What changed in this filing

/stocks — the workspaceLOADING

Item 9A. Controls and Procedures

2025-02-28 compared with 2024-02-29 · 49 added, 43 removed, 390 unchanged (19% of the section changed)

39 unchanged sentences

In addition, he has been the portfolio manager of:

(1) DNO from September 2009 to September 2018, (2) USO and USL since March 2010, (3) BNO since June 2010, (4) UNG since May 2015, (5) United States 3x Oil Fund and United States 3x Short Oil Fund from July 2017 to December 2019, and (6) the USCF Commodity Strategy Fund, a series of USCF Mutual Funds Trust, from October 2017 to March 2019.

Allen also has served as the portfolio manager of the USCF SummerHaven Dynamic Commodity Strategy No K-1 Fund, a series of the USCF ETF Trust, from May 2018 to October 2021 and then portfolio manager since January 2022.

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Baum , 54, has served as the Chief Investment Officer of USCF since September 1, 2016 and as a Portfolio Manager of USCF from March 2016 to April 2017.

He also serves as the Chief Investment Officer of USCF Advisers since June 2021.

He also has served as the Chief Investment Officer of USCF Advisers since June 2021.

Prior to joining USCF, Mr.

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Baum is a CFA Charterholder, CAIA Charterholder, earned a B.B.A.

in Finance from Texas Tech University and holds NFA Series 3 and FINRA Series 7 registration.

in Finance from Texas Tech University and holds an NFA Series 3 and FINRA Series 7 registrations.

Crumbaugh , 61 , Management Director of USCF since April 2023 and Chief Financial Officer, Secretary and Treasurer of USCF since May 2015.

Crumbaugh served as the Chief Financial Officer of The Marygold Companies, Inc., formerly Concierge Technologies, Inc.

(“Marygold”), the parent of USCF Investments, Inc.

(formerly Wainwright Holdings, Inc.) (“USCF Investments”) from December 2017 to January 2024 and as a management director on the board of directors of Marygold from April 2023 to January 2024.

He is also the Treasurer and a member of the Board of Directors of Marygold & Co., a subsidiary of Marygold, since November 2019.

In addition, Mr.

Crumbaugh has served as a director of USCF Investments, the parent and sole member of USCF, since December 2016.

Crumbaugh has been a principal of USCF listed with the CFTC and NFA since July 1, 2015 and, as of

January 2017, he is a principal 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.

Crumbaugh has been a principal of USCF listed with the CFTC and NFA since July 1, 2015 and, as of January 2017, he is a principal of USCF Advisers, an affiliate of USCF, which 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.

Since June 2015, Mr.

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Crumbaugh joined USCF as the Assistant Chief Financial Officer on April 6, 2015.

Crumbaugh served as the Chief Financial Officer of The Marygold Companies, Inc., formerly Concierge Technologies, Inc.

(“Marygold”), the parent of USCF Investments, Inc.

(formerly Wainwright Holdings, Inc.) (“USCF Investments”) from December 2017 to January 2024 and as a management director on the board of directors of Marygold from April 2023 to January 2024.

He is also the Treasurer and a member of the Board of Directors of Marygold & Co., a subsidiary of Marygold, since November 2019.

Prior to joining USCF, Mr.

3 unchanged sentences

and January 2011 through February 2011.

From December 2012 through December 2013, Mr.

Crumbaugh was Vice President, Corporate Controller and Treasurer of Auction.com, LLC, a residential and commercial real estate online auction company.

From March 2011 through September 2012, Mr.

Crumbaugh was Chief Financial Officer of IP Infusion Inc., a technology company providing network routing and switching software enabling software-defined networking solutions for major mobile carriers and network infrastructure providers.

Crumbaugh earned a B.A.

6 unchanged sentences

Frydman is listed as a principal of USCF as of June 1, 2022.

Frydman earned her JD from the Northwestern University Pritzker School of Law and a B.A.

Frydman earned her J.D.

from the Northwestern University Pritzker School of Law and a B.A.

in College of Letters and Spanish from Wesleyan University.

3 unchanged sentences

Prior to that, while still at USCF, he was a Portfolio Manager beginning with the launch of USO in April 2006.

Love was the portfolio manager of USO from April 2006 until March 2010 and the portfolio manager for USL from December 2007 until March 2010.

Love has been the portfolio manager of UNG since April 2007, and the portfolio manager of UGA, UHN, and UNL since March 2010.

Love has served as on the Board of Managers of USCF Advisers since November 2016 and as its President since June 18, 2015.

Love also served as a portfolio manager of USCF from April 2006 until April 2015.

Love has served on the Board of Managers of USCF Advisers since November 2016 and as its President since June 2015.

He also acted as co-portfolio manager of the Stock Split Index Fund, a series of the USCF ETF Trust for the period from September 2014 to December 2015, when he was promoted to the position of President and Chief Executive Officer of the USCF ETF Trust.

He also has served as the President and Chief Executive Officer of the USCF ETF Trust since December 2015.

Love has been a principal of USCF listed with the CFTC and NFA since January 17, 2006.

6 unchanged sentences

from the University of Southern California, holds NFA Series 3 and FINRA Series 7 registrations and is a CFA Charterholder.

Andrew F Ngim , 63, co-founded USCF in 2005 and has served as a Management Director from May 2005 to April 2023 and, since August 15, 2016, has served as the Chief Operating Officer of USCF.

Ngim has served as the portfolio manager for USCI and CPER since January 2013 and for the United States Agriculture Index Fund from January 2013 to September 2018.

Andrew F Ngim , 64, co-founded USCF in 2005 and has served as the Chief Operating Officer of USCF since August 2016.

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

3 unchanged sentences

from January 2000 to January 2013.

Ngim also served as portfolio manager of (a) the following series of the USCF ETF Trust:

(1) the Stock Split Index Fund from September 2014 to October 2017, (2) the USCF Restaurant Leaders Fund from November 2016 to October 2017, (3) USCF SummerHaven SHPEI Index Fund from December 2017 to October 2020, (4) USCF SummerHaven SHPEN Index Fund from December 2017 to April 2020, and (b) a series of USCF Mutual Funds Trust, the USCF Commodity Strategy Fund, from March 2017 to March 2019.

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, (4) the USCF Sustainable Commodity Strategy Fund from August 9, 2023 to present, and (5) the USCF Aluminum Strategy Fund from October 6, 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, and (4) the USCF Sustainable Commodity Strategy Fund from August 9, 2023 to present.

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

Ngim has been a principal of USCF listed with the CFTC and NFA since November 2005 and a principal of USCF Advisers LLC since January 2017.

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.

Ngim earned his B.A.

13 unchanged sentences

Rooney , 52, Management Director of USCF since April 2023 and Chief Marketing Officer of USCF since January 2016.

Since January 2016.

She also has 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 USCF Investments, Inc.

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.

USCF Investments, Inc.

is the sole member of USCF.

6 unchanged sentences

Additionally, effective as of February 2017, she is an associated person of USCF Advisers, LLC, an affiliate of USCF, which 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.

Rooney graduated from Wellesley College with a Bachelor of Arts in economics and psychology in June 1994.

Rooney graduated from Wellesley College with a B.A.

in economics and psychology in June 1994.

Ellis , 78, Independent Director of USCF since September 2005.

7 unchanged sentences

He has been a principal of USCF listed with the CFTC and NFA since November 2005.

Ellis is a professional engineer, retired, and earned an MBA in international finance.

Ellis is a professional engineer, retired, and earned an M.B.A.

in international finance.

Fobes III , 60, Independent Director of USCF and Chairman of USCF’s audit committee since September 2005.

10 unchanged sentences

Robinson has been a Research Fellow since 1993 with the Hoover Institution, a public policy think tank located on the campus of Stanford University.

He authored three books and has

been published in the New York Times, Red Herring, and Forbes ASAP and is the editor of Can Congress Be Fixed?:

He authored three books and has been published in the New York Times, Red Herring, and Forbes ASAP and is the editor of Can Congress Be Fixed?:

Five Essays on Congressional Reform (Hoover Institution Press, 1995).

Robinson has been a principal of USCF listed with the CFTC and NFA since December 2005.

He earned an MBA from the Stanford University Graduate School of Business, graduated from Oxford University in 1982 after studying politics, philosophy, and economics and graduated summa cum laude from Dartmouth College in 1979.

He earned an M.B.A.

from the Stanford University Graduate School of Business, graduated from Oxford University in 1982 after studying politics, philosophy, and economics and graduated summa cum laude from Dartmouth College in 1979.

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

25 unchanged sentences

Andrew F Ngim, Darius Coby, Seth Lancaster and Zach Sanchez execute trades on behalf of each Trust Series.

In addition, Nicholas D.

Gerber, John P.

In addition, John P.

Love, Robert L.

1 unchanged sentence

Allen, Kevin A.

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

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

Love, Kevin A.

36 unchanged sentences

Rouwenhorst is 62 years old.

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

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.

5 unchanged sentences

from Tufts University in 1969.

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

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.

Previously, he was a Special Consultant to the United Nations Joint Staff Pension Fund from September 2015 to May 2016.

29 unchanged sentences

Each Trust Series intends to disclose any amendments or waivers to the Code of Ethics applicable to USCF’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, on its website.

Insider Trading Policy

USCF has adopted an insider trading policy applicable to USCF’s directors, officers and employees, which is included as an exhibit to this annual report on Form 10-K.

Executive Sessions of the Non-Management Directors

2 unchanged sentences

Ellis to preside over each such executive session.

Interested parties who wish to make their concerns known to the non-management directors

may communicate directly with Mr.

Interested parties who wish to make their concerns known to the non-management directors may communicate directly with Mr.

Ellis by writing to 475 Milan Drive, No.

52 unchanged sentences

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

Trust Series of more than 5%, will be subject to the provisions regarding “Fiduciary Duty” as set forth in Section 5.6 of the Trust Agreement and will be reviewed and approved by the audit committee of the Board of USCF.

” Any transaction with a related person that must be disclosed in accordance with SEC Regulation S-K item 404(a), including financial transactions by any Trust Series with directors or executive officers of USCF or holders of beneficial interests in USCF or any Trust Series of more than 5%, will be subject to the provisions regarding “Fiduciary Duty” as set forth in Section 5.6 of the Trust Agreement and will be reviewed and approved by the audit committee of the Board of USCF.

Director Independence

10 unchanged sentences

Audit fees consist of fees paid to Cohen & Company, Ltd.

and Spicer Jeffries LLP for (i) the audit of each of the Trust’s and the Trust Series’ annual financial statements included in the annual report on Form 10-K, and review of financial statements included in the quarterly reports on Form 10-Q and certain of the Trust’s and the Trust Series’ current reports on Form 8-K;

for (i) the audit of each of the Trust’s and the Trust Series’ annual financial statements included in the annual report on Form 10-K, and review of financial statements included in the quarterly reports on Form 10-Q and certain of the Trust’s and the Trust Series’ current reports on Form 8-K;

(ii) the audit of the Trust’s and each Trust Series’ internal control over financial reporting included in the annual report on Form 10-K;

25 unchanged sentences

Amended and Restated Advisory Agreement.

Insider Trading Policies and Procedures

Consent of Independent Registered Public Accounting Firm.

26 unchanged sentences

Incorporated by reference to Registrant’s Annual Report on Form 10-K for the year ended December 31, 2019, filed on March 13, 2020.

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

Filed herewith.

10 unchanged sentences

February 28, 2025

Pursuant to the requirements of the Securities Exchange Act of 1934, this Report has been signed below by the following persons on behalf of the Registrant in the capacities* and on the dates indicated.

Title (Capacity)

Chief Executive Officer of United States Commodity Funds, LLC

February 28, 2025

(Principal Executive Officer)

/s/ Stuart P.

Chief Financial Officer of United States Commodity Funds, LLC

February 28, 2025

(Principal Financial Officer)

The Registrant is a trust and the persons are signing in their capacities as officers of United States Commodity Funds LLC, the Sponsor of the Registrant.

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