments.

An outbreak of infectious respiratory illness caused by a novel coronavirus known as COVID-19 was first detected in China in December 2019 and spread globally.

In March 2020, the World Health Organization declared the COVID-19 outbreak a pandemic.

COVID-19 resulted in numerous deaths, travel restrictions, closed international borders, enhanced health screenings at ports of entry and elsewhere, disruption of and delays in healthcare service preparation and delivery, prolonged quarantines and the imposition of both local and more widespread “work from home” measures, cancellations, loss of employment, supply chain disruptions, and lower consumer and institutional demand for goods and services, as well as general concern and uncertainty.

The spread of COVID-19 had a material adverse impact on local economies in the affected jurisdictions and also on the global economy, as cross border commercial activity and market sentiment were impacted by the outbreak and government and other measures seeking to contain its spread.

Infectious disease outbreaks like COVID-19 may arise in the future and could adversely affect individual issuers and capital markets in ways that cannot necessarily be foreseen.

In addition, actions taken by government and quasi-governmental authorities and regulators throughout the world in response to such an outbreak, including the potential for significant fiscal and monetary policy changes, may affect the value, volatility, pricing and liquidity of some investments or other assets, including those held by or invested in by each Trust Series.

Public health crises caused by infectious disease outbreaks may exacerbate other pre-existing political, social and economic risks in certain countries or globally and their duration cannot be determined with certainty.

Infectious disease outbreaks like COVID-19 could negatively affect the Trust Series and the valuation and performance of the investments of each Trust Series.

Infectious disease outbreaks like the COVID-19 pandemic may arise in the future and could adversely affect each Trust Series and, more generally, individual issuers and capital markets, in ways that cannot necessarily be foreseen.

For example, COVID-19 resulted in numerous deaths, travel restrictions, closed international borders, enhanced health screenings at ports of entry and elsewhere, disruption of and delays in healthcare service preparation and delivery, prolonged quarantines and the imposition of both local and more widespread “work from home” measures, cancellations, loss of employment, supply chain disruptions, and lower consumer and institutional demand for goods and services, as well as general concern and uncertainty.

The COVID-19 pandemic that occurred in 2020 had a material adverse impact on local economies in the affected jurisdictions and also on the global economy, as cross border commercial activity and market sentiment were impacted by the outbreak and government and other measures seeking to contain COVID-19’s spread.

An infectious disease outbreak may arise in the future and could have the same or similar effects as the COVID-19 pandemic, or different effects that cannot be foreseen.

Moreover, as was the case with the COVID-19 pandemic, actions taken by government and quasi-governmental authorities and regulators throughout the world in response to an infectious disease outbreak, including the potential for significant fiscal and monetary policy changes, may affect the value, volatility, pricing and liquidity of some investments or other assets, including those held by or invested in by each Trust Series.

Public health crises caused by infectious disease outbreaks may exacerbate other preexisting political, social and economic risks in certain countries or globally and their duration cannot be determined with certainty.

In a rising rate environment, the Trust Series may not be able to fully invest at prevailing rates until any current investments in Treasury Bills mature in order to avoid selling those investments at a loss.

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As of December 31, 2024, the value of the SDCI was $2,329.08, up approximately 18.57% over the year ended December 31, 2024.

Of the 27 components of SummerHaven Dynamic Commodity Index (SDCI), sixteen had positive returns for first-half 2022.

Gas Oil returned 57.7% in the first-half 2022 while Copper declined by -17.4%.

The best performing sector was energy (up 57.7%).

Commodities have continued the 2021 rally as inflation grew from 1.4% in 2020 to 9.1% in 2022.

Of the 27 components of SummerHaven Dynamic Commodity Index (SDCI), thirteen had positive returns fin the year ended December 31, 2024.

The best performing sector was Softs (up approximately 25.9%) followed by Precious Metals (up approximately 19.0%).

Commodities broadly rallied from early 2020 to mid-2022 as inflation grew from 1.4% in 2020 to 9.1% in 2022.

Inflation is a headwind for stocks and bonds and a tailwind for real assets such as commodities.

Historically, commodities have been a hedge against inflation and positive inflation shocks.

In 2022, as the fact of high inflation became more evident, stocks and Bonds suffered losses while commodities continued to perform well.

The age-old wisdom of stock-bond diversification has been challenged in an unprecedented way.

Since the inception in 1976 of US aggregate bond index, 2022 is the only year where both US stocks and bonds have experience significant negative returns (-20.0% and -10.3% respectively).

In contrast, USCI’s NAV was up 18.47% for the nine months ended September 30, 2023.

As inflation has declined since mid-2022, the Bloomberg Commodity Index Total Return (BCOMTR) also declined.

However, USCI’s dynamic strategy led to outperformance versus the BCOMTR, rising from mid-2022 through the end of 2024 while BCOMTR and other broad commodity indexes declined.

The return of approximately 18.57% on the SDCI listed above is a hypothetical return only and could not actually be achieved by an investor holding Futures Contracts due to the impact of trading costs and other expenses.

USCI’s per share NAV began the year at $56.23 and ended the year at $56.34 on December 31, 2023, an increase of approximately 0.20% over the year.

USCI’s per share NAV began the period at $56.34 and ended the period at $66.04 on December 31, 2024, an increase of approximately 17.22% over the year.

See “Tracking Each Trust Series’ Benchmark” below for information about how expenses and income affect USCI’s per share NAV.

The Russia-Ukraine war and the emerging conflict in the Middle East due to Hamas’ attack on Israel have raised concerns among investors that a global shortage of many commodities is possible.

Russia, Ukraine, and Belarus are major producers and exporters of many metals, grains, and energy products that are critical to global supply.

Substantial productive capacity has been halted in Ukraine, and Russia may be unable or unwilling to export what it produces.

This has put upward pressure on commodity prices globally, beyond the impact of bullish fundamentals that were already in place.

Should the war continue or escalate, or if sanctions or retaliation lead to a further reduction in production and exports from Ukraine, Russia, and Belarus, then commodity prices could rise further and prices could become more volatile.

Conversely, should concerns about commodity shortages resulting from the Russia-Ukraine war ebb due to an expected or actual resolution of the war, then commodity prices could stabilize or decline.

Likewise, the situation in the Middle East has impacted energy prices, with WTI and Brent crude oil rising approximately 10% in the first two weeks after the Hamas attack.

Crude, along with gasoline, heating oil, and gasoil would experience even stronger gains if production or transportation of crude oil is disrupted.

If the situation remains contained primarily to Israel, and or, should hostilities end, then prices for crude oil and its derivatives could stabilize or decline.

Significant market volatility can occur in the commodity markets and the commodity futures markets.

Such volatility can be caused by events such as the COVID-19 pandemic, related supply chain disruptions, war, including the Russia-Ukraine war, attacks or threats of attack by terrorists, conflicts in the Middle East, and disputes among commodity-producing countries.

Events such as these can increase volatility, which may affect the value, pricing and liquidity of some investments or other assets, including those held by or invested in by a Trust Series and have a negative impact on such Trust Series or its ability to have all of its assets invested in the Benchmark Component Futures Contracts.

Copper Markets

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During the year ended December 31, 2024, the price of the front month copper futures contract traded in a range between $368.15 per pound and $510.60 per pound.

Prices decreased by 16.78% between December 31, 2021 to December 31, 2023 finishing the period at $3.8105.

Copper futures markets rose dramatically from 2020 to mid-April 2022.

Copper prices declined sharply from late spring to mid-summer due to concerns about demand from the manufacturing sector, monetary tightening and related concerns about a slowdown in global growth, and COVID-19 flare ups in China.

In the second half of 2022, Copper recovered some of it’s earlier losses for the year, partially as a result of China reopening its economy.

Long-term, copper demand is likely to remain robust and supply is also likely to remain constrained and slow to respond to demand increases.

Prices increased by approximately 3.5% between December 31, 2023 to December 31, 2024 finishing the year at $402.65.

Copper futures markets reached an all-time high in May of 2024 before declining 22% between the May peak and August low.

Prices resumed their upward trajectory in early August, due to an improving outlook for the U.S.

and global economy, China stimulus, and growing supply constraints and forecasts for forthcoming copper shortages.

However, copper fell in the fourth quarter of 2024 as the outlook from the third quarter soured.

Over the longer term, with tight markets, increased demand from China and from new technologies, and a growing drumbeat of forecasts for a supply crunch, copper demand is likely to remain robust and supply is also likely to remain constrained and slow to respond to demand increases, however prices may come under pressure during periods of contraction and/or economic uncertainty.

The Russia-Ukraine war has affected many commodities in which Russia, Ukraine, and Belarus are major producers and exports, such as certain metals, grains, and energy products.

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On September 14, 2011, USCF redeemed the 20 Sponsor Shares of USCI, and on September 19, 2011, USCF purchased five shares of USCI in the open market.

Since its initial offering of 50,000,000 shares, USCI has registered 10,000,000 additional shares as of December 31, 2023.

As of December 31, 2023, USCI had issued 41,600,000 shares, 3,000,000 of which were outstanding.

As of December 31, 2023, USCI had registered an unlimited number of shares available for issuance.

As of December 31, 2024, USCI had 2,900,000 shares outstanding.

USCI has an unlimited number of shares registered and available for issuance.

More shares may have been issued by USCI than are outstanding due to the redemption of shares.

Since its initial offering of 30,000,000 shares, CPER has registered 50,000,000 additional shares as of December 31, 2023.

As of December 31, 2023, CPER had issued 26,700,000 shares, 5,450,000 of which were outstanding.

As of December 31, 2023, CPER had registered an unlimited number of shares available for issuance.

As of December 31, 2024, CPER had 5,650,000 shares outstanding.

CPER has an unlimited number of shares registered and available for issuance.

More shares may have been issued by CPER than are outstanding due to the redemption of shares.

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As of December 31, 2024, USCI and CPER had the following Authorized Participants:

ABN AMRO Clearing USA LLC, BNP Paribas Securities Corp., Citadel Securities LLC, Goldman Sachs & Company, Jefferies LLC., JP Morgan Securities Inc., Merrill Lynch Professional Clearing Corp., Morgan Stanley & Company Inc., RBC Capital Markets LLC and Virtu Americas LLC.

ABN AMRO Clearing USA LLC, BNP Paribas Securities Corp., Citadel Securities LLC, Goldman Sachs & Company, Jefferies & Company Inc., JP Morgan Securities Inc., Merrill Lynch Professional Clearing Corp., Morgan Stanley & Company Inc., RBC Capital Markets LLC and Virtu Americas LLC.

For the Year Ended December 31, 2024 Compared to the Year Ended December 31, 2023

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The fee is accrued daily and paid monthly.

The increase in the per share NAV for the year ended December 31, 2023, compared to the year ended December 31, 2022, was due to increase in values of the Futures Contracts held by USCI.

The increase in the per share NAV for the year ended December 31, 2024, compared to the year ended December 31, 2023, was due to an increase in values of the Futures Contracts held by USCI.

Average interest rates earned on short-term investments held by USCI, including cash, cash equivalents and Treasuries, were higher during the year ended December 31, 2024, compared to the year ended December 31, 2023.

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To the degree that the aggregate yield is higher, the net expense ratio, inclusive of income, will be lower.

The decrease in total fees and other expenses excluding management fees for the year ended December 31, 2023, compared to the year ended December 31, 2022 was due primarily to a decrease in total commissions accrued to brokers and professional fees.

The increase in total fees and other expenses excluding management fees for the year ended December 31, 2024, compared to the year ended December 31, 2023 was due primarily to an increase in audit, professional, and reporting fees.

The decrease in USCI’s total commissions accrued to brokers for the year ended December 31, 2024, compared to the year ended December 31, 2023, was due primarily to a lower number of Futures Contracts being held and traded.

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Total fees and other expenses excluding management fees

Fees and expenses related the registration or offering of additional shares

Total commissions accrued to brokers

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The fee is accrued daily and paid monthly.

The increase in the per share NAV for the year ended December 31, 2023, compared to the year ended December 31, 2022, was due to an increase/decrease in the values of the Futures Contracts held by CPER.

The increase in the per share NAV for the year ended December 31, 2024, compared to the year ended December 31, 2023, was due to an increase in the values of the Futures Contracts held by CPER.

Average interest rates earned on short-term investments held by CPER, including cash, cash equivalents and Treasuries, were higher during the year ended December 31, 2024, compared to the year ended December 31, 2023.

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To the degree that the aggregate yield is higher, the net expense ratio, inclusive of income, will be lower.

The decrease in CPER’s total commissions accrued to brokers for the year ended December 31, 2023, compared to the year ended December 31, 2022, was due primarily to a lower number of Futures Contracts being held and traded.

The decrease CPER’s total commissions accrued to brokers for the year ended December 31, 2024, compared to the year ended December 31, 2023, was due primarily to a lower number of Futures Contracts being held and traded.

Tracking Each Trust Series’ Benchmark

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During the year ended December 31, 2024, USCI’s portfolio held at all times Futures Contracts based on at least fourteen different commodities.

Due to changes in the composition of the SDCI, each month the list of Benchmark Component Futures Contracts held by

USCI changed (see the section “The SDCI” below).

Due to changes in the composition of the SDCI, each month the list of Benchmark Component Futures Contracts held by USCI changed (see the section “The SDCI” below).

The table below lists the Benchmark Component Futures Contracts held during each month in 2024.

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Thus, USCI’s total actual return on its holdings in any of the commodities shown below may be higher, or lower, than the actual change in the spot price of the particular commodity.

Benchmark Component Futures Contracts for USCI

Price Performance

Feeder Cattle

Crude Oil (WTI)

Unleaded Gasoline

Crude Oil (Brent)

Unleaded Gasoline

* From 12/31/23 to 12/31/2024 Source:

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The average daily difference was 0.004% (or 0.4 basis points, where 1 basis point equals 1/100 of 1%).

As a percentage of the daily movement of the SDCI, the average difference in daily tracking by the per share NAV was (1.728)%, meaning that over this time period USCI’s tracking difference was within the plus or minus 10% range established as its benchmark tracking goal.

As a percentage of the daily movement of the SDCI, the average error in daily tracking by the per share NAV was (8.554)%, meaning that over this time period USCI’s tracking error was within the plus or minus 10% range established as its benchmark tracking goal.

Since the commencement of the offering of USCI’s shares to the public on August 10, 2010 through December 31, 2024, the simple average daily change in the SDCI was 0.017%, while the simple average daily change in the per share NAV of USCI over the same time period was 0.011%.

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However, if USCI’s daily changes in its per share NAV had instead exactly tracked the changes in the daily total return of the SDCI, USCI would have had an estimated per share NAV of $65.36 as of December 31, 2024, for a total return over the relevant time period of 16.02%.

The difference between the actual per share NAV total return of USCI of 0.20% and the expected total return based on the SDCI of 1.60% was a difference over the time period of (1.40)%, which is to say that USCI’s actual total return underperformed its benchmark by that percentage.

The difference between the actual per share NAV total return of USCI of 17.22% and the expected total return based on the SDCI of 16.02% was a difference over the time period of 1.20%, which is to say that USCI’s actual total return outperformed its benchmark by that percentage.

USCI incurs expenses primarily composed of the management fee, brokerage commissions for the buying and selling of futures contracts, and other expenses.

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The average daily difference was 0.002% (or 0.2 basis points, where 1 basis point equals 1/100 of 1%).

As a percentage of the daily movement of the SCI, the average difference in daily tracking by the per share NAV was (3.436)%, meaning that over this time period CPER’s tracking difference was within the plus or minus 10% range established as its benchmark tracking goal.

As a percentage of the daily movement of the SCI, the average error in daily tracking by the per share NAV was (3.204)%, meaning that over this time period CPER’s tracking error was within the plus or minus 10% range established as its benchmark tracking goal.

Since the commencement of the offering of CPER’s shares to the public on November 15, 2011 through December 31, 2024, the simple average daily change in the SCI was 0.013%, while the simple average daily change in the per share NAV of CPER over the same time period was 0.009%.

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The following two charts demonstrate the correlation between the changes in CPER’s NAV and the changes in the SCI.

The first chart below shows the daily movement of CPER’s per share NAV versus the daily movement of the SCI for the 30-valuation day period ended December 29, 2023, the last trading day in December.

The first chart below shows the daily movement of CPER’s per share NAV versus the daily movement of the SCI for the 30-valuation day period ended December 31, 2024, the last trading day in September.

The second chart below shows the monthly total returns of CPER as compared to the monthly value of the SCI for the five years ended December 31, 2024.

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However, if CPER’s daily changes in its per share NAV had instead exactly tracked the changes in the daily total return of the SCI, CPER would have had an estimated per share NAV of $25.13 as of December 31, 2024, for a total return over the relevant time period of 4.26%.

The difference between the actual per share NAV total return of CPER of 4.46% and the expected total return based on the SCI of 5.77% was a difference over the time period of (1.31)%, which is to say that CPER’s actual total return underperformed its benchmark by that percentage.

The difference between the actual per share NAV total return of CPER of 4.69% and the expected total return based on the SCI of 4.26% was a difference over the time period of 0.43%, which is to say that CPER’s actual total return outperformed its benchmark by that percentage.

CPER incurs expenses primarily composed of the management fee, brokerage commissions for the buying and selling of futures contracts, and other expenses.

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At the same time, each Trust Series earns dividend and interest income on its cash, cash equivalents and Treasuries.

A Trust Series is not required to distribute any portion of its income to its shareholders and did not make any distributions to shareholders during the during the year ended December 31, 2023.

A Trust Series is not required to distribute any portion of its income to its shareholders and did not make any distributions to shareholders during the year ended December 31, 2024.

Interest payments, and any other income, were retained within the portfolio and added to each Trust Series’ NAV.

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As such, USCF anticipates that each Trust Series could possibly outperform its benchmark so long as interest earned is higher than the fees and expenses paid by each Trust Series.

Third, a Trust Series may hold Futures Contracts in a particular commodity other than the one specified as the Applicable Benchmark Component Futures Contract, or may hold Other Related Investments in its portfolio that may fail to closely track the Applicable Index’s

total return movements.

Taking USCI as an example, assume for a given month one of the Benchmark Component Futures Contracts is the NYMEX WTI physically settled Futures Contract, trading under the symbol “CL,” for the contract month of November 2020.

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*PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS

SummerHaven Dynamic Commodity Index Total Return SM (“SDCI”) Year-Over-Year Hypothetical Total Returns (Year Ending 2013 through 12/31/2023)* YTD)

SummerHaven Dynamic Commodity Index Total Return SM (“SDCI”) Year-Over-Year Hypothetical Total Returns (Year Ending 2014 - 12/31/2024)*

SummerHaven Index Management, Bloomberg

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*PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS

Hypothetical Performance Results* for the SCI for the period from Year Ending December 31, 2013 through December 31, 2023

Hypothetical Performance Results* for the SCI for the period from Year Ending 2014 through December 31, 2024

Ending Level*

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*PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS

SummerHaven Copper Index (“SCI”) Year-Over-Year Hypothetical Total Returns (1/1/2013– 12/31/2023 YTD)

SummerHaven Copper Index (“SCI”) Year-Over-Year Hypothetical Total Returns (1/1/2014– 12/31/2024)

SummerHaven Index Management, Bloomberg

*PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS

Hypothetical and Historical Results for the period from December 31, 1997 through December 31, 2024

Hypothetical and Historical Results for the period

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Ten Year Comparison of Index Returns of

BCOM HG TR, Spot Copper Price, Spot Copper Price less Storage Cost, and the Hypothetical Returns of the SCI TR (12/31/2013– 12/31/2023)

BCOM HG TR, Spot Copper Price, Spot Copper Price less Storage Cost, and

the Hypothetical Returns of the SCI TR (12/31/2014– 12/31/2024)

SHIM, Bloomberg, LME

changes described above and became effective on January 1, 2021, from which point then the revised composition of the index is included.

The following chart compares the hypothetical total return of the SCI in comparison with the actual total return of two major indices and spot copper prices (less storage cost) over a five year period , where the SCI includes the original composition of the index until the changes described above and became effective on January 1, 2021, from which point then the revised composition of the index is included.

*PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS

Five Year Comparison of Index Returns of

BCOM HG TR, Spot Copper Price, Spot Copper Price less Storage Cost, and the Hypothetical Returns of the SCI (12/31/2018- 12/31/2023)

BCOM HG TR, Spot Copper Price, Spot Copper Price less Storage

Cost, and the Hypothetical Returns of the SCI (12/31/2019- 12/31/2024)

SHIM, Bloomberg, LME

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The values which are used by each Trust Series for its Futures Contracts are provided by its commodity broker who uses market prices when available, while OTC swaps are valued based on the present value of estimated future cash flows that would be received from or paid to a third party in settlement of these derivative contracts prior to their delivery date and valued on a daily basis.

In addition, each Trust Series estimates interest

income on a daily basis using prevailing rates earned on its cash and cash equivalents.

In addition, each Trust Series estimates interest income on a daily basis using prevailing rates earned on its cash and cash equivalents.

These estimates are adjusted to the actual amount received on a monthly basis and the difference, if any, is not considered material.

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Each Trust Series’ exposure to market risk depends on a number of factors, including the markets for commodities, the volatility of interest rates and foreign exchange rates, the liquidity of the Applicable Interest markets and the relationships among the contracts held by each such Trust Series.

The limited experience that each Trust Series has had in utilizing its model to trade in Applicable Interests in

a manner intended to track the changes in the Applicable Index, as well as drastic market occurrences, could ultimately lead to the loss of all or substantially all of an investor’s capital.

The limited experience that each Trust Series has had in utilizing its model to trade in Applicable Interests in a manner intended to track the changes in the Applicable Index, as well as drastic market occurrences, could ultimately lead to the loss of all or substantially all of an investor’s capital.

When a Trust Series enters into Futures Contracts and Other Related Investments, it is exposed to the credit risk that the counterparty will not be able to meet its obligations.

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In addition, the CFTC requires FCMs to hold in a secure account a Trust Series’ assets related to foreign Futures Contracts trading.

During the year ended December 31, 2023, USCI made investments on the London Metal Exchange.

During the year ended December 31, 2024, CPER made investments on the London Metal Exchange.

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Either party may terminate these agreements earlier for certain reasons described in the agreements.

As of December 31, 2023, USCI’s portfolio consisted of 4,766 Futures Contracts traded on the Futures Exchanges and CPER’s portfolio consisted of held 1,342 Contracts traded on the COMEX.

As of December 31, 2024, USCI’s portfolio consisted of 4,066 Futures Contracts traded on the Futures Exchanges and CPER’s portfolio consisted of 1,396 Contracts traded on the COMEX.

For a list of each of USCI’s and CPER’s current holdings, please see www.uscfinvestments.com.

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 7. Management’s Discussion and Analysis