What changed in this filing

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Item 9A. Controls and Procedures

2025-02-26 compared with 2024-02-23 · 37 added, 35 removed, 221 unchanged (25% of the section changed)

33 unchanged sentences

Chief Compliance Officer

Melanie Ringold 1

Board of Managers

David Hemming

Vice President, Head of Alternatives Portfolio Management

Executive officer, within the meaning of Rule 3b-7 under the Exchange Act, of the Fund.

3 unchanged sentences

The Board of Managers is composed of Messrs.

Hartigan, Krugman and Zerr.

Hartigan and Krugman and Ms.

The Board of Managers has established an Audit Committee with the following members:

Hartigan, Krugman and Zerr.

The overall purpose of the Audit Committee is to assist the Board of Managers with overseeing the Fund’s financial statements, the Fund's compliance with legal and regulatory requirements, the qualifications and independence of the Fund’s independent registered public accounting firm (the “independent auditor”), the performance of the internal audit function for the Fund, and the performance of the independent auditor.

Hartigan and Krugman and Ms.

Ringold.The overall purpose of the Audit Committee is to assist the Board of Managers with overseeing the Fund’s financial statements, the Fund's compliance with legal and regulatory requirements, the qualifications and independence of the Fund’s independent registered public accounting firm (the “independent auditor”), the performance of the internal audit function for the Fund, and the performance of the independent auditor.

The Managing Owner has designated Mr.

29 unchanged sentences

In this role, Mr.

Krugman was responsible for strategic and financial planning for Invesco Ltd.’s global investments organization including global real estate, private equity and global fixed income.

Krugman was responsible for strategic and financial planning for Invesco Ltd.’s global investments organization including

global real estate, private equity and global fixed income.

Prior to that, Mr.

Krugman was Invesco Ltd.’s Treasurer and Head of

Investor Relations from May 2011 to March 2017.

Krugman was Invesco Ltd.’s Treasurer and Head of Investor Relations from May 2011 to March 2017.

In this role, he was responsible for management of Invesco Ltd.’s liquidity and capital management programs.

39 unchanged sentences

Zimdars was listed as a principal of the Managing Owner on February 1, 2018.

John Zerr (61) has been a Member of the Board of Managers of the Managing Owner since September 2006.

Zerr has also served as Chief Operating Officer of the Americas for Invesco Ltd.

since February 2018.

Prior to his current position, Mr.

Zerr served as Managing Director and General Counsel – U.S.

Retail of Invesco Management Group, Inc., a registered investment adviser affiliated with the Managing Owner, from March 2006 until February 2018, where he was responsible for overseeing the U.S.

Retail Legal Department for Invesco Ltd.

and its affiliated companies.

Zerr has also been a Senior Vice President of IDI since March 2006.

He also served as a Director of that entity until February 2010.

Zerr has served as Senior Vice President of Invesco

Advisers, Inc., a registered investment adviser affiliated with the Managing Owner, since December 2009.

Zerr serves as a Director and Vice President of Invesco Investment Services, Inc., a registered transfer agency since May 2007.

Zerr has served as Director, Senior Vice President, General Counsel and Secretary of a number of other Invesco Ltd.

wholly owned subsidiaries which service or serviced portions of Invesco Ltd.’s U.S.

Retail business since May 2007 and since June 2010 with respect to certain Van Kampen entities engaged in the asset management business that were acquired by Invesco Ltd.

from Morgan Stanley.

In each of the foregoing positions Mr.

Zerr is responsible for overseeing legal operations.

In such capacity, Mr.

Zerr also is responsible for overseeing the legal activities of the Invesco Funds.

Zerr earned a BA degree in economics from Ursinus College.

He graduated cum laude with a J.D.

from Temple University School of Law.

Zerr was listed as a principal of the Managing Owner on December 6, 2012.

Melanie Ringold (48) has been a Member of the Board of Managers of the Sponsor since July 2024.

Ringold has also served as Head of Legal for the Americas at Invesco Ltd., a global investment management company and affiliate of the Sponsor,since January 2023.

In this role, she is responsible for overseeing legal support for all of Invesco’s Americas business.

Prior to her current position, Ms.

Ringold served as Assistant General Counsel from March 2011 until January 2023, where she was responsible for overseeing legal support for the investments organization and co-chairing the firm’s US Regulatory Change Committee.

Ms.58Ringold earned a JD from the University of Houston Law Center and a BA degree in political science from the University of Michigan.

Ringold was listed as a principal of the Sponsor on July 31, 2024.

David Hemming (43) joined the Managing Owner in September 2016 as a Senior Portfolio Manager and has been Head ofAlternatives Portfolio Management since November 2020, and a Vice President of the Managing Owner since November 2024.

In these roles, Mr.

Hemming manages a team of two other portfolio managers and is responsible for portfolio management processes forover 20 commodity and alternatives-based registered investment companies and other pooled investment vehicles managed by the Managing Owner.

He is a graduate of University of St.

Andrews (Scotland), with an MA (honours) in Economics and International relations, and City University Business School, with a MSc in Investment Management.

Hemming was listed as a principal of the Managing Owner on November 6, 2024, and he was registered as associated person and swap associated person the Managing Owneron April 19, 2017, and April 26, 2017, respectively.

Invesco Group Services Inc., which is a wholly owned, indirect subsidiary of Invesco Ltd., has been a principal of the Managing Owner since September 27, 2018 and has periodically been listed with NFA as a principal of other NFA members since May 17, 1990.

3 unchanged sentences

Central Time.

Insider Trading Policy

The Managing Owner has adopted an Insider Trading Policy, which applies to all of its employees and itself.

The Insider Trading Policy operates in concert with the Code of Ethics and Personal Trading Policy for North America (collectively, the “Trading Policies”).

The Managing Owner believes that the Trading Policies are reasonably designed to promote compliance with insider trading laws, rules and regulations with respect to the purchase, sale and/or other dispositions of securities, including Shares of the Fund, as well as the applicable rules and regulations of the Exchange.

A copy of the Insider Trading Policy is filed as Exhibit 19.1 to this Annual Report on Form 10-K.

EXECUTIVE COMPENSATION

13 unchanged sentences

Brokerage commissions of $5,001 were unpaid at December 31, 2022 and are reported as a liability on the Statements of Financial Condition.

SECURITY OWNERSHIP OF CERTAIN BENEFICI AL OWNERS AND MANAGEMENT AND RELATED STOCKHOLDER MATTERS [PENDING]

SECURITY OWNERSHIP OF CERTAIN BENEFICI AL OWNERS AND MANAGEMENT AND RELATED STOCKHOLDER MATTERS

The Fund has no officers or directors.

The following table sets forth certain information regarding beneficial ownership of the Fund’s General Shares and Shares as of January 31, 2025, as known by management.

No person is known by the Managing Owner to own beneficially more than 5% of outstanding Shares.

No person is known by the Managing Owner to own beneficially more than 5% of outstanding Shares of such class.

Title of Class

13 unchanged sentences

The following table sets forth the fees for professional services rendered by PricewaterhouseCoopers LLP, the Fund’s independent registered public accounting firm for the years ended December 31, 2024 and 2023.

Fiscal Years Ended December 31,

For the Years Ended

Audit-Related Fees (1)

All Other Fees

(1) Audit-Related Fees for the fiscal year ended December 31, 2024 include fees billed for reviewing regulatory filings.

(2) Tax Fees for the fiscal years ended December 31, 2024 and 2023 include fees billed for preparing tax forms.

21 unchanged sentences

Distribution Services Agreement 8

Insider Trading Policies and Procedures (filed herewith)

Consent of PricewaterhouseCoopers LLP (filed herewith)

26 unchanged sentences

Previously filed as an exhibit to Form 8-K on May 19, 2020 and incorporated herein by reference.

Previously filed as an exhibit to Form 10-K on February 23, 2024 and incorporated herein by reference.

Pursuant to the requirements 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.

15 unchanged sentences

February 25, 2025

/s/ J OHN Z ERR

/s/ MELANIE RINGOLD

Melanie Ringold

February 25, 2025

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