STATEMENT OF ADDITIONAL INFORMATIONCAMBRIA ETF TRUST
Cambria Shareholder Yield ETF (SYLD)
Cambria Foreign Shareholder Yield ETF (FYLD)
Cambria Emerging Shareholder Yield ETF (EYLD)
Cambria Global Tail Risk ETF (FAIL)
Cambria Global Value ETF (GVAL)
Cambria Global Momentum ETF (GMOM)
Cambria Value and Momentum ETF (VAMO)
Cambria Global Asset Allocation ETF (GAA)
Cambria Tail Risk ETF (TAIL)
Cambria Trinity ETF (TRTY)
Cambria Cannabis ETF (TOKE)
Cambria Global Real Estate ETF (BLDG)
Cambria Micro and SmallCap Shareholder Yield ETF (MYLD)
Cambria Tactical Yield ETF (TYLD)
Cambria LargeCap Shareholder Yield ETF (LYLD)
3300 Highland Avenue, Manhattan Beach, CA 90266
PHONE: (310) 683-5500
September 1, 2024
This Statement of Additional Information (the “SAI”) describes additional information related to certain series of the Cambria
ETF Trust. The Trust is an open-end registered management investment company under the Investment Company Act. ThisSAI relates to each of the Funds listed above.
Shares of each Fund are listed and traded on the CBOE BZX Exchange, Inc.
Each Fund is actively managed. Cambria Investment Management, L.P. serves as the investment adviser to the Funds, and Tidal
Investments, LLC serves as the sub-adviser to each Fund. ALPS Distributors, Inc. serves as the Distributor for each Fund.
This SAI is not a prospectus. It should be read in conjunction with the Funds’ Prospectus, dated September 1, 2024, and asrevised from time to time, which incorporates this SAI by reference.
Capitalized terms used herein that are not defined have the same meaning as in the Prospectus, unless otherwise noted. A
copy of the Prospectus may be obtained without charge by writing to the Distributor, calling 855-ETF-INFO (383-4636) orvisiting www.cambriafunds.com. An annual report for each Fund is available in the same manner at no charge by request to
the Fund(s) at the address, website, or phone number noted above. Each Fund’s audited financial statements for the most recent
fiscal year are incorporated in this SAI by reference to the Funds’ annual report to shareholders dated April 30, 2024.
THE U.S. SECURITIES AND EXCHANGE COMMISSION HAS NOT APPROVED OR DISAPPROVED
THESE SECURITIES OR PASSED UPON THE ADEQUACY OF THIS SAI. ANY REPRESENTATION TO THE
CONTRARY IS A CRIMINAL OFFENSE.

TABLE OF CONTENTS
Page
GLOSSARY �����������������������������������������������������������������������������������������������������������������������������������������������������������������

3

TRUST AND FUNDS OVERVIEW�����������������������������������������������������������������������������������������������������������������������������5

EXCHANGE LISTING AND TRADING�������������������������������������������������������������������������������������������������������������������5

DISCLOSURE OF PORTFOLIO HOLDINGS�����������������������������������������������������������������������������������������������������������

6

INVESTMENT POLICIES AND RESTRICTIONS���������������������������������������������������������������������������������������������������

6

INVESTMENT OBJECTIVES, INVESTMENT STRATEGIES AND RISKS�����������������������������������������������������������

8

PORTFOLIO TURNOVER������������������������������������������������������������������������������������������������������������������������������������������

39

MANAGEMENT OF THE FUNDS�����������������������������������������������������������������������������������������������������������������������������

40

CONTROL PERSONS AND PRINCIPAL HOLDERS OF SECURITIES�����������������������������������������������������������������

45

INVESTMENT MANAGEMENT AND OTHER SERVICES �����������������������������������������������������������������������������������

50

PORTFOLIO MANAGERS﻿�����������������������������������������������������������������������������������������������������������������������������������������

55

PORTFOLIO TRANSACTIONS AND BROKERAGE�����������������������������������������������������������������������������������������������

56

THE DISTRIBUTOR���������������������������������������������������������������������������������������������������������������������������������������������������

58

ACCOUNTING AND LEGAL SERVICE PROVIDERS���������������������������������������������������������������������������������������������

59

ADDITIONAL INFORMATION CONCERNING SHARES�������������������������������������������������������������������������������������

60

TRANSACTIONS IN CREATION UNITS�����������������������������������������������������������������������������������������������������������������

62

DETERMINATION OF NET ASSET VALUE �����������������������������������������������������������������������������������������������������������

70

TAXATION�������������������������������������������������������������������������������������������������������������������������������������������������������������������

71

FINANCIAL STATEMENTS���������������������������������������������������������������������������������������������������������������������������������������

79

APPENDIX A: PROXY VOTING POLICIES AND PROCEDURES FOR THE TRUST������������������������������������������

A-1

APPENDIX B: DESCRIPTION OF SECURITIES RATINGS�����������������������������������������������������������������������������������

B-1

No person has been authorized to give any information or to make any representations other than those contained in this SAI
and the Prospectus and, if given or made, such information or representations may not be relied upon as having been authorized
by the Trust. This SAI does not constitute an offer to sell securities.

2

GLOSSARY
The following terms are used throughout this SAI, and have the meanings used below:“1933 Act” means the Securities Act of 1933, as amended.
“1934 Act” means the Securities Exchange Act of 1934, as amended.
“Authorized Participant” means a broker-dealer or other participant in the Continuous Net Settlement System of the National
Securities Clearing Corporation (NSCC) or a participant in DTC with access to the DTC system, who has executed anagreement with the Distributor that governs transactions in the Funds’ Creation Units.
“Balancing Amount” means an amount equal to the difference between the NAV of a Creation Unit and the market value ofthe In-Kind Creation (or Redemption) Basket, used to ensure that the NAV of a Fund Deposit (or Redemption) (other than theTransaction Fee), is identical to the NAV of the Creation Unit being purchased.
“Board” means the Board of Trustees of the Trust.
“Business Day” means any day on which the Trust is open for business.
“Cambria” or the “Adviser” means Cambria Investment Management, L.P., the investment adviser to each Fund.
“Cash Component” means an amount of cash consisting of a Balancing Amount and a Transaction Fee calculated in connection
with creations.
“Cash Redemption Amount” means an amount of cash consisting of a Balancing Amount and a Transaction Fee calculated inconnection with redemptions.
“CEA” means the Commodity Exchange Act, as amended.
“CFTC” means the Commodity Futures Trading Commission.
“Code” means the Internal Revenue Code of 1986, as amended.
“Creation Unit” means an aggregation of Shares that each Fund issues and redeems on a continuous basis at NAV. Shares will
not be issued or redeemed except in Creation Units.
“Distribution Plan” means the Funds’ Distribution and Service Plan adopted pursuant to Rule 12b-1 under the Investment
Company Act.
“Distributor” means ALPS Distributors, Inc., the distributor to each Fund.
“Dodd-Frank Act” means the Dodd-Frank Wall Street Reform and Consumer Protection Act.
“DTC” means the Depository Trust Company.
“ETF” means exchange-traded fund.
“Exchange” means CBOE BZX Exchange, Inc.
“FINRA” means the Financial Industry Regulatory Authority.
“Funds” means the series of the Trust discussed in this SAI: Cambria Shareholder Yield ETF, Cambria Foreign Shareholder
Yield ETF, Cambria Emerging Shareholder Yield ETF, Cambria Global Tail Risk ETF, Cambria Global Value ETF, Cambria
Global Momentum ETF, Cambria Value and Momentum ETF, Cambria Global Asset Allocation ETF, Cambria Tail Risk ETF,
Cambria Trinity ETF, Cambria Cannabis ETF, Cambria Global Real Estate ETF, Cambria Micro and SmallCap Shareholder
Yield ETF, Cambria Tactical Yield ETF, and Cambria LargeCap Shareholder Yield ETF.

3

“Fund Deposit” means the In-Kind Creation Basket and Cash Component necessary to purchase a Creation Unit from a Fund.
“Fund Redemption” means the In-Kind Redemption Basket and Cash Redemption Amount received in connection with theredemption of a Creation Unit.
“In-Kind Creation Basket” means the basket of securities to be deposited to purchase Creation Units of a Fund.
“In-Kind Redemption Basket” means the basket of securities a shareholder will receive upon redemption of a Creation Unit.
“Investment Company Act” means the Investment Company Act of 1940, as amended.
“IRS” means the Internal Revenue Service.
“NAV” means the net asset value of a Share.
“NSCC” means the National Securities Clearing Corporation.
“NYSE” means the New York Stock Exchange, Inc.
“Prospectus” means the Funds’ Prospectus, dated September 1, 2024, as may be amended and supplemented from time to time.
“REIT” means a real estate investment trust.
“RIC” means a “regulated investment company” under Subchapter M of the Code.
“SAI” means this Statement of Additional Information, dated September 1, 2024, as may be amended and supplemented fromtime to time.
“SEC” means the United States Securities and Exchange Commission.
“Shares” means the shares of a Fund.
“Tidal” or the “Sub-Adviser” means Tidal Investments, LLC, the investment sub-adviser to each Fund.
“Transaction Fees” are fees imposed to compensate the Trust for costs incurred in connection with transactions for Creation
Units. The Transaction Fee is comprised of a flat (or standard) fee and may include a variable fee. For the Transaction Fees
applicable to each Fund, see “Transaction Fees” in this SAI.
“Trust” means the Cambria ETF Trust, a Delaware statutory trust.

4

TRUST AND FUNDS OVERVIEWThe Trust is a Delaware statutory trust formed on September 9, 2011 and an open-end registered management investmentcompany comprised of eighteen funds, fifteen of which have commenced operations and are discussed in this SAI. Each Fundis a diversified, actively-managed ETF. The offering of the Shares is registered under the 1933 Act. Cambria serves as theinvestment adviser to each Fund. Tidal Investments, LLC serves as the investment sub-adviser to each Fund.
Each Fund offers and issues Shares at NAV only in aggregations of a specified number of Shares, generally in exchange for abasket of securities, together with the deposit of a specified cash payment, or, in certain circumstances, for an all cash payment.
Shares of each Fund are listed and traded on the Exchange. Shares trade on the Exchange at market prices that may be below,
at, or above NAV.
Unlike mutual funds, Shares are not individually redeemable securities. Rather, each Fund issues and redeems Shares on acontinuous basis at NAV, only in Creation Units. In the event of the liquidation of a Fund, the Trust may lower the number of
Shares in a Creation Unit.
In the instance of creations and redemptions, Transaction Fees may be imposed. Such fees are limited in accordance withrequirements of the SEC applicable to management investment companies offering redeemable securities. Some of theinformation contained in this SAI and the Prospectus — such as information about purchasing and redeeming Shares froma Fund and Transaction Fees — is not relevant to most retail investors because it applies only to transactions for Creation
Units and most retail investors do not transact for Creation Units.
Once created, Shares generally trade in the secondary market, at market prices that change throughout the day, in amounts lessthan a Creation Unit. Investors purchasing Shares in the secondary market through a brokerage account or with the assistanceof a broker may be subject to brokerage commissions and charges.
Diversification
Each Fund is “diversified” within the meaning of the Investment Company Act. Under applicable federal laws, to qualify
as a diversified fund, a Fund, with respect to 75% of its total assets, may not invest greater than 5% of its total assets in any
one issuer and may not hold greater than 10% of the securities of one issuer, other than investments in cash and cash items(including receivables), U.S. government securities, and securities of other investment companies. The remaining 25% of
the Fund’s total assets does not need to be “diversified” and may be invested in securities of a single issuer, subject to otherapplicable laws. The diversification of the Fund’s holdings is measured at the time the Fund purchases a security. However, if
the Fund purchases a security and holds it for a period of time, the security may become a larger percentage of the Fund’s total
assets due to movements in the financial markets. If the market affects several securities held by a Fund, the Fund may have agreater percentage of its assets invested in securities of fewer issuers.
EXCHANGE LISTING AND TRADING
Shares of each Fund are listed and traded on the Exchange. Shares trade on the Exchange or in secondary markets at pricesthat may differ from their NAV, including because such prices may be affected by market forces (such as supply and demandfor Shares). As is the case of other securities traded on an exchange, when you buy or sell Shares on the Exchange or in thesecondary markets your broker will normally charge you a commission or other transaction charges. Further, the Trust reserves
the right to adjust the price of Shares in the future to maintain convenient trading ranges for investors (namely, to maintain aprice per Share that is attractive to investors) by share splits or reverse share splits, which would have no effect on the NAV.
There can be no assurance that a Fund will continue to meet the requirements of the Exchange necessary to maintain thelisting of Shares. The Exchange will consider the suspension of trading in, and will initiate delisting proceedings of, Shares
under any of the following circumstances: (i) if any of the requirements set forth in the Exchange rules are not continuously
maintained; (ii) if the Exchange files separate proposals under Section 19(b) of the Investment Company Act and any of thestatements regarding (a) the description of the Fund; (b) limitations on the Fund’s portfolio holdings or reference assets; or(c) the applicability of the Exchange listing rules specified in such proposals are not continuously maintained; (iii) if following
the initial 12-month period beginning at the commencement of trading of the Fund, there are fewer than 50 beneficial ownersof the Shares of such Fund; or (iv) such other event shall occur or condition shall exist that, in the opinion of the Exchange,
makes further dealings on such Exchange inadvisable. The Exchange will remove the Shares of a Fund from listing and trading
upon termination of a Fund.

5

The Funds are not sponsored, endorsed, sold or promoted by the Exchange. The Exchange makes no representation or warranty,
express or implied, to the owners of Shares of the Funds or any member of the public regarding the advisability of investingin securities generally or in the Funds particularly or the ability of the Funds to achieve their objectives. The Exchange has no
obligation or liability in connection with the administration, marketing or trading of the Funds.
DISCLOSURE OF PORTFOLIO HOLDINGSThe Board has adopted a policy regarding the disclosure of information about the Funds’ portfolio securities. Under the policy,
portfolio holdings of the Funds, which form the basis for the calculation of NAV on a Business Day, are publicly disseminatedprior to the opening of trading on the Exchange that Business Day through financial reporting or news services, including
the website www.cambriafunds.com. In addition, each Business Day a portfolio composition file, which displays the In-Kind
Creation Basket and Cash Component, is publicly disseminated prior to the opening of the Exchange via the NSCC.
INVESTMENT POLICIES AND RESTRICTIONSIn addition to the investment objectives and policies set forth in the Prospectus, each Fund is subject to the investment
restrictions set forth below. The investment policies enumerated in this section may be changed with respect to a Fund only by
a vote of the holders of a majority of a Fund’s outstanding voting securities. For the purposes of the Investment Company Act,a “majority of outstanding shares” means the vote of the lesser of: (i) 67% or more of the voting securities of the Fund present
at the meeting if the holders of more than 50% of the Fund’s outstanding voting securities are present or represented by proxy;or (ii) more than 50% of the outstanding voting securities of the Fund.
1.

The Funds may not borrow money, except to the extent permitted by the Investment Company Act, the rules andregulations thereunder and any applicable exemptive relief.

2.

The Funds may not issue senior securities, except to the extent permitted by the Investment Company Act, the rules
and regulations thereunder and any applicable exemptive relief.

3.

The Funds may not engage in the business of underwriting securities except to the extent that the Funds may beconsidered an underwriter within the meaning of the 1933 Act in the acquisition, disposition or resale of its portfolio
securities or in connection with investments in other investment companies, or to the extent otherwise permitted
under the Investment Company Act, the rules and regulations thereunder and any applicable exemptive relief.

4.

The Funds may not purchase or sell real estate, except to the extent permitted under the Investment Company Act, therules and regulations thereunder and any applicable exemptive relief.

5.

The Funds may not purchase or sell commodities, contracts relating to commodities or options on contracts relating tocommodities except to the extent permitted under the Investment Company Act, the rules and regulations thereunder
and any applicable exemptive relief. This policy shall not prevent the Funds from purchasing or selling foreign
currency or purchasing, selling or entering into futures contracts, options, forward contracts, swaps, caps, floors,collars and other financial instruments as currently exist or may in the future be developed.

6.

The Funds may not make loans, except to the extent permitted under the Investment Company Act, the rules andregulations thereunder and any applicable exemptive relief.

7.

No Fund, except for the Cambria Cannabis ETF and Cambria Global Real Estate ETF, will concentrate its investments
in issuers of one or more particular industries, except that each of the Cambria Foreign Shareholder Yield ETF,
Cambria Emerging Shareholder Yield ETF, and Cambria Global Value ETF will invest more than 25% of its total
assets in securities of the same industry to approximately the same extent that each such Fund’s underlying index
concentrates in the securities of a particular industry or group of industries. To the extent that the underlying index of
the Cambria Global Value ETF is not concentrated in the securities of a particular industry or group of industries, theCambria Global Value ETF will not concentrate its investments in issuers of one or more industries.

8.

The Cambria Cannabis ETF will concentrate (invest more than 25% of its total assets) in securities of the cannabis
industry.

9.

The Cambria Global Real Estate ETF will concentrate (invest more than 25% of its total assets) in securities of realestate-related industries.
6In addition to the foregoing fundamental investment policies, the Funds are also subject to the following non-fundamental
investment policies, which may be changed by the Board without a shareholder vote upon at least 60 days’ prior written notice
to shareholders:1.

A Fund may not hold illiquid assets in excess of 15% of its net assets. For this purpose, “illiquid securities” aresecurities that the Fund may not sell or dispose of within seven days in the ordinary course of business at approximately
the amount at which the Fund has valued the securities. A repurchase agreement maturing in more than seven days is
considered illiquid, unless it can be terminated after a notice period of seven days or less.

2.

Under normal market conditions, the Cambria Cannabis ETF invests at least 80% of the value of the Fund’s net assets(plus borrowings for investment purposes) in Cannabis Companies (as defined the Prospectus).

3.

Under normal market conditions, the Cambria Global Real Estate ETF will invest at least 80% of the value of theFund’s net assets (plus borrowings for investment purposes) in the securities of real estate companies.

4.

Under normal market conditions, the Cambria Micro and SmallCap Shareholder Yield ETF invests at least 80%
of its net assets, plus borrowings for investment purposes, in equity securities, including common stock, issued by
U.S.-based micro and small capitalization publicly listed companies that provide high “shareholder yield.”

5.

Under normal market conditions, the Cambria Tactical Yield ETF invests at least 80% of its net assets, plus borrowings
for investment purposes, in fixed income securities, including individual bonds as well as exchange traded products
and ETFs that invest primarily in bonds.

6.

Under normal market conditions, the Cambria LargeCap Shareholder Yield ETF will invest at least 80% of its net
assets, plus borrowings for investment purposes, in equity securities, including common stock, issued by U.S.-basedlarge capitalization publicly listed companies that provide high “shareholder yield.”With respect to the fundamental policy relating to borrowing money set forth in (1) above, the Investment Company Act
permits a Fund to borrow money in amounts of up to one-third of the Fund’s total assets, at the time of borrowing, from banks
for any purpose (the Fund’s total assets include the amounts being borrowed). To limit the risks attendant to borrowing, theInvestment Company Act requires the Fund to maintain at all times an “asset coverage” of at least 300% of the amount of its
borrowings (not including borrowings for temporary purposes in an amount not exceeding 5% of the value of the Fund’s total
assets). Asset coverage means the ratio that the value of the Fund’s total assets (including amounts borrowed), minus liabilities
other than borrowings, bears to the aggregate amount of all borrowings. In the event that such asset coverage falls below thispercentage, the Fund is required to reduce the amount of its borrowings within three days (not including Sundays and holidays)
so that the asset coverage is restored to at least 300%.
With respect to the fundamental policy relating to issuing senior securities set forth in (2) above, “senior securities” are defined
as fund obligations that have a priority over the Fund’s shares with respect to the payment of dividends or the distribution ofFund assets. The Investment Company Act prohibits a Fund from issuing any class of senior securities or selling any seniorsecurities of which it is the issuer, except that the Fund is permitted to borrow from banks, as described immediately above.
With respect to the fundamental policy relating to making loans set forth in (6) above, the Investment Company Act does
not prohibit a Fund from making loans; however, SEC staff interpretations currently prohibit funds from lending more than
one-third of their total assets, except through the purchase of debt obligations. (A repurchase agreement is an agreement topurchase a security, coupled with an agreement to sell that security back to the original seller on an agreed-upon date at a pricethat reflects current interest rates. The SEC staff treats repurchase agreements as loans). Certain types of derivatives give rise
to future payment obligations and therefore, also may be considered to be senior securities. Rule 18f-4 under the 1940 Act
permits funds that comply with the conditions therein to enter into certain types of derivatives transactions notwithstanding theprohibitions and restrictions on the issuance of senior securities under the 1940 Act.
Except with respect to borrowing and illiquid securities, if a percentage limitation is satisfied at the time of investment, alater increase or decrease in such percentage resulting from a change in the value of a Fund’s investments will not constitute a
violation of such limitation. Thus, a Fund may continue to hold a security even though it causes the Fund to exceed a percentage
limitation because of fluctuation in the value of the Fund’s assets, except that any borrowing by a Fund or investment in illiquid
securities that exceeds the fundamental investment limitations stated above must be reduced to meet such limitations within the
period required by the Investment Company Act or the relevant rules, regulations or interpretations thereunder.

7

For purposes of applying the limitations set forth in the concentration policies, the Funds, with respect to their equity
holdings, will generally use the industry classifications provided by the Global Industry Classification Standards (GICS®), awidely recognized industry classification methodology developed by MSCI, Inc. and Standard & Poor’s Financial Services
LLC. With respect to the Cambria Global Real Estate ETF, securities of “real estate-related industries” means securities
classified in one of these two industries of the real estate sector, as determined by GICS: (1) equity REITs and (2) realestate management and development. Also, with respect to the limitations set forth in the Funds’ concentration policies,
securities of the U.S. government (including its agencies and instrumentalities) and, except as set forth in the following
sentence, tax-free securities of state or municipal governments and their political subdivisions (and repurchase agreements
collateralized by government securities) are not considered to be issued by members of any industry. To the extent that theincome from a municipal bond is derived principally from a specific project or backed principally from the assets and revenueof a non-governmental user, the securities will be deemed to be from the industry of that project or user. In addition, as ofJune 29, 2020, each Fund is actively managed, and no Fund tracks an underlying index. Accordingly, the Cambria Foreign
Shareholder Yield ETF, Cambria Emerging Shareholder Yield ETF, and Cambria Global Value ETF will not concentrate theirinvestments in issuers of one or more particular industries to approximately the same extent as an underlying index.
With respect to the Cambria Global Real Estate ETF’s non-fundamental policy to invest in the securities of real estatecompanies, real estate companies are defined as (i) exchange-listed REITs and (ii) companies included in the real estate sector
according to GICS.
INVESTMENT OBJECTIVES, INVESTMENT STRATEGIES AND RISKS
Each Fund’s investment objective, principal investment strategies and associated risks are described in the Fund’s Prospectus.
The following chart, which supplements and should be read together with the information in the Prospectus, describe thespecific investments and technique applicable to the Cambria Shareholder Yield ETF (SYLD), Cambria Foreign Shareholder
Yield ETF (FYLD), Cambria Emerging Shareholder Yield ETF (EYLD), Cambria Global Tail Risk ETF (FAIL), Cambria
Global Value ETF (GVAL), Cambria Global Momentum ETF (GMOM), Cambria Global Value and Momentum ETF(VAMO), Cambria Global Asset Allocation ETF (GAA), Cambria Tail Risk ETF (TAIL), Cambria Trinity ETF (TRTY),
Cambria Cannabis ETF (TOKE), Cambria Global Real Estate ETF (BLDG), Cambria Micro and SmallCap Shareholder
Yield ETF (MYLD), Cambria Tactical Yield ETF (TYLD), and Cambria LargeCap Shareholder Yield ETF (LYLD). Unlessotherwise indicated in the Prospectus or this SAI, the investment objective and policies of each Fund may be changed without
shareholder approval.
Recent Events. Local, regional, or global events such as war, acts of terrorism, the spread of infectious illness or other publichealth issues, recessions, or other events could have a significant impact on the market generally and on specific securities.
Periods of market volatility may occur in response to such events and other economic, political, and global macro factors. The
COVID-19 pandemic, Russia’s invasion of Ukraine, and higher inflation have resulted in extreme volatility in the financial
markets, economic downturns around the world, severe losses to some sectors of the economy and individual issuers, andreduced liquidity of certain instruments. These events have caused significant disruptions to business operations, including
business closures; strained healthcare systems; disruptions to supply chains and employee availability; large fluctuations in
consumer demand; large expansion of government deficits and debt as a result of government actions to mitigate the effects ofsuch events; and widespread uncertainty regarding the long-term effects of such events.

8

SYLD FYLD EYLD FAIL GVAL GMOM VAMO GAA TAIL TRTY TOKE BLDG MYLD TYLD LYLD
Cannabis-Related
Securities
Cash Items
Central Clearing
Credit Quality Standards
Cryptocurrency
Investments
Debt-Related Investments
Asset-Backed Securities
Corporate Debt
Securities
Debt and Other Fixed
Income Securities
Generally
Exchange-Traded Notes
High Yield Securities
Mortgage-Related andOther Asset-Backed
Securities
Municipal Securities
U.S. Government
Securities
Zero Coupon Securities
Derivatives
CFTC Regulation
Futures Contracts andRelated Options
Options Contracts
Swap Agreements
Dollar Rolls, Delayed
Delivery Transactionsand When Issued or
Forward Commitment
Securities
Equity-Related Investments
Common Stocks
Convertible Securities
Master Limited
Partnerships
Investments in Other
Investment Companies
or Other Pooled
Investments
Preferred Stocks
Real Estate Investment
TrustsRights and Warrants
Foreign Investments
Generally
Asia-Pacific Risk
Australia Risk

X

X

X
X
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X

X

X

X
X
X
X

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X

X

X

X

X

X

X

X

X
X

X

X

X

X

X

X

X
X

X

X
X

X

X
X
X

X
X

X
X
X

X

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X

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X

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X

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X

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X

X
X
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X

X
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X
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X

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9

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Canada Risk
Depositary Receipts
Emerging Markets Risk
Europe Risk
Foreign Currency
Transactions
Foreign Government
Securities
India Risk
Latin America Risk
Middle East Risk
Russia Risk
South Africa Risk
Turkey Risk
Illiquid Securities
Repurchase Agreements
Reverse Repurchase
Agreements
Securities Lending
Short SalesSYLD FYLD EYLD FAIL GVAL GMOM VAMO GAA TAIL TRTY TOKE BLDG MYLD TYLD LYLD
X
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Cannabis-Related Securities
The Fund seeks to achieve its investment objective by investing, under normal market conditions, primarily in (1) Cannabis
Companies, and (2) total return swaps intended to provide exposure to Cannabis Companies. Cannabis Companies arecompanies that (i) engage in or support the legal production, cultivation, and/or sale of cannabis, including marijuana andhemp, such as certain agrobusiness, biotechnology, life sciences, pharmaceutical, retail, finance, and real estate companies,(ii) perform lawful research as to the medical and pharmaceutical applications of marijuana and cannabis extracts, including
cannabinoids, or (iii) produce and develop devices, goods, and equipment related to the cannabis industry, including hemp andits legal derivatives. To be identified as a Cannabis Company, Cambria must determine that a company derives a significant
portion (i.e., at least 50%) of its revenue or profits from the legal sale, cultivation, production, or provision of cannabis-related
products, services, or research. The Fund will only invest in publicly-traded Cannabis Companies that operate in a jurisdiction
where the Cannabis Companies’ cannabis-related business activities are legal under the national and local laws of the relevant
jurisdiction, including U.S. federal and state laws. Further, the Fund will only invest in Cannabis Companies listed and tradedon a national securities exchange that requires compliance with all laws, rules and regulations applicable to their business,
including U.S. federal laws. Accordingly, the Fund does not currently (directly or indirectly) invest in Cannabis Companies
located in the U.S. if their cannabis-related business activities are illegal under U.S. federal law, even if such activities are legal
under state law. If U.S. federal law changes in the future and these cannabis-related business activities become legal at thefederal level, the Fund will begin investing in these U.S.-listed Cannabis Companies in accordance with the Fund’s investment
objective and principal investment strategy.
As of the date of this SAI, the securities of Cannabis Companies held by the Fund will be purchased on regulated, major stock
exchanges, such as the New York Stock Exchange, NYSE American, Nasdaq Stock Market, TSX Exchange, and TSX Venture
Exchange. Cannabis Companies do not include those companies whose securities trade on the Canadian Stock Exchange.
The Fund does not invest in any Cannabis Company that grows, produces, distributes, or sells cannabis or products derived
from cannabis in a country, state, province, locality or other political subdivision where this activity is illegal under applicablelaw. Cannabis Companies do not include companies that grow, produce, distribute, or sell cannabis or products derived fromcannabis inside the U.S. This is the case regardless of whether such a company is listed on a U.S. exchange or an exchange in acountry where cannabis is legal. Cannabis Companies do not include companies that grow, produce, distribute, or sell cannabisor products derived from cannabis both in a country where its activities are entirely legal and in the U.S. where its activities are10

legal under state and local law but not under U.S. federal law. Further, the Fund itself does not and is not seeking to distribute
cannabis in the U.S.
Cannabis Companies only supply products and/or perform activities that are legal under applicable national and local laws,
including U.S. federal, state, and local laws. Cannabis Companies may, however, supply such products and perform suchactivities in the U.S. to companies that grow, produce, distribute, or sell cannabis or products derived from cannabis in a mannerthat is legal under state and local law but not under U.S. federal law. Cannabis Companies with a presence in the U.S. may
engage in pharmaceutical activities and/or grow, produce, distribute, or sell hemp or products derived from hemp but only ifsuch activities are properly licensed and legal under applicable U.S. federal, state, and local laws and otherwise in conformity
with the Farm Bill of 2018. If, after acquiring a Cannabis Company’s securities, the Advisor identifies or becomes aware thatthe company no longer meets the Fund’s definition of Cannabis Companies, the Fund will promptly sell that position.
Cash Items
The Fund may invest a portion of its assets in cash or cash items pending other investments or to maintain liquid assets requiredin connection with some of the Fund’s investments. These cash items and other high quality debt securities may include money
market instruments, such as securities issued by the U.S. Government and its agencies, bankers’ acceptances, commercial
paper, bank certificates of deposit and investment companies that invest primarily in such instruments.
Credit Quality Standards
All Funds, Except Cambria Global Tail Risk ETF. When investing in fixed income securities and, if applicable, preferred orconvertible stocks, the Fund maintains the following credit quality standards, which apply at the time of investment:
For securities that carry a rating assigned by a nationally recognized statistical rating organization (a “Rating
Organization”), Cambria will use the highest rating assigned by the Rating Organization to determine a security’s
credit rating. Commercial paper must be rated at least “A-1” or equivalent by a Rating Organization. Corporate debt
obligations, mortgage-backed and other asset-backed securities and municipal securities must be rated at least “B-”or equivalent by a Rating Organization. For securities that are not rated by a Rating Organization, Cambria’s internal
credit rating will apply and be subject to the equivalent rating minimums described here. The Funds may retain a debt
security that has been downgraded below the initial investment criteria.
Cambria Global Tail Risk ETF. The Fund is not subject to minimum credit rating standards and may invest in securities of any
rating and unrated securities.
Cryptocurrency Investments
Cryptocurrencies (also referred to as “virtual currencies” and “digital currencies”) are digital assets designed to act as a
medium of exchange. Although cryptocurrency is an emerging asset class, there are thousands of cryptocurrencies, the mostwell-known of which is bitcoin. The Fund may seek investment exposure to bitcoin indirectly through investing up to 5%of its net assets in Grayscale Bitcoin Trust (“GBTC”), a privately offered investment vehicle that invests in bitcoin. GBTC
is not registered as an investment company under the Investment Company Act or regulated as a commodity pool under the
CEA. Consequently, shareholders of GBTC do not have the regulatory protections afforded to investors under either regulatory
scheme. Except for its investment in GBTC, the Fund will not invest, directly or indirectly, in cryptocurrencies.
In addition to the general risks of investing in other investment vehicles, the value of the Fund’s indirect investments incryptocurrency is subject to fluctuations in the value of the cryptocurrency, which can be highly volatile. The value ofcryptocurrencies is determined by the supply and demand for cryptocurrency in the global market for the trading of
cryptocurrency, which consists primarily of transactions on electronic exchanges. The price of bitcoin could drop precipitously(including to zero) for a variety of reasons including but not limited to regulatory changes, a crisis of confidence in the bitcoin
network or a change in user preference to competing cryptocurrencies. The Fund’s exposure to cryptocurrency can result in
substantial losses to the Fund.
Cryptocurrency facilitates decentralized, peer-to-peer financial exchange and value storage that is used like money, without
the oversight of a central authority or banks. The value of cryptocurrency is not backed by any government, corporation, orother identified body. Federal, state and/or foreign governments may restrict the use and exchange of cryptocurrency, andregulation in the U.S. is still developing. Ongoing and future regulatory actions may alter, perhaps to a materially adverse

11

extent, the nature of an investment in cryptocurrency. A determination that cryptocurrency or any other digital asset is a“security” may adversely affect the value of cryptocurrency. Similar to fiat currencies (i.e., a currency that is backed by acentral bank or a national, supra-national or quasi-national organization), cryptocurrencies are susceptible to theft, loss anddestruction. Accordingly, the bitcoin held by GBTC (and the Fund’s indirect exposure to such holdings) is also susceptible
to these risks.
Cryptocurrencies trade on exchanges, which are largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives and other currencies. These exchanges can cease operating
temporarily or even permanently, resulting in the potential loss of users’ cryptocurrency or other market disruptions.
Cryptocurrency exchanges may be more exposed to the risk of market manipulation than exchanges for more traditional assets.
Cryptocurrency exchanges that are regulated typically must comply with minimum net worth, cybersecurity, and anti-money
laundering requirements, but are not typically required to protect customers or their markets to the same extent that regulated
securities exchanges or futures exchanges are required to do so. Furthermore, many cryptocurrency exchanges lack certain
safeguards established by more traditional exchanges to enhance the stability of trading on the exchange, such as measuresdesigned to prevent sudden drops in value of items traded on the exchange (i.e., “flash crashes”). As a result, the prices
of cryptocurrencies on exchanges may be subject to larger and more frequent sudden declines than assets traded on more
traditional exchanges.
Shares of GBTC have historically traded, and may continue to trade, at a significant premium or discount to net asset value. If
GBTC were to cease to trade at a premium to its NAV, the value of the Fund’s investment in GBTC could decrease, even if thevalue of GBTC’s underlying holdings in bitcoin does not decrease. In addition, the Fund’s investment in GBTC will be subject
to the operating expenses associated with GBTC. If GBTC incurs expenses in U.S. dollars, GBTC would be required to sell
bitcoins to pay these expenses. The sale of GBTC’s bitcoins to pay expenses in U.S. dollars at a time of low bitcoin prices could
adversely affect the value of an investment in the Fund.
Factors affecting the further development of cryptocurrency include, but are not limited to, continued worldwide growthor possible cessation or reversal in the adoption and use of cryptocurrency and other digital assets; government andquasi-government regulation or restrictions on or regulation of access to and operation of digital asset networks; changes in
consumer demographics and public preferences; maintenance and development of open-source software protocol; availability
and popularity of other forms or methods of buying and selling goods and services; the use of the networks supporting
digital assets, such as those for developing smart contracts and distributed applications; general economic conditions and theregulatory environment relating to digital assets; negative consumer or public perception; and general risks tied to the use of
information technologies, including cyber risks. A hack or failure of one cryptocurrency may lead to a loss in confidence in,and thus decreased usage or and or value of, other cryptocurrencies.
Currently, there is relatively limited use of cryptocurrency in the retail and commercial marketplace, which contributes toprice volatility. A lack of expansion by cryptocurrencies into retail and commercial markets, or a contraction of such use, may
result in increased volatility or a reduction in the value of cryptocurrencies, either of which could adversely impact the Fund’sinvestment. In addition, to the extent market participants develop a preference for one cryptocurrency over another, the valueof the less preferred cryptocurrency would likely be adversely affected.
The Fund’s exposure to cryptocurrency may change over time and, accordingly, such exposure may not be represented
in the Fund’s portfolio at any given time. Many significant aspects of the tax treatment of investments in cryptocurrency
are uncertain, and an investment in bitcoin may produce income that if directly earned by a RIC would not be treated as
qualifying income for purposes of the applicable qualifying income requirement necessary for the Fund to qualify as a RIC
under Subchapter M of the Code. The Fund may invest directly in GBTC, which is expected to be treated as a grantor trust
for U.S. federal income tax purposes, and therefore an investment by the Fund in GBTC will generally be treated as a direct
investment by the Fund in bitcoin for such purposes. To the extent the Fund invests in GBTC, it intends to seek to restrict
its income from such investments to a maximum of 10% of its gross income (when combined with its other investmentsthat produce non-qualifying income) to comply with the qualifying income requirement necessary for the Fund to qualify
as a RIC under Subchapter M of the Code. However, the Fund may generate more non-qualifying income than anticipated,
may not be able to generate qualifying income in a particular taxable year at levels sufficient to meet the qualifying income
requirement, or may not be able to accurately predict the non-qualifying income from these investments. Accordingly, theextent to which the Fund invests in GBTC directly may be limited by the qualifying income requirement, which the Fundmust continue to satisfy to maintain its status as a RIC. Failure to comply with the qualifying income requirement would
have significant negative tax consequences to Fund shareholders.

12In 2014, the IRS released Notice 2014-21 (the “Notice”) discussing certain aspects of “convertible” virtual currency (thatis, digital assets that have an equivalent value in fiat currency or that act as a substitute for fiat currency) for U.S. federal
income tax purposes and, in particular, stating that such a digital asset (i) is “property,” (ii) is not “currency” for purposes of
the rules relating to foreign currency gain or loss and (iii) may be held as a capital asset. In 2019, the IRS released a Revenue
Ruling 2019-24 and a set of “Frequently Asked Questions” (the “Ruling & FAQs”) that provide some additional guidance. The
IRS and Treasury department have also recently released final regulations addressing information reporting of digital assets(the “Final Regulations”). The Final Regulations also provide guidance with respect to the calculation of gain or loss and thebasis of digital assets under section 1001 and 1012 of the Code. The Final Regulations with respect to the computation of gainor loss are proposed to apply to taxable years for all sales and acquisitions of digital assets on or after January 1, 2026.
The Final Regulations, the Notice, and the Ruling & FAQs do not address other significant aspects of the U.S. federal income
tax treatment of digital assets. Other tax issues include the income and withholding taxation of incidental rights received
through a fork in the blockchain, airdrops offered to bitcoin holders and other similar events, including situations where suchrights are disclaimed, as is expected with respect to GBTC’s intended treatment of such events. There is limited guidance fromthe IRS with respect to the treatment of bitcoin for tax purposes. In any event, there can be no assurance that the IRS will
not alter its positions or otherwise provide further guidance, potentially retroactive in effect, with respect to digital assets inthe future or that a court would uphold the treatment set forth in the Final Regulations, the Notice and the Ruling & FAQs orin other guidance. For these reasons, the Fund’s investment in GBTC could result in unexpected and potentially retroactive
recognition of taxable income, which could increase distributions to shareholders and subject to the Fund to excise tax andincome tax liability and potential loss in value, with effects that would be directly or indirectly negative or contrary to theFund’s tax position and investment strategy, and result in the Fund altering its investment strategy, potentially resulting insubstantial investment losses for shareholders. It is also unclear what additional guidance on the treatment of digital assets for
U.S. federal income tax purposes may be issued in the future. Any such alteration of the current IRS positions or additional
guidance could have an adverse effect on the value of bitcoin.
Cryptocurrency is a new technological innovation with a limited history; it is a highly speculative asset and future regulatory
actions or policies may limit, perhaps to a materially adverse extent, the value of the Fund’s indirect investment in cryptocurrency
and the ability to exchange a cryptocurrency or utilize it for payments.
Debt-Related Investments
Asset-Backed Securities
Asset-backed securities (“ABS”) are bonds backed by pools of loans or other receivables. ABS are created from many typesof assets, including auto loans, credit card receivables, home equity loans, and student loans. ABS are issued through special
purpose vehicles that are bankruptcy remote from the issuer of the collateral. The credit quality of an ABS transaction depends
on the performance of the underlying assets. To protect ABS investors from the possibility that some borrowers could misspayments or even default on their loans, ABS include various forms of credit enhancement.
Some ABS, particularly home equity loan transactions, are subject to interest-rate risk and prepayment risk. A change ininterest rates can affect the pace of payments on the underlying loans, which in turn affects total return on the securities.
ABS also carry credit or default risk. If many borrowers on the underlying loans default, losses could exceed the credit
enhancement level and result in losses to investors in an ABS transaction. Finally, ABS have structure risk due to a uniquecharacteristic known as early amortization, or early payout, risk. Built into the structure of most ABS are triggers for early
payout, designed to protect investors from losses. These triggers are unique to each transaction and can include: a big rise indefaults on the underlying loans, a sharp drop in the credit enhancement level, or even the bankruptcy of the originator. Once
early amortization begins, all incoming loan payments are used to pay investors as quickly as possible.
Consistent with the Fund’s investment objectives and policies, Cambria also may invest in other types of ABS.
Corporate Debt Securities
The rate of interest on a corporate debt security may be fixed, floating or variable, and may vary inversely with respect toa reference rate. Except for the Cambria Emerging Shareholder Yield ETF and Cambria Value and Momentum ETF, debt
securities may be acquired with warrants attached. The Fund may invest in commercial interests, including commercial paper,
master notes and other short-term corporate instruments that are denominated in U.S. dollars. Commercial paper consistsof short-term promissory notes issued by corporations. Commercial paper may be traded in the secondary market after its
issuance. Master notes are demand notes that permit the investment of fluctuating amounts of money at varying rates of13interest pursuant to arrangements with issuers who meet the quality criteria of the Fund. The interest rate on a master note may
fluctuate based upon changes in specified interest rates, be reset periodically according to a prescribed formula or be a set rate.
Although there is no secondary market in master demand notes, if such notes have a demand future, the payee may demand
payment of the principal amount of the note upon relatively short notice. Master notes are generally illiquid and therefore
subject to the Fund’s percentage limitations for investments in illiquid securities. See Appendix B to this SAI for a descriptionof corporate bond credit ratings.
Debt and Other Fixed Income Securities Generally
Debt securities include securities issued or guaranteed by the U.S. Government, its agencies, instrumentalities, and politicalsubdivisions, foreign governments, their authorities, agencies, instrumentalities, and political subdivisions, supra-national
agencies, corporate debt securities, master-demand notes, Yankee dollar and Eurodollar bank certificates of deposit, time
deposits, bankers’ acceptances, commercial paper and other notes, inflation-indexed securities, and other debt securities. Debt
securities may be investment grade securities or high yield securities, which are described below. Investment grade securities
include securities issued or guaranteed by the U.S. Government, its agencies and instrumentalities, as well as securities rated
in one of the four highest rating categories by at least two Rating Organizations rating that security, such as Standard & Poor’s
Ratings Services (“Standard & Poor’s”), Moody’s Investors Service, Inc. (“Moody’s”) or Fitch Ratings Ltd. (“Fitch”), or rated
in one of the four highest rating categories by one Rating Organization if it is the only Rating Organization rating that security
or unrated, if deemed to be of comparable quality by Cambria and traded publicly on the world market. The Fund, at thediscretion of Cambria, may retain a debt security that has been downgraded below the initial investment criteria.
Debt and other fixed income securities include fixed and floating rate securities of any maturity. Fixed rate securities pay
a specified rate of interest or dividends. Floating rate securities pay a rate that is adjusted periodically by reference to a
specified index or market rate. Fixed and floating rate securities include securities issued by federal, state, local, and foreign
governments and related agencies, and by a wide range of private issuers, and generally are referred to in this SAI as “fixedincome securities.” Indexed bonds are a type of fixed income security whose principal value and/or interest rate is adjusted
periodically according to a specified instrument, index, or other statistic (e.g., another security, inflation index, currency, orcommodity).
Holders of fixed income securities are exposed to both market and credit risk. Market risk (or “interest rate risk”) relates
to changes in a security’s value as a result of changes in interest rates. In general, the values of fixed income securities
increase when interest rates fall and decrease when interest rates rise. Given the historically low interest rate environment,risks associated with rising rates are heightened. Credit risk relates to the ability of an issuer to make payments of principal
and interest. Obligations of issuers are subject to bankruptcy, insolvency and other laws that affect the rights and remedies ofcreditors.
Because interest rates vary, the future income of the Fund that invests in fixed income securities cannot be predicted withcertainty. The future income of the Fund that invests in indexed securities also will be affected by changes in those securities’
indices over time (e.g., changes in inflation rates, currency rates, or commodity prices).
Exchange-Traded Notes
The Fund may invest in exchange-traded notes (“ETNs”). ETNs are debt obligations of investment banks which are tradedon exchanges and the returns of which are linked to the performance of market indexes. The market price for an ETN may behigher or lower than, respectively, the ETN’s NAV. Investing in ETNs exposes the Fund to all the risks of that investment and,in general, subjects it to a pro rata portion of the ETN’s fees and expenses. In addition to trading ETNs on exchanges, investors
typically may redeem ETNs directly with the issuer on a periodic basis, typically in a minimum amount of 50,000 units, orhold the ETNs until maturity. ETNs may be riskier than ordinary debt securities and may have no principal protection. The
Fund’s investment in an ETN may be influenced by many unpredictable factors, including highly volatile commodities prices,changes in supply and demand relationships, weather, agriculture, trade, changes in interest rates, and monetary and othergovernmental policies, action and inaction. Investing in ETNs is not equivalent to investing directly in index components or
the relevant index itself. Because ETNs are debt securities, they possess credit risk; if the issuer has financial difficulties orgoes bankrupt, the investor may not receive the return it was promised.
High Yield Securities
Securities rated lower than Baa by Moody’s, or equivalently rated by S&P or Fitch, are sometimes referred to as “highyield securities” or “junk bonds.” Investing in these securities involves special risks in addition to the risks associated withinvestments in higher-rated fixed income securities. While offering a greater potential opportunity for capital appreciation and14higher yields, high yield securities typically entail greater potential price volatility and may be less liquid than higher-rated
securities. The Fund may have difficulty selling certain junk bonds because they may have a thin trading market. The lack ofa liquid secondary market may have an adverse effect on the market price and the Fund’s ability to dispose of particular issues
and may also make it more difficult for the Fund to obtain accurate market quotations in valuing these assets. High yieldsecurities are inherently speculative with respect to the issuer’s continuing ability to meet principal and interest payments. They
may also be more susceptible to real or perceived adverse economic and competitive industry conditions than higher-rated
securities. Issuers of securities in default may fail to resume principal or interest payments, in which case the Fund may lose
its entire investment.
Companies that issue high yield bonds are often highly leveraged and may not have more traditional methods of financing
available to them. During an economic downturn or recession, highly leveraged issuers of high-yield securities may experiencefinancial stress, and may not have sufficient revenues to meet their interest payment obligations. Economic downturns tend to
disrupt the market for high yield bonds, lowering their values and increasing their price volatility. The risk of issuer default ishigher with respect to high yield bonds because such issues may be subordinated to other creditors of the issuer.
The credit rating of a high yield bond does not necessarily address its market value risk, and, from time to time, ratings maychange to reflect developments regarding the issuer’s financial condition. Generally, the lower the rating of a high yield bond,the more speculative its characteristics.
Mortgage-Related and Other Asset-Backed Securities
Mortgage-related securities include mortgage pass-through securities, collateralized mortgage obligations (“CMOs”),
commercial mortgage-backed securities, mortgage dollar rolls, CMO residuals, stripped mortgage-backed securities(“SMBSs”) and other securities that directly or indirectly represent a participation in, or are secured by and payable from,mortgage loans on real property. The value of some mortgage- or asset-backed securities may be particularly sensitive tochanges in prevailing interest rates. Early repayment of principal on some mortgage-related securities may expose the Fundto a lower rate of return upon reinvestment of principal. When interest rates rise, the value of a mortgage-related security
generally will decline; however, when interest rates are declining, the value of mortgage-related securities with prepayment
features may not increase as much as other fixed income securities. The rate of prepayments on underlying mortgages willaffect the price and volatility of a mortgage-related security, and may shorten or extend the effective maturity of the security
beyond what was anticipated at the time of purchase. If unanticipated rates of prepayment on underlying mortgages increase
the effective maturity of a mortgage-related security, the volatility of the security can be expected to increase. The valueof these securities may fluctuate in response to the market’s perception of the creditworthiness of the issuers. Additionally,
although mortgages and mortgage-related securities are generally supported by some form of government or private guarantee
and/or insurance, there is no assurance that private guarantors or insurers will meet their obligations.
One type of SMBS has one class receiving all of the interest from the mortgage assets (the interest-only, or “IO” class), while
the other class will receive all of the principal (the principal only, or “PO” class). The yield to maturity on an IO class isextremely sensitive to the rate of principal payments (including prepayments) on the underlying mortgage assets, and a rapid
rate of principal payments may have a material adverse effect on the Fund’s yield to maturity from these securities. The Fundmay invest in other asset-backed securities that have been offered to investors.
Other mortgage-related securities include securities other than those described above that directly or indirectly represent a
participation in, or are secured by and payable from, mortgage loans on real property, including mortgage dollar rolls, CMO
residuals or SMBSs. Other mortgage-related securities may be equity or debt securities issued by agencies or instrumentalitiesof the U.S. Government or by private originators of, or investors in, mortgage loans, including savings and loan associations,homebuilders, mortgage banks, commercial banks, investment banks, partnerships, trusts and special purpose entities of theforegoing.
Municipal Securities
Municipal securities include debt obligations issued by governmental entities to obtain funds for various public purposes,
such as the construction of a wide range of public facilities, the refunding of outstanding obligations, the payment of general
operating expenses, and the extension of loans to other public institutions and facilities. Other types of municipal securities
include short-term General Obligation Notes, Tax Anticipation Notes, Bond Anticipation Notes, Revenue Anticipation Notes,
Project Notes, Tax-Exempt Commercial Paper, Construction Loan Notes and other forms of short-term tax-exempt loans. Such
instruments are issued with a short-term maturity in anticipation of the receipt of tax funds, the proceeds of bond placements
or other revenues. An issuer’s obligations under its municipal securities are subject to the provisions of bankruptcy, insolvency,
and other laws affecting the rights and remedies of creditors, such as the federal bankruptcy code, and laws, if any, which may

15

be enacted by Congress or state legislatures extending the time for payment of principal or interest, or both, or imposing otherconstraints upon the enforcement of such obligations or upon the ability of municipalities to levy taxes. The power or abilityof an issuer to meet its obligations for the payment of interest on and principal of its municipal securities may be materiallyadversely affected by litigation or other conditions.
Municipal securities can be significantly affected by political changes as well as uncertainties in the municipal market related
to taxation, legislative changes, or the rights of municipal security holders. Because many municipal securities are issued tofinance similar projects, especially those relating to education, health care, transportation and utilities, conditions in those
sectors can affect the overall municipal market. In addition, changes in the financial condition of an individual municipal
insurer can affect the overall municipal market.
Municipal bonds, which generally have maturities of more than one year when issued, are designed to meet longer-term capitalneeds. Some longer-term municipal bonds allow an investor to “put” or sell the security at a specified time and price to theissuer or other “put provider.” If a put provider fails to honor its commitment to purchase the security, the Fund may have totreat the security’s final maturity as its effective maturity, potentially increasing the volatility of the Fund.
The Fund may invest in municipal lease obligations. Municipal leases frequently carry risks distinct from those associated withgeneral obligation or revenue bonds. State constitutions and statutes set requirements that states and municipalities must meetto incur debt. These may include voter referenda, interest rate limits or public sale requirements. Many leases and contracts
include no appropriation clauses, which provide that the governmental issuer has no obligation to make future payments
under the lease or contract unless money is appropriated for such purposes by the appropriate legislative body on a yearly orother periodic basis. Municipal lease obligations also may be subject to abatement risk. For example, construction delays ordestruction of a facility as a result of an uninsurable disaster that prevents occupancy could result in all or a portion of a lease
payment not being made.
Investing in the municipal bond market is subject to certain risks. The amount of public information available about themunicipal bonds held by the Fund is generally less than that for corporate equities or bonds, and the investment performanceof the Fund may therefore be more dependent on the analytical abilities of Cambria. The secondary market for municipal
bonds, particularly the lower-rated bonds, also tends to be less well developed or liquid than many other securities markets,
which may adversely affect the Fund’s ability to sell its bonds at attractive prices. The ability of municipal issuers to maketimely payments of interest and principal may be diminished during general economic downturns and as governmental costburdens are reallocated among federal, state and local governments. In addition, laws enacted in the future by Congress orstate legislatures or referenda could extend the time for payment of principal and/or interest, or impose other constraints on
enforcement of such obligations, or on the ability of municipal issuers to levy taxes. Issuers of municipal securities mightseek protection under the bankruptcy laws. In the event of bankruptcy of such an issuer, the Fund could experience delays incollecting principal and interest and the Fund may not, in all circumstances, be able to collect all principal and interest to which
it is entitled. See Appendix B to this SAI for a description of municipal bond credit ratings.
U.S. Government Securities
U.S. government securities include securities issued or guaranteed by the U.S. government or its authorities, agencies, or
instrumentalities. Different kinds of U.S. government securities have different kinds of government support. For example,
some U.S. government securities (e.g., U.S. Treasury bonds and Treasury inflation protected securities (TIPS)) are supportedby the full faith and credit of the U.S. Other U.S. government securities are issued or guaranteed by federal agencies orgovernment-chartered or - sponsored enterprises but are neither guaranteed nor insured by the U.S. government (e.g., debt
securities issued by the Federal Home Loan Mortgage Corporation (“Freddie Mac”), Federal National Mortgage Association(“FNMA” or “Fannie Mae”), and Federal Home Loan Banks (“FHLBs”).
It is possible that the availability and the marketability (that is, liquidity) of the securities discussed in this section could be
adversely affected by actions of the U.S. government to tighten the availability of credit.
As with other fixed income securities, U.S. government securities expose their holders to market risk because their values
typically change as interest rates fluctuate. For example, the value of U.S. government securities may fall during times of risinginterest rates. Yields on U.S. government securities tend to be lower than those of corporate securities of comparable maturities.
In addition to investing directly in U.S. government securities, the Fund may purchase certificates of accrual or similar
instruments evidencing undivided ownership interests in interest payments and/or principal payments of U.S. government
securities. Certificates of accrual and similar instruments may be more volatile than other government securities.

16

Zero Coupon Securities
Zero coupon securities may be issued by a wide variety of corporate and governmental issuers. Zero coupon securities
tend to be subject to greater market risk than interest-paying securities of similar maturities. When an investor purchases a
traditional coupon-bearing bond, it is paid periodic interest at a predetermined rate. Zero coupon securities tend to be subject togreater price fluctuations in response to changes in interest rates than are ordinary interest-paying debt securities with similar
maturities. The value of zero coupon securities appreciates more during periods of declining interest rates and depreciates
more during periods of rising interest rates than ordinary interest-paying debt securities with similar maturities.
Derivatives
The Fund may use derivative instruments as part of its investment strategies. Generally, derivatives are financial contracts
whose value depends upon, or is derived from, the value of an underlying asset, reference rate or index, and may relate tobonds, interest rates, currencies, commodities, and related indexes. Examples of derivative instruments include put options,call options, swap agreements, forward currency contracts, futures contracts, and options on futures contracts.
Regulatory developments may limit the availability of certain derivatives, may make the use of derivatives by the Fund morecostly, and may otherwise adversely impact the performance and value of derivatives. Regulatory developments also maychange the way in which the Fund itself is regulated. Such developments may affect the Fund’s ability to invest or the extent
to which it may invest in certain derivatives and subject the Fund to additional regulatory requirements. Complying with new
requirements may increase the cost of the Fund’s investments and the cost of implementing the Fund’s investment program andrelated operations, which could adversely affect the Fund’s performance.
CFTC Regulation
The 2010 enactment of the Dodd-Frank Act resulted in historic and comprehensive statutory reform of derivatives, including
swaps, options, futures and forward contracts, and the manner in which they are designed, negotiated, reported, executed,
settled (or “cleared”) and regulated. Title VII of the Dodd-Frank Act creates a framework for the regulation of OTC derivatives,
such as swaps. In particular, it makes broad changes to the OTC derivatives market and grants significant new authority to the
SEC and the CFTC to regulate OTC derivatives and market participants. The legislation and the related regulations developedby the CFTC, SEC, and other federal regulators that have been and may be promulgated in the future may negatively impact
a Fund’s ability to meet its investment objective either through investment limits or requirements imposed on it or any of its
counterparties. In particular, capital requirements and requirements related to the mandatory clearing of OTC derivatives
transactions have impacted and may continue to impact the costs to a Fund of trading these instruments and, as a result, may
affect returns to investors in a Fund.
Central Clearing. Forward currency contracts that are centrally cleared are subject to the creditworthiness of the clearingorganizations involved in the transaction. For example, an investor could lose margin payments it has deposited with theclearing organization as well as the net amount of gains not yet paid by the clearing organization if it breaches its agreementwith the investor or becomes insolvent or goes into bankruptcy. In the event of bankruptcy of the clearing organization, theinvestor may be entitled to the net amount of gains the investor is entitled to receive plus the return of margin owed to it only inproportion to the amount received by the clearing organization’s other customers, potentially resulting in losses to the investor.
To the extent a forward currency contract is not centrally cleared, the use of forward currency contracts also involves the riskthat a loss may be sustained as a result of the insolvency or bankruptcy of the counterparty or the failure of the counterparty
to make required payments or otherwise comply with the terms of the agreement. The creditworthiness of firms with which
the Fund enters into forward currency contracts will be monitored by Cambria. If a counterparty’s creditworthiness declines,
the value of the forward currency contract might decline, potentially resulting in losses to the Fund. Changing conditions in aparticular market area may have an adverse impact on the creditworthiness of the counterparty. For example, the counterparty
may have experienced losses as a result of its exposure to a sector of the market that adversely affect its creditworthiness. If
a default occurs by the other party to such transaction, the Fund may have contractual remedies pursuant to the agreements
related to the transaction, but exercising these remedies could take significant time and expense.
Commodity Pool Exclusion and Registration. In February 2012, the CFTC announced substantial amendments to the
exclusion in its Regulation 4.5 for registered investment companies from registration as a commodity pool operator (“CPO”).
Under these amendments, if the Fund uses commodity interests (such as CFTC-regulated futures, options on futures andswaps) other than for bona fide hedging purposes (as defined by the CFTC) and seeks to claim the Regulation 4.5 exclusion

17

from registration, the aggregate initial margin and premiums required to establish these positions (after taking into accountunrealized profits and unrealized losses on any such positions and excluding the amount by which options are “in-the-money”
at the time of purchase) may not exceed 5% of the Fund’s NAV. Alternatively, the aggregate net notional value of these
positions, determined at the time the most recent position was established, may not exceed 100% of the Fund’s NAV (after
taking into account unrealized profits and unrealized losses on any such positions).
To the extent a Fund invests in derivative instruments subject to regulation by the CFTC, it will seek to do so in reliance uponand in accordance with CFTC Rule 4.5 and comply with one of the two alternative limitations described above. To the extent
these limits are approached, Cambria may not be able to take advantage of investment opportunities for the Fund in order tocomply with and maintain the exclusion.
Outer Limits. Transactions using derivative instruments, such as options or forward currency contracts, may expose the Fundto an obligation to another party. Under such circumstances, the Fund will comply with Rule 18f-4 under the Investment
Company Act and, if applicable, the value-at-risk limitations thereunder to create an outer limit on the Fund’s leverage risk.
Turnover. The Fund’s forward currency contracts activities, if any, may affect its turnover rate. The sale or purchase of forward
currency contracts may cause the Fund to sell or purchase related investments, thus increasing its turnover rate.
Futures Contracts and Related Options
The Fund may utilize futures contracts and options. Rule 18f-4 under the 1940 Act imposes requirements and restrictions on
a fund’s use of certain derivatives that may oblige the fund to make payments or incur additional obligations in the future.
Rule 18f-4 imposes limits on the amount of leverage risk to which a fund may be exposed through such derivatives. If afund’s derivatives exposure is more than 10% of its net assets the fund must apply a Value at Risk (“VaR”) test to its use ofcertain derivatives and financing transactions, establish and maintain a derivatives risk management program, and appoint a
derivatives risk manager to implement such program.
The Fund may purchase or sell stock index futures contracts and options thereon, including as a substitute for a comparable
market position in the underlying securities, to hedge the portfolio, or to satisfy regulatory requirements. A futures contract
generally obligates the seller to deliver (and the purchaser to take delivery of) the specified commodity on the expiration dateof the contract. A stock index futures contract obligates the seller to deliver (and the purchaser to take) an amount of cash
equal to a specific dollar amount (the contract multiplier) multiplied by the difference between the final settlement price ofa specific stock index futures contract and the price at which the agreement is made. No physical delivery of the underlying
stocks in the index is made.
The Fund generally chooses to engage in closing or offsetting transactions before final settlement wherein a second identical
futures contract is sold to offset a long position (or bought to offset a short position). In such cases the obligation is to deliver(or take delivery of) cash equal to a specific dollar amount (the contract multiplier) multiplied by the difference between theprice of the offsetting transaction and the price at which the original contract was entered into. If the original position enteredinto is a long position (futures contract purchased) there will be a gain (loss) if the offsetting sell transaction is done at a higher(lower) price, inclusive of commissions. If the original position entered into is a short position (futures contract sold) there will
be a gain (loss) if the offsetting buy transaction is done at a lower (higher) price, inclusive of commissions.
Whether the Fund realizes a gain or loss from futures activities depends generally upon movements in the underlying asset. The
extent of the Fund’s loss from an unhedged short position in futures contracts is potentially unlimited. The Fund may engage in
related closing transactions with respect to options on futures contracts. The Fund intends to engage in transactions in futurescontracts that are traded on a U.S. exchange or board of trade or that have been approved for sale in the United States by the CFTC.
Upon entering into a futures contract, the Fund will be required to deposit with the broker an amount of cash or cash equivalents
known as “initial margin,” which is in the nature of a performance bond or good faith deposit on the contract, and that is returnedto the Fund upon termination of the futures contract, assuming all contractual obligations have been satisfied. Subsequent
payments, known as “variation margin,” to and from the broker will be made daily as the price of the index underlying thefutures contract fluctuates, making the long and short positions in the futures contract more or less valuable, a process known
as “marking-to-market.” At any time prior to expiration of a futures contract, the Fund may elect to close its position by taking
an opposite position, which will operate to terminate the Fund’s existing position in the contract.

18

The Fund may cover its long position in a futures contract by taking a short position in the instruments underlying the futurescontract, or by taking positions in instruments the prices of which are expected to move relatively consistently inversely withthe futures contract. The Fund may cover its short position in a futures contract by taking a long position in the instruments
underlying the futures contract, or by taking positions in instruments, the prices of which are expected to move relatively
consistently to the futures contract. The Fund may “cover” its short position in a futures contract by purchasing a call option
on the same futures contract with a strike price (i.e., an exercise price) as low or lower than the price of the futures contract,or, if the strike price of the call is greater than the price of the futures contract, the Fund may earmark or segregate cash or
liquid instruments equal in value to the difference between the strike price of the call and the price of the future. The Fund may
cover its long or short positions in futures by earmarking or segregating with its custodian bank or on the books and records ofthe Fund (and mark-to-market on a daily basis) cash or liquid instruments that, when added to any amounts deposited with afutures commission merchant as margin, are equal to the market value of the futures contract or otherwise “cover” its position.
Although the Fund intends to sell futures contracts only if there is an active market for such contracts, no assurance can begiven that a liquid market will exist for any particular contract at any particular time. Many futures exchanges and boards oftrade limit the amount of fluctuation permitted in futures contract prices during a single trading day. Once the daily limit has
been reached in a particular contract, no trades may be made that day at a price beyond that limit or trading may be suspended
for specified periods during the day. Futures contract prices could move to the limit for several consecutive trading days withlittle or no trading, thereby preventing prompt liquidation of futures positions and potentially subjecting the Fund to substantial
losses. If trading is not possible, or if the Fund determines not to close a futures position in anticipation of adverse pricemovements, the Fund will be required to make daily cash payments of variation margin. The risk that the Fund will be unable
to close out a futures position will be minimized by entering into such transactions on a national securities exchange with anactive and liquid secondary market.
Options Contracts
The Fund may purchase put and call options on specific securities (including groups or “baskets” of specific securities),
interest rates, and indices. In addition, the Fund may write put and call options on such financial instruments.
Options on Securities. The Fund may purchase put and call options on securities. A put option on a security gives the purchaserof the option the right (but not the obligation) to sell, and the writer of the option the obligation to buy, the underlying security
at a stated price (the “exercise price”) at any time before the option expires. A call option on a security gives the purchaser theright (but not the obligation) to buy, and the writer the obligation to sell, the underlying security at the exercise price at any
time before the option expires. The purchase price for a put or call option is the “premium” paid by the purchaser for the rightto sell or buy.
The Fund may purchase put options to hedge against a decline in the value of its portfolio. By using put options in this way,
the Fund would reduce any profit it might otherwise have realized in the underlying security by the amount of the premium
paid for the put option and by transaction costs. In similar fashion, the Fund may purchase call options to protect against
an increase in the price of securities that the Fund anticipates purchasing in the future, a practice sometimes referred to as“anticipatory hedging.” The premium paid for the call option plus any transaction costs will reduce the benefit, if any, realized
by the Fund upon exercise of the option, and, unless the price of the underlying security rises sufficiently, the option may expire
unexercised.
Options on Interest Rates and Indices. The Fund may purchase put and call options on interest rates and bond indices. An
option on interest rates or on an index gives the holder the right to receive, upon exercise of the option, an amount of cash if theclosing value of the underlying interest rate or index is greater than, in the case of a call, or less than, in the case of a put, theexercise price of the option. This amount of cash is equal to the difference between the exercise-settlement value of the interest
rate option or the closing price of the index and the exercise price of the option expressed in dollars times a specified multiple(the “multiplier”). The writer of the option is obligated, for the premium received, to make delivery of this amount. Settlements
for interest rate and index options are always in cash.
Swap Agreements
The Fund may enter into swap agreements, including interest rate swaps, credit default swaps, currency swaps, commodity
index swaps, inflation-linked swaps and total return swaps. A typical interest rate swap involves the exchange of a floatinginterest rate payment for a fixed interest payment. A typical credit default swap (“CDS”) involves an agreement to make aseries of payments by the buyer in exchange for receipt of payment by the seller if the loan defaults. In the event of default

19the buyer of the CDS receives compensation (usually the face value of the loan), and the seller of the CDS takes possessionof the defaulted loan. In the event that the Fund acts as a protection seller of a CDS, the Fund will segregate assets equivalent
to the full notional value of the CDS. In the event that the Fund acts as a protection buyer of a CDS, the Fund will cover
the total amount of required premium payments plus the pre-payment penalty. A typical foreign currency swap involves theexchange of cash flows based on the notional difference among two or more currencies (e.g., the U.S. dollar and the euro).
Commodity index swaps and total return swaps involve the exchange of payments based on the value of an index or total
return on an underlying reference asset. The total return includes appreciation or depreciation on the reference asset, plus any
interest or dividend payments. Inflation-linked swaps are typically an agreement between two parties to exchange payments
at a future date based on the difference between a fixed payment and a payment linked to the inflation rate at future date.
Swaps agreements can be structured to provide for periodic payments over the term of the swap contract or a single payment
at maturity (also known as a “bullet swap”). Swap agreements may be used to hedge or achieve exposure to, for example,
commodities, currencies, and interest rates without actually purchasing such commodities, currencies or securities. The Fundmay use swap agreements to invest in a market without owning or taking physical custody of the underlying securities incircumstances in which direct investment is restricted for legal reasons or is otherwise impracticable. Swap agreements willtend to shift the Fund’s investment exposure from one type of investment to another or from one payment stream to another.
Depending on their structure, swap agreements may increase or decrease the Fund’s exposure to long- or short-term interest
rates (in the United States or abroad), commodities, and foreign currencies, and may increase or decrease the overall volatilityof the Fund’s investments and its share price.
Dollar Rolls, Delayed Delivery Transactions and When Issued or Forward Commitment Securities
The purchase or sale of when-issued securities enables an investor to hedge against anticipated changes in interest rates andprices by locking in an attractive price or yield. The price of delayed delivery transactions, including when-issued securities, isfixed at the time the commitment to purchase or sell is made, but delivery and payment for the securities takes place at a later
date, normally one to two months after the date of purchase. During the period between purchase and settlement, no payment ismade by the purchaser to the issuer and no interest accrues to the purchaser. Such transactions therefore involve a risk of loss if
the value of the security to be purchased declines prior to the settlement date or if the value of the security to be sold increases
prior to the settlement date. A sale of a when-issued security also involves the risk that the other party will be unable to settle
the transaction. Dollar rolls are a type of forward commitment transaction. Purchases and sales of securities on a forward
commitment basis involve a commitment to purchase or sell securities with payment and delivery to take place at somefuture date, normally one to two months after the date of the transaction. As with when-issued securities, these transactions
involve certain risks, but they also enable an investor to hedge against anticipated changes in interest rates and prices. Forward
commitment transactions are executed for existing obligations, whereas in a when-issued transaction, the obligations have notyet been issued. When purchasing securities on a when-issued or forward commitment basis, a segregated account of liquid
assets at least equal to the value of purchase commitments for such securities will be maintained until the settlement date. Suchtransactions, however, would be deemed not to involve a senior security (i.e., will not be considered derivatives transactions
or subject to asset segregation requirements), provided that (i) the Fund intends to physically settle the transaction and (ii) thetransaction will settle within 35 days of its trade date. If such a transaction were considered to be a derivatives transaction, it
would be subject to the requirements of Rule 18f-4 under the 1940 Act.
Equity-Related Investments
Common Stocks
Common stock represents an ownership interest in a company and usually possesses voting rights and earns dividends.
Dividends on common stock are not fixed but are declared at the discretion of the issuer. Common stock generally represents
the riskiest investment in a company. In addition, common stock generally has the greatest appreciation and depreciation
potential because increases and decreases in earnings are usually reflected in a company’s common stock price.
The fundamental risk of investing in common stock is the risk that the value of the stock might decrease. Stock values
fluctuate in response to the activities of an individual company or in response to general market and/or economic conditions.
Historically, common stocks have provided greater long-term returns and have entailed greater short-term risks than preferredstocks, fixed-income securities and money market investments. This may not be true currently or in the future. The market
value of all securities, including common stocks, is based upon the market’s perception of value and not necessarily the bookvalue of an issuer or other objective measure of a company’s worth. If you invest in the Fund, you should be willing to accept
the risks of the stock market and should consider an investment in the Fund only as a part of your overall investment portfolio.

20

Convertible Securities
Convertible securities include fixed-income securities, preferred stock or other securities that may be converted into or
exchanged for a given amount of common stock of the same or a different issuer during a specified period and at a specified
price in the future. A convertible security entitles the holder to receive interest on debt or the dividend on preferred stock until
the convertible security matures or is redeemed, converted or exchanged.
Convertible securities have unique investment characteristics in that they generally: (1) have higher yields than the underlying
common stock, but lower yields than comparable non-convertible securities; (2) are less subject to fluctuation in value than theunderlying common stock since they have fixed-income characteristics; and (3) provide the potential for capital appreciation
if the market price of the underlying common stock increases.
A convertible security may be subject to redemption at the option of the issuer at a price established in the convertible security’s
governing instrument. If a convertible security is called for redemption, the Fund will be required to permit the issuer toredeem the security, convert it into the underlying common stock or sell it to a third party.
Convertible securities are typically issued by smaller capitalization companies whose stock price may be volatile. Therefore, theprice of a convertible security may reflect variations in the price of the underlying common stock in a way that non-convertible
debt does not. The extent to which such risk is reduced, however, depends in large measure upon the degree to which theconvertible security sells above its value as a fixed-income security.
Master Limited Partnerships
The Fund may invest in master limited partnerships (“MLPs”) which are publicly traded partnerships primarily engaged
in the transportation, storage, processing, refining, marketing, exploration, production, and mining of minerals and natural
resources. Their interests, or units, trade on public securities exchanges exactly like the shares of a corporation, without
entity level taxation. MLPs generally have two classes of owners, one or more general partners and the limited partners (i.e.,
investors). The general partner typically controls the operations and management of the MLP through an equity interest in the
MLP plus, in many cases, ownership of common units and subordinated units. Limited partners typically own the remainder ofthe partnership, through ownership of common units, and have a limited role in the partnership’s operations and management.
In certain instances, creditors of an MLP would have the right to seek a return of capital that had been distributed to alimited partner. The right of an MLP’s creditors would continue even after the Fund had sold its investment in the partnership.
MLPs typically invest in real estate, oil and gas equipment leasing assets, but they also finance entertainment, research anddevelopment, and other projects.
MLP common units, like other equity securities, can be affected by macroeconomic and other factors affecting the stock
market in general, expectations of interest rates, investor sentiment towards an issuer or certain market sector, changes in aparticular issuer’s financial condition, or unfavorable or unanticipated poor performance of a particular issuer (in the case of
MLPs, generally measured in terms of distributable cash flow). Prices of common units of individual MLPs, like the prices ofother equity securities, also can be affected by fundamentals unique to the partnership or company, including earnings powerand coverage ratios.
Investments in Other Investment Companies or Other Pooled Investments
The Fund may invest in the securities of other investment companies to the extent permitted by law. Subject to applicableregulatory requirements, the Fund may invest in shares of both open- and closed-end investment companies (including money
market funds and ETFs). The market price for ETF and closed-end fund shares may be higher or lower than, respectively, theETF’s and closed-end fund’s NAV. Investing in another investment company exposes the Fund to all the risks of that investmentcompany and, in general, subjects it to a pro rata portion of the other investment company’s fees and expenses. As a result, aninvestment by the Fund in an ETF or investment company could cause the Fund’s operating expenses to be higher and, in turn,
performance to be lower than if the Fund were to invest directly in the securities underlying the ETF or investment company.
The Fund also may invest in private investment funds, vehicles, or structures.
Preferred Stocks
The Fund may invest in preferred stocks. Preferred stocks include convertible and non-convertible preferred and preference
stocks that are senior to common stock. Preferred stocks are equity securities that are senior to common stock with respect tothe right to receive dividends and a fixed share of the proceeds resulting from the issuer’s liquidation. Some preferred stocks
also entitle their holders to receive additional liquidation proceeds on the same basis as holders of the issuer’s common stock,and thus represent an ownership interest in the issuer. Depending on the features of the particular security, holders of preferredstock may bear the risks disclosed in the Prospectus or this SAI regarding equity or fixed income securities.

21Real Estate Investment Trusts (REITs)
A REIT is a company that pools investor funds to invest primarily in income producing real estate or real estate related loans
or interests. U.S. REITs are not taxed on income distributed to their shareholders if, among other things, they distribute
substantially all of their taxable income (other than net capital gains) for each taxable year.
Because REITs have ongoing fees and expenses, which may include management, operating and administration expenses,
REIT shareholders, including the Fund, will indirectly bear a proportionate share of those expenses in addition to the expensesof the Fund. However, such expenses are not considered to be Acquired Fund Fees and Expenses and, therefore, are notreflected as such in the Fund’s fee table.
The Fund also may be subject to certain risks associated with the direct investments of the REITs. REITs may be affectedby changes in their underlying properties and by defaults by borrowers or tenants. Mortgage REITs may be affected by thequality of the credit extended. Furthermore, REITs are dependent on specialized management skills. Some REITs may
have limited diversification and may be subject to risks inherent in financing a limited number of properties. REITs depend
generally on their ability to generate cash flow to make distributions to shareholders or unitholders, and may be subject todefaults by borrowers and to self-liquidations. In addition, the performance of a U.S. REIT may be affected by its failure
to qualify for tax-free pass-through of income under the Code, including regulations thereunder and IRS interpretations, orsimilar authority upon which the Fund may rely or its failure to maintain exemption from registration under the Investment
Company Act.
Rights and Warrants
A right is a privilege granted to existing shareholders of a corporation to subscribe to shares of a new issue of common stock
before it is issued. Rights normally have a short life of usually two to four weeks, are freely transferable and entitle the holder
to buy the new common stock at a lower price than the public offering price. Warrants are securities that are usually issued
together with a debt security or preferred stock and that give the holder the right to buy proportionate amount of common
stock at a specified price. Warrants are freely transferable and are traded on major exchanges. Unlike rights, warrants normally
have a life that is measured in years and entitles the holder to buy common stock of a company at a price that is usually higher
than the market price at the time the warrant is issued. Corporations often issue warrants to make the accompanying debt
security more attractive. An investment in warrants and rights may entail greater risks than certain other types of investments.
Generally, rights and warrants do not carry the right to receive dividends or exercise voting rights with respect to the underlying
securities, and they do not represent any rights in the assets of the issuer. In addition, their value does not necessarily changewith the value of the underlying securities, and they cease to have value if they are not exercised on or before their expiration
date. Investing in rights and warrants increases the potential profit or loss to be realized from the investment as compared withinvesting the same amount in the underlying securities.
Foreign Investments Generally
Foreign Market Risk. Foreign security investment or exposure involves special risks not present in U.S. investments that canincrease the chances that the Fund will lose money. These risks are higher for emerging markets investments, which can be
subject to greater social, economic, regulatory and political uncertainties, and may have significantly less liquidity, thandeveloped markets. In particular, the Fund is subject to the risk that because there are generally fewer investors on foreignexchanges and a smaller number of shares traded each day, it may be difficult for the Fund to buy and sell securities, orincrease or decrease exposures, on those exchanges. In addition, prices of foreign securities may fluctuate more than prices of
securities traded in the U.S.
Foreign Economy Risk. The economies of certain foreign markets often do not compare favorably with that of the U.S. withrespect to such issues as growth of gross domestic product, reinvestment of capital, resources, and balance of payments
positions. Certain foreign economies may rely heavily on particular industries or foreign capital and are more vulnerable
to diplomatic developments, the imposition of economic sanctions against a particular country or countries, changes ininternational trading patterns, trade barriers, and other protectionist or retaliatory measures. Investments in foreign markets
may also be adversely affected by governmental actions such as the imposition of capital controls, nationalization of companies
or industries, expropriation of assets, or the imposition of punitive taxes. In addition, the governments of certain countries
may prohibit or impose substantial restrictions on foreign investing in their capital markets or in certain industries. Any ofthese actions could severely affect security prices, impair the Fund’s ability to purchase or sell foreign securities, or obtain
exposure to them, or transfer the Fund’s assets back into the U.S., or otherwise adversely affect the Fund’s operations. Other
foreign market risks include foreign exchange controls, difficulties in pricing securities, defaults on foreign government

22

securities, difficulties in enforcing favorable legal judgments in foreign courts, and political and social instability. Legal
remedies available to investors in certain foreign countries may be less extensive than those available to investors in the U.S. orother foreign countries. Foreign corporate governance may not be as robust as in the U.S. As a result, protections for minority
investors may not be strong, which could affect security prices.
Currency Risk and Exchange Risk. Securities in which the Fund invests, or to which they obtain exposure, may be denominatedor quoted in currencies other than the U.S. dollar. Changes in foreign currency exchange rates will affect the value of thesesecurities. Generally, when the U.S. dollar rises in value against a foreign currency, an investment in a security denominated inthat currency loses value because the currency is worth fewer U.S. dollars. Similarly, when the U.S. dollar decreases in value
against a foreign currency, an investment in, or exposure to, a security denominated in that currency gains value because thecurrency is worth more U.S. dollars. This risk is generally known as “currency risk,” which is the possibility that a stronger
U.S. dollar will reduce returns for U.S. investors investing overseas. Foreign currencies also involve the risk that they will be
devalued or replaced, adversely affecting the Fund’s investments.
Governmental Supervision and Regulation/Accounting Standards. Many foreign governments supervise and regulate stock
exchanges, brokers and the sale of securities to a lesser extent than the U.S. government. Some countries may not have laws toprotect investors the way that the U.S. securities laws do. Accounting standards in other countries are not necessarily the sameas in the U.S. If the accounting standards in another country do not require as much disclosure or detail as U.S. accounting
standards, it may be harder to completely and accurately determine a company’s financial condition.
Certain Risks of Holding Fund Assets Outside the U.S. Foreign securities in which the Fund invests, or to which it obtains
exposure, are generally held outside the U.S. in foreign banks and securities depositories. The Fund’s custodian is the Fund’s“foreign custody manager” as provided in Rule 17f-5 under the Investment Company Act. The “foreign custody manager” is
responsible for determining that the Fund’s directly-held foreign assets will be subject to reasonable care, based on standards
applicable to custodians in relevant foreign markets. However, certain foreign banks and securities depositories may be recently
organized or new to the foreign custody business. They may also have operations subject to limited or no regulatory oversight.
Also, the laws of certain countries may put limits on the Fund’s ability to recover its assets if a foreign bank or depository or
issuer of a security or an agent of any of the foregoing goes bankrupt. In addition, it likely will be more expensive for the Fundto buy, sell and hold securities, or increase or decrease exposures thereto, in certain foreign markets than it is in the U.S. market
due to higher brokerage, transaction, custody and/or other costs. The increased expense of investing in foreign markets reduces
the amount the Fund can earn on its investments.
Settlement and clearance procedures in certain foreign markets differ significantly from those in the U.S. Foreign settlement
and clearance procedures and trade regulations also may involve certain risks (such as delays in payment for or delivery of
securities) not typically involved with the settlement of U.S. investments. Communications between the U.S. and emerging
market countries may be unreliable, increasing the risk of delayed settlements or losses of security certificates. Settlements
in certain foreign countries at times have not kept pace with the number of securities transactions. The problems may make it
difficult for the Fund to carry out transactions. If the Fund cannot settle or is delayed in settling a purchase of securities, theFund may miss attractive investment opportunities and certain of its assets may be uninvested with no return earned thereon
for some period. If the Fund cannot settle or is delayed in settling a sale of securities, directly or indirectly, it may lose money
if the value of the security then declines or, if it has contracted to sell the security to another party, the Fund could be liable
to that party for any losses incurred.
Dividends and interest on, and proceeds from the sale of, foreign securities the Fund holds, or has exposure to, may be subject
to foreign withholding or other taxes, and special federal tax considerations may apply.
Cambria Global Tail Risk ETF. Although the Fund is designed to manage the risks associated with a significant negative
movement in the value of global ex-U.S. equities over rolling one-month periods, and thus stands to benefit from a substantial
downturn in the global ex-U.S. equity market, the Fund also invests in ex-U.S. fixed income securities and is subject generally
to risks associated with foreign investments. Accordingly, the following risks may negatively impact the Fund’s ex-U.S. fixedincome securities although the Fund’s put option strategy is designed to counter a downturn in the global ex-U.S. equity
market.

23

Asia-Pacific Risk
Investments in securities of issuers in Asia-Pacific countries involve risks not typically associated with investments insecurities of issuers in other regions. Such heightened risks include, among others, expropriation and/or nationalizationof assets, confiscatory taxation, political instability, including authoritarian and/or military involvement in governmental
decision-making, armed conflict and social instability as a result of religious, ethnic and/or socio-economic unrest. Certain
Asia-Pacific economies have experienced rapid rates of economic growth and industrialization in recent years, and there is no
assurance that these rates of economic growth and industrialization will be maintained.
Certain Asia-Pacific countries have democracies with relatively short histories, which may increase the risk of politicalinstability. These countries have faced political and military unrest, and further unrest could present a risk to their local
economies and securities markets. Indonesia and the Philippines have each experienced violence and terrorism, which has
negatively impacted their economies. North Korea and South Korea each have substantial military capabilities, and historicaltensions between the two countries present the risk of war; in the recent past, these tensions have escalated. Any outbreak ofhostilities between the two countries could have a severe adverse effect on the South Korean economy and securities market.
Increased political and social unrest in these geographic areas could adversely affect the performance of investments in thisregion.
Certain governments in this region administer prices on several basic goods, including fuel and electricity, within theirrespective countries. Certain governments may exercise substantial influence over many aspects of the private sector in theirrespective countries and may own or control many companies. Future government actions could have a significant effect on
the economic conditions in this region, which in turn could have a negative impact on private sector companies. There is also
the possibility of diplomatic developments adversely affecting investments in the region.
Corruption and the perceived lack of a rule of law in dealings with international companies in certain Asian countries may
discourage foreign investment and could negatively impact the long-term growth of certain economies in this region. In
addition, certain countries in the region are experiencing high unemployment and corruption, and those countries have fragile
banking sectors. Their securities markets are not as developed as those of other countries and, therefore, are subject to additionalrisks such as trading halts.
Some economies in this region are dependent on a range of commodities, including oil, natural gas and coal. Accordingly,
they are strongly affected by international commodity prices and particularly vulnerable to any weakening in global demand
for these products. The market for securities in this region may also be directly influenced by the flow of international capital,
and by the economic and market conditions of neighboring countries. Adverse economic conditions or developments inneighboring countries may increase investors’ perception of the risk of investing in the region as a whole, which may adversely
impact the market value of the securities issued by companies in the region.
Investments in China and Hong Kong. Investing in Chinese securities listed and traded in Hong Kong involves
special considerations not typically associated with investing in countries with more democratic governments or moreestablished economies or securities markets. Such risks may include: (i) the risk of nationalization or expropriationof assets or confiscatory taxation; (ii) greater social, economic and political uncertainty (including the risk of war);(iii) dependency on exports and the corresponding importance of international trade; (iv) increasing competition from
Asia’s other low-cost emerging economies; (v) currency exchange rate fluctuations and the lack of available currency
hedging instruments; (vi) higher rates of inflation; (vii) controls on foreign investment and limitations on repatriationof invested capital and on the Fund’s ability to exchange local currencies for U.S. dollars; (viii) greater governmental
involvement in and control over the economy; (ix) the risk that the Chinese government may decide not to continue
to support the economic reform programs implemented since 1978 and could return to the prior, completely centrally
planned, economy; (x) the fact that Chinese companies, particularly those located in China, may be smaller, lessseasoned and newly organized; (xi) the differences in, or lack of, auditing and financial reporting standards which
may result in unavailability of material information about issuers, particularly in China where, for example, the PublicCompany Accounting Oversight Board )=(“PCAOB”) lacks access to inspect PCAOB registered accounting firms;(xii) the fact that statistical information regarding the economy of China may be inaccurate or not comparable tostatistical information regarding the U.S. or other economies; (xiii) the less extensive, and still developing, regulationof the securities markets, business entities and commercial transactions; (xiv) the fact that the settlement period of
securities transactions in foreign markets may be longer; (xv) the fact that the willingness and ability of the Chinese
government to support the Chinese and Hong Kong economies and markets is uncertain; (xvi) the risk that it may be
more difficult, or impossible, to obtain and/or enforce a judgment than in other countries; (xvii) the rapid and erratic
nature of growth, particularly in China, resulting in inefficiencies and dislocations; (xviii) the risk that, because of24the degree of interconnectivity between the economies and financial markets of China and Hong Kong, any sizable
reduction in the demand for goods from China, or an economic downturn in China, could negatively affect theeconomy and financial market of Hong Kong as well; and (xix) the risk that certain companies in a Fund’s portfolio
may have dealings with countries subject to sanctions or embargoes imposed by the U.S. Government or identified
as state sponsors of terrorism.
After many years of steady growth, the growth rate of China’s economy has recently slowed. Although this slowdown
was to some degree intentional, the slowdown has also slowed the once rapidly growing Chinese real estate market
and left local governments with high debts with few viable means to raise revenue, especially with the fall in demandfor housing. Despite its attempts to restructure its economy towards consumption, China remains heavily dependent
on exports. Accordingly, China is susceptible to economic downturns abroad, including any weakness in demand fromits major trading partners, including the United States, Japan, and Europe. In addition, China’s aging infrastructure,
worsening environmental conditions, rapid and inequitable urbanization, quickly widening urban and rural income
gap, domestic unrest and provincial separatism all present major challenges to the country. Further, China’s territorial
claims, including its land reclamation projects and the establishment of an Air Defense Identification Zone overislands claimed and occupied by Japan, are another source of tension and present risks to diplomatic and traderelations with certain of China’s regional trade partners.
Investments in Hong Kong are also subject to certain political risks not associated with other investments. Following
the establishment of the People’s Republic of China by the Communist Party in 1949, the Chinese government
renounced various debt obligations incurred by China’s predecessor governments, which obligations remain indefault, and expropriated assets without compensation. There can be no assurance that the Chinese government
will not take similar action in the future. Investments in China and Hong Kong involve risk of a total loss due togovernment action or inaction. China has committed by treaty to preserve Hong Kong’s autonomy and its economic,
political and social freedoms for 50 years from the July 1, 1997 transfer of sovereignty from the United Kingdom
to China. However, if China would exert its authority so as to alter the economic, political or legal structures or the
existing social policy of Hong Kong, investor and business confidence in Hong Kong could be negatively affected,
which in turn could negatively affect markets and business performance. In addition, the Hong Kong dollar trades at a
fixed exchange rate in relation to (or, is “pegged” to) the U.S. dollar, which has contributed to the growth and stabilityof the Hong Kong economy. However, it is uncertain how long the currency peg will continue or what effect theestablishment of an alternative exchange rate system would have on the Hong Kong economy. Because each Fund’s
NAV is denominated in U.S. dollars, the establishment of an alternative exchange rate system could result in a decline
in a Fund’s NAV. These and other factors could have a negative impact on a Fund’s performance.
Investments in Japan. Although Japan continues to recover from a prolonged economic downturn dating back to
2000, Japan’s economic growth rate has remained relatively low and it may remain low in the future and/or continue
to lag the growth rates of other developed nations and its Asian neighbors. Economic growth in Japan is heavily
dependent on international trade, government support of the financial services sector and other troubled sectors,
and consistent government policy supporting its export market. In the past, Japanese exports have been adversely
affected by trade tariffs and other protectionist measures as well as increased competition from developing nations.
Japan has few natural resources and is heavily dependent on oil imports. Higher commodity prices could therefore
have a negative impact on the Japanese economy. Slowdowns in the economies of key trading partners such as
the United States, China and/or countries in Southeast Asia, including economic, political or social instability insuch countries, could also have a negative impact on the Japanese economy as a whole. Despite the emergence ofChina as an important trading partner of Japan, strained relationships between Japan and its neighboring countries,
including China, Russia, South Korea and North Korea, based on historical grievances, territorial disputes, anddefense concerns, may also inject uncertainty into Japanese markets. Increased political tension between countries
in the region could adversely affect the Japanese economy and, in the event of a crisis, destabilize the region. The
Japanese economy is also vulnerable to concerns of economic slowdown from within the Japanese financial system,
including high levels of nonperforming loans, over-leveraged corporate balance sheets, extensive cross-ownershipby major corporations, a changing corporate governance structure, and large government deficits. Japanese currency
fluctuations may also adversely impact the Japanese economy and its export market. In the past, the Japanese
government has intervened in its currency market to maintain or reduce the value of the yen. Any such intervention in
the currency markets could cause the value of the yen to fluctuate sharply and unpredictably and could cause losses
to investors. In addition, Japan’s labor market is adapting to an aging workforce, declining population, and demandfor increased labor mobility. These demographic shifts and fundamental structural changes to the labor market may
negatively impact Japan’s economic competitiveness.

25

In March 2011, a massive earthquake and tsunami struck northeastern Japan causing major damage to the country’s
domestic energy supply, including damage to nuclear power plants. In the wake of this natural disaster, Japan’s financial
markets fluctuated dramatically and the resulting economic distress affected Japan’s recovery from its recession. The
government injected capital into the economy and proposed plans for massive spending on reconstruction efforts
in disaster-affected areas in order to stimulate economic growth. The full extent of the disaster’s impact on Japan’s
economy and foreign investment in Japan is difficult to estimate. The risks of natural disasters of varying degrees,such as earthquakes and tsunamis, and the resulting damage, continue to exist. These and other factors could have anegative impact on a Fund’s performance.
Investments in Korea. The economy of Korea is heavily dependent on exports and the demand for certain finishedgoods. Korea’s main industries include electronics, automobile production, chemicals, shipbuilding, steel, textiles,
clothing, footwear, and food processing. Conditions that weaken demand for such products worldwide or in other
Asian countries could have a negative impact on the Korean economy as a whole. The Korean economy’s relianceon international trade makes it highly sensitive to fluctuations in international commodity prices, currency exchange
rates and government regulation, and vulnerable to downturns of the world economy, particularly with respect toits four largest export markets (the EU, Japan, United States, and China). Korea has experienced modest economic
growth in recent years, but such continued growth may slow due, in part, to the economic slowdown in China and theincreased competitive advantage of Japanese exports with the weakened yen. Relations with North Korea could also
have a significant impact on the economy of Korea. Relations between South Korea and North Korea remain tense,
as exemplified in periodic acts of hostility, and the possibility of serious military engagement still exists. These andother factors could have a negative impact on a Fund’s performance.
Investments in Malaysia. Investments in Malaysian issuers involve risks that are specific to Malaysia, including,legal, regulatory, political, currency and economic risks. The Malaysian economy, among other things is dependent
upon external trade with other economies, including the U.S., China, Japan and Singapore. As a result, Malaysia isdependent on the economies of these other countries and any change in the price or demand for Malaysian exports
may have an adverse impact on the Malaysian economy. In addition, the Malaysian economy is heavily focused onexport of electronic goods. As a result, Malaysia’s reliance on the electronics sector makes it vulnerable to economic
downturns in, among other sectors, the technology sector.
Investments in Taiwan. The economy of Taiwan is heavily dependent on exports. Currency fluctuations, increasing
competition from Asia’s other emerging economies, and conditions that weaken demand for Taiwan’s export products
worldwide could have a negative impact on the Taiwanese economy as a whole. Concerns over Taiwan’s history ofpolitical contention and its current relationship with China may also have a significant impact on the economy of
Taiwan. These and other factors could have a negative impact on a Fund’s performance.
Investments in Singapore. The economy of Singapore is heavily dependent on international trade and exports.
Conditions that weaken demand for its products in the Asian region or worldwide could have a significant, negative
impact on Singapore’s economy as a whole. Singapore’s economy may also be particularly vulnerable to externalmarket changes due to the country’s small size. These and other factors could have a negative impact on the Fund’s
performance.
Australia Risk
Australia’s economy depends heavily on agricultural and mining sector exports as well as the economies of its key trading
partners, including China, the United States, and Japan. Conditions that weaken the price and demand for its exports and/or
natural resources and commodities, in general, could have a significant, negative impact on the Australian economy as a whole.
Canada Risk
The U.S. is Canada’s largest trading partner and foreign investor. As a result, changes to the U.S. economy may significantly
affect the Canadian economy. The economy of Canada is also heavily dependent on the demand for natural resources andagricultural products. Canada is a major producer of commodities such as forest products, metals, agricultural products, andenergy related products like oil, gas, and hydroelectricity. Accordingly, a change in the supply and demand of these resources,
both domestically and internationally, can have a significant effect on Canadian market performance. Canada is a top producerof zinc and uranium and a global source of many other natural resources, such as gold, nickel, aluminum, and lead. Conditions
that weaken demand for such products worldwide could have a negative impact on the Canadian economy as a whole. Theseand other factors could have a negative impact on a Fund’s performance.

26

Depositary Receipts
The Fund may invest in foreign securities by purchasing sponsored and unsponsored depositary receipts, including American
Depositary Receipts (“ADRs”), European Depositary Receipts (“EDRs”) and Global Depositary Receipts (“GDRs”) or othersecurities convertible into securities of issuers based in foreign countries. These securities may not necessarily be denominatedin the same currency as the securities which they represent. Generally, ADRs, in registered form, are denominated in
U.S. dollars and are designed for use in the U.S. securities markets, GDRs, in bearer form, are issued and designed for use
outside the United States and EDRs (also referred to as Continental Depositary Receipts (“CDRs”)), in bearer form, may bedenominated in other currencies and are designed for use in European securities markets. ADRs are receipts typically issued
by a U.S. bank or trust company evidencing ownership of the underlying securities. EDRs are European receipts evidencing
a similar arrangement. GDRs are receipts typically issued by non-United States banks and trust companies that evidence
ownership of either foreign or domestic securities. For purposes of the Fund’s investment policies, ADRs, GDRs and EDRs are
deemed to have the same classification as the underlying securities they represent. Thus, an ADR, GDR or EDR representing
ownership of common stock will be treated as common stock.
In an unsponsored arrangement, the foreign issuer assumes no obligations and the depositary’s transaction fees are paid by
the depositary holder. Unsponsored depositary receipts may be created without the participation of the foreign issuer. Holdersof these receipts generally bear all the costs of the depositary receipt facility, whereas foreign issuers typically bear certain
costs in a sponsored depositary receipt. The bank or trust company depositary of an unsponsored depositary receipt may
be under no obligation to distribute shareholder communications received from the foreign issuer or to pass through voting
rights. Accordingly, available information concerning the issuer may not be current, and the prices of unsponsored depositary
receipts may be more volatile than the prices of sponsored depositary receipts. In addition, the issuers of securities underlying
unsponsored depositary receipts may be subject to less stringent government supervision.
Emerging Markets Risk
Investing in companies domiciled in emerging market countries may be subject to greater risks than investments in developed
countries. These risks include: (i) less social, political, and economic stability; (ii) greater illiquidity and price volatility due tosmaller or limited local capital markets for such securities, or low or non-existent trading volumes; (iii) foreign exchanges andbroker-dealers may be subject to less scrutiny and regulation by local authorities; (iv) local governments may decide to seizeor confiscate securities held by foreign investors and/or local governments may decide to suspend or limit an issuer’s ability
to make dividend or interest payments; (v) local governments may limit or entirely restrict repatriation of invested capital,
profits, and dividends; (vi) capital gains may be subject to local taxation, including on a retroactive basis; (vii) issuers facing
restrictions on dollar or euro payments imposed by local governments may attempt to make dividend or interest payments
to foreign investors in the local currency; (viii) investors may experience difficulty in enforcing legal claims related to thesecurities and/or local judges may favor the interests of the issuer over those of foreign investors; (ix) bankruptcy judgments
may only be permitted to be paid in the local currency; (x) limited public information regarding the issuer may result in greaterdifficulty in determining market valuations of the securities, and (xi) lax financial reporting on a regular basis, substandard
disclosure, and differences in accounting standards may make it difficult to ascertain the financial health of an issuer. Manyemerging market countries have experienced currency devaluations and substantial (and, in some cases, extremely high) rates
of inflation. Other emerging market countries have experienced economic recessions. These circumstances have had a negative
effect on the economies and securities markets of such emerging market countries.
Europe Risk
Investing in European countries exposes the Fund to the economic and political risks associated with Europe in general and thespecific European countries in which it invests. The economies and markets of European countries are often closely connected
and interdependent, and events in one European country can have an adverse impact on other European countries. The Fundmakes investments in securities of issuers that are domiciled in, or have significant operations in, member countries of the
Economic and Monetary Union of the European Union (the “EU”), which requires member countries to comply with restrictions
on inflation rates, deficits, interest rates, debt levels and fiscal and monetary controls, each of which may significantly affectevery country in Europe. Decreasing imports or exports, changes in governmental or EU regulations on trade, changes in theexchange rate of the euro (the common currency of certain EU countries), the default or threat of default by an EU member
country on its sovereign debt, and/or an economic recession in an EU member country may have a significant adverse effecton the economies of EU member countries and their trading partners. Although certain European countries do not use the euro,
many of these countries are obliged to meet the criteria for joining the euro zone. Consequently, these countries must comply
with many of the restrictions noted above.

27

The European financial markets have experienced volatility and adverse trends in recent years due to concerns about economic
downturns, rising government debt levels and the possible default of government debt in several European countries, including
Greece, Ireland, Italy, Portugal and Spain. In order to prevent further economic deterioration, certain countries, without priorwarning, can institute “capital controls.” Countries may use these controls to restrict volatile movements of capital enteringand exiting their country. Such controls may negatively affect the Fund’s investments. A default or debt restructuring by any
European country would adversely impact holders of that country’s debt and sellers of credit default swaps linked to thatcountry’s creditworthiness, which may be located in countries other than those listed above. In addition, the credit ratingsof certain European countries were recently downgraded. These downgrades may result in further deterioration of investor
confidence. These events have adversely affected the value and exchange rate of the euro and may continue to significantly
affect the economies of every country in Europe, including countries that do not use the euro and non-EU member countries.
Responses to the financial problems by European governments, central banks and others, including austerity measures andreforms, may not produce the desired results, may result in social unrest and may limit future growth and economic recovery
or have other unintended consequences. Further defaults or restructurings by governments and other entities of their debt could
have additional adverse effects on economies, financial markets and asset valuations around the world. In addition, one ormore countries may abandon the euro and/or withdraw from the EU. The impact of these actions, especially if they occur in adisorderly fashion, is not clear but could be significant and far-reaching.
Investing in the securities of issuers located or operating in Eastern Europe is highly speculative and involves risks not usuallyassociated with investing in the more developed markets of Western Europe. Political and economic reforms are too recent
to establish a definite trend away from centrally planned economies and state-owned industries. In the past, some Eastern
European governments have expropriated substantial amounts of private property, and many claims of the property owners
have never been fully settled.
Many Eastern European countries continue to move toward market economies at different paces with different characteristics.
Most Eastern European securities markets suffer from thin trading activity, dubious investor protections, and often a dearth ofreliable corporate information. Information and transaction costs, differential taxes, and sometimes political or transfer risk give acomparative advantage to the domestic investor rather than the foreign investor. In addition, these markets are particularly sensitive
to social, political, economic, and currency events in Russia and may suffer heavy losses as a result of their trading and investment
links to the Russian economy and currency. Russia also may attempt to assert its influence in the region through economic or evenmilitary measures, as it did with Georgia in the summer of 2008 and Ukraine in 2014 and 2022. Eastern European economies
may also be particularly susceptible to changes in the international credit markets due to their reliance on bank related inflows
of capital. The global economic crisis has restricted international credit supplies, and several Eastern European economies have
faced significant credit and economic crises. Although some Eastern European economies are expanding again, major challenges
are still present as a result of their continued dependence on the Western European zone for credit.
On January 31, 2020, the United Kingdom (“UK”) formally withdrew from the EU, subject to a transition period that
ended on December 31, 2020. The uncertainty associated with the Brexit process as well as the consequences that follow
from its outcome could (i) adversely affect European or worldwide political, regulatory, economic, or market conditions,(ii) contribute to instability in global political institutions, regulatory agencies, and financial markets, and (iii) impact thevolatility of exchange rates and interest rates. Brexit could also lead to legal uncertainty and politically divergent nationallaws and regulations as a new relationship between the UK and EU is defined and the UK determines which EU laws to
replace or replicate. Any of these effects of Brexit could adversely affect any of the companies to which the Fund has
exposure and any other assets in which the Fund invests. The impact of Brexit in the near- and long-term is still unknown
and could have additional adverse effects on economies, financial markets and asset valuations around the world.
In addition, the extent and duration of Russia’s military invasion of Ukraine, initiated in February 2022, and the broad-ranging
economic sanctions levied against Russia by the United States, the EU, the UK, and other countries, remain unknown, but these
events could have a significant adverse impact on Europe’s overall economy. The current political and financial uncertainty
surrounding Russia and Ukraine may increase market volatility and the economic risk of investing in securities in Europe andmay also cause uncertainty for the global economy and broader financial markets. The ultimate fallout and long-term impact
from these events are not known. For more information on the war in Ukraine and its impact on Europe, see “Investment
Objectives, Investment Strategies and Risks — Recent Events” herein.
Investments in Austria. Investments in Austrian issuers may subject the Fund to legal, regulatory, political, currency,
security, and economic risk specific to Austria. The Austrian economy, along with certain other EU economies, hasfrom time to time experienced significant financial market volatility and economic adversity, and certain Austrianbanks required government support in order to avoid potential insolvency and wider regional contagion. In addition, the28Austrian banking sector has significant exposure to Central and Eastern Europe. Eastern European markets remain
relatively undeveloped and can be particularly sensitive to political and economic developments, and adverse eventsin these Eastern European countries may greatly impact the Austrian economy.
Investments in Czech Republic. The Czech Republic’s economy is heavily dependent on the manufacturing andexport of industrial materials and machinery. Key trading partners are member states of the European Union, mostnotably Germany, Spain, Italy, France and the United Kingdom. Decreasing demand for the Czech Republic’s
products and services or changes in governmental regulations on trade may have a significantly adverse effect on
the Czech economy. The Czech Republic and many of the Western European developed nations are member statesof the EU. As a result, these member states are dependent upon one another economically and politically. The recent
ratification of the Treaty of Lisbon by EU member states is expected to further heighten the degree of economic andpolitical interdependence. This and other political or economic developments could cause market disruptions andaffect adversely the values of securities of Czech issuers.
The Czech Republic and surrounding regions have a history of ethnic unrest and conflict. If conflict were to renew inthe future, it could have a significant adverse impact on Czech issuers.
Investments in France. Investments in securities of French issuers involve risks that are specific to France, including
certain legal, regulatory, political, economic, currency and security risks. Interest rates on France’s debt may rise tolevels that make it difficult for it to service high debt levels without significant financial help from, among others,
the European Central Bank and could potentially result in default. In addition, the French economy is dependent to asignificant extent on the economies of certain key trading partners, including Germany and other Western European
countries. Reduction in spending on French products and services, or changes in any of the economies may cause
an adverse impact on the French economy. In addition, France has been subject to acts of terrorism which has
been detrimental to tourism. The French economy is dependent on exports from the agricultural sector. Leading
agricultural exports include dairy products, meat, wine, fruit and vegetables, and fish. As a result, the French economy
is susceptible to fluctuations in demand for agricultural products.
Investments in Italy. Investment in Italian issuers involves risks that are specific to Italy, including, regulatory, political,
currency and economic risks. Italy’s economy is dependent upon external trade with other economies — specificallyGermany, France and other Western European developed countries. As a result, Italy is dependent on the economiesof these other countries and any change in the price or demand for Italy’s exports may have an adverse impact on its
economy. Interest rates on Italy’s sovereign debt may rise to levels that may make it difficult for it to service highdebt levels without significant financial help from the EU and could potentially lead to default. These events haveadversely impacted the Italian economy, causing credit agencies to lower Italy’s sovereign debt rating and could
decrease outside investment in Italian companies.
Investments in Poland. Investment in securities of Polish issuers involves risks not typically associated with investments
in securities of issuers in developed countries. Such heightened risks include, among others, a relatively short historyof democracy, expropriation and/or nationalization of assets, confiscatory taxation, less publicly available financial
and other information, and potential difficulties in enforcing contractual obligations. In addition, Poland faces many
economic development problems, including high unemployment, inadequate infrastructure, endemic corruption,
poverty, and intensifying global competition from neighboring countries.
Securities laws in Poland are relatively new and unsettled and, consequently, there is a risk of rapid and unpredictablechange in laws regarding foreign investment, securities regulation, custody and title to securities and shareholder
rights. Accordingly, foreign investors may be adversely affected by new or amended laws and regulations. In
circumstances where adequate laws and shareholder rights exist, it may not be possible to obtain swift and equitable
enforcement of the law.
The securities market of Poland is considered an emerging market characterized by a small number of listed companies
and a relatively illiquid secondary trading market, particularly for corporate bonds. These factors, coupled withrestrictions on foreign investment and other factors, limit the supply of securities available for investment by a Fund.
This will affect the rate at which a Fund is able to invest in Poland, the purchase and sale prices for such securities
and the timing of purchases and sales.

29

The government in Poland may restrict or control to varying degrees the ability of foreign investors to invest in
securities of issuers located or operating in Poland. Moreover, governmental approval or special licenses prior toinvestments by foreign investors may be required and may limit the amount of investments by foreign investors
in a particular industry and/or issuer. A delay in obtaining a required government approval or license would delay
investments in Poland, and, as a result, a Fund may not be able to invest in certain securities while approval is pending.
The government of Poland may also withdraw or decline to renew a license that enables a Fund to invest in Poland.
Any one of these factors could cause a decline in the value of a Fund.
The Polish government may exercise substantial influence over many aspects of the private sector and may own orcontrol many companies. Future government actions could have a significant effect on the economic conditions in
Poland, which could have a negative impact on private sector companies. There is also the possibility of diplomaticdevelopments that could adversely affect investments in Poland.
The market for Polish securities is directly influenced by the flow of international capital, and economic and market
conditions of certain countries, especially emerging market countries in Eastern Europe. Adverse economic conditions
or developments in other emerging market countries have at times significantly affected the availability of credit in
the Polish economy and resulted in considerable outflows of funds and declines in the amount of foreign currency
invested in Poland.
Investments in Spain. Investment in Spanish issuers involves risks that are specific to Spain, including, legal,
regulatory, political, currency, security and economic risks. The Spanish economy, along with certain other EU
economies, experienced a significant economic slowdown during the financial crisis that began in 2008. In reaction
to the crisis, the Spanish government introduced austerity reforms aimed at reducing its fiscal deficit to sustainablelevels. Austerity reforms included, among other things, reduction in government employees’ salaries, freezing ofpension funds, and suspension of public work projects. Such austerity reforms, while directed at stimulating the
Spanish economy in the long-term, may have a negative short-term effect on Spain’s financial markets. Due largely
to outstanding bad loans to construction companies and real estate developers, Spanish banks underwent a series ofmergers to increase liquidity and made efforts to shift debt off of their balance sheets. However, reports indicate thatdebt levels remain high, although bank lending has contracted. In addition, unemployment rates remain high. These
factors could adversely impact growth potential of Spanish stocks in which the Fund invests. In addition, the Spanish
government is engaged in a long-running campaign against terrorism. Acts of terrorism on Spanish soil or against
Spanish interests abroad may cause uncertainty in the Spanish financial markets and adversely affect the performanceof the issuers to which the Fund has exposure. Political tensions and social conflict have escalated recently as a resultof a referendum by Catalonia for independence from Spain. The secessionist movement could have a negative impact
on the Spanish economy and a destabilizing effect on the country.
Investments in the United Kingdom. The UK trades heavily with other European countries and the United States andmay be impacted by changes to the economic health of their key trading partners. The UK also relies heavily on theexport of financial services. Accordingly, a slowdown in the financial services sector may have an adverse impact on
the UK’s economy. On January 31, 2020, the UK formally exited the EU. For more information about “Brexit” andthe associated risks, see the above description of “Europe Risk.”
Foreign Currency Transactions
The Fund may hold funds in bank deposits in U.S. or foreign currency, including during the completion of investment programs.
For additional currency exposure, the Fund may also conduct currency exchange transactions either on a spot (cash) basis at
the spot rate prevailing in the foreign exchange market or by entering into a forward currency contract. These transactions will
expose the Fund to foreign currency fluctuations.
The prediction of currency movements is extremely difficult and the successful execution of a speculative strategy is highly
uncertain. Should exchange rates move in an unexpected manner, the Fund may not achieve the anticipated benefits of thetransaction, or it may realize losses. The successful use of forward currency contracts will usually depend on Cambria’s ability
to forecast accurately currency exchange rate movements and its skill in analyzing and predicting currency values. There is
no assurance that Cambria’s use of forward currency contracts will be advantageous to the Fund or that Cambria will hedge
exposures at an appropriate time. The precise matching of forward contract amounts and the value of the securities involved
is generally not possible because the value of such securities, measured in the foreign currency, will change after the forward
currency contract has been established. The projection of short-term currency market movements is extremely difficult, and30

the successful execution of a short-term hedging strategy is highly uncertain. Further, under certain circumstances, the Fund
may have to limit its currency transactions to qualify as a RIC under the Code or to maintain its exception from registration as
a commodity pool operator under the CEA.
Forward contracts may be considered “derivatives” — financial instruments whose performance is derived, at least in part,from the performance of another asset (such as a security, currency or an index of securities). A forward currency contract
involves an obligation to purchase or sell a specific amount of a specific currency at a future date, which may be any fixed
number of days (usually less than one year) from the date of the contract agreed upon by the parties, at a price set at the timeof the contract.
At or before settlement of a forward currency contract, the Fund may either deliver the currency or terminate its contractual
obligation to deliver the currency by purchasing an offsetting contract; or, if the forward currency contract is cash settled,
pay or receive the difference between it and its counterparty’s obligations under the contract. If the Fund makes delivery of acurrency at or before the settlement of a forward contract, it may be required to obtain the currency through the conversion ofassets into the currency. The Fund may close out a forward contract obligating it to purchase currency by selling an offsetting
contract. If the Fund engages in an offsetting transaction, it may later enter into a new forward currency contract to sell thecurrency. If the Fund engages in an offsetting transaction, it will incur a gain or loss to the extent that there has been movement
in forward currency contract prices.
Forward currency contracts have historically been individually negotiated and privately traded by currency traders and theircustomers, though in the future they may become centrally cleared. These contracts may result in a loss if a counterparty,
including a central clearing agency, does not perform as expected or becomes insolvent. In the event of insolvency of acounterparty, the Fund might be unable to close out a forward currency contract at any time prior to maturity or, even if itentered an offsetting transaction with a second counterparty, the Fund would continue to be subject to settlement risk relating
to the transaction with the insolvent counterparty.
The Fund may enter into forward contracts for a variety of reasons, including hedging and extracting investment returns.
Hedging. With respect to hedging, the Fund may invest in forward currency contracts to hedge either specifictransactions (transaction hedging) or portfolio positions (position hedging). Transaction hedging is the purchase orsale of forward currency contracts with respect to specific receivables or payables of the Fund in connection with thepurchase and sale of portfolio securities. Position hedging is the sale of a forward currency contract on a particularcurrency with respect to portfolio positions denominated or quoted in that currency.
Position hedging and transaction hedging generally involve the Fund seeking to “lock in” the exchange rate between
currencies. For example, if the Fund owned securities denominated in euros, to effectuate a position hedge, it could
enter into a forward currency contract to sell euros in return for U.S. dollars to hedge against possible declines inthe euro’s value. Such a hedge would tend to offset both positive and negative currency fluctuations, but would notoffset changes in security values caused by other factors. The Fund could also hedge the position by selling anothercurrency expected to perform similarly to the euro. This type of hedge, sometimes referred to as a proxy hedge, could
offer advantages in terms of cost, yield or efficiency, but generally would not hedge currency exposure as effectively
as a simple hedge into U.S. dollars. Proxy hedges may result in losses if the currency used to hedge does not perform
similarly to the currency in which the hedged securities are denominated.
Purchasing a forward currency contract to lock in the U.S. dollar price of a security denominated in a foreign currency
that the Fund intends to acquire may serve as a long hedge. Alternatively, selling a forward currency contract tolock in the U.S. dollar equivalent of the proceeds from the anticipated sale of a security or a dividend or interest
payment denominated in a foreign currency may serve as a short hedge. Currency hedges do not protect against pricemovements in the securities that are attributable to other causes.
The Fund might seek to hedge against changes in the value of a particular currency when no forward currency
contracts on that currency are available or such forward currency contracts are more expensive than certain otherderivative instruments. In such cases, the Fund may seek to hedge against price movements in that currency byentering into transactions using forward currency contracts on another currency or a basket of currencies, the valuesof which Cambria believes will have a high degree of positive correlation to the value of the currency being hedged.
The risk that movements in the price of the forward currency contract will not correlate perfectly with movements inthe price of the currency subject to the hedging transaction is magnified when this strategy is used.

31

The Fund is not obligated to actively engage in currency hedging transactions; therefore, the Fund may not attempt
to hedge its exposure to a particular foreign currency at a time when doing so might have avoided a loss. Further, theFund may not be able to hedge against a currency devaluation that is so generally anticipated that the Fund is unable
to contract to sell the currency at a price above the devaluation level it anticipates.
Investing. The Fund may invest in a combination of (i) forward foreign currency contracts and U.S. dollar-denominatedinstruments or (ii) forward currency contracts and non-U.S. dollar-denominated instruments to seek performancethat is substantially the same as a direct investment in a foreign currency-denominated instrument. This investment
technique creates a “synthetic” position in the particular foreign-currency instrument whose performance Cambria istrying to duplicate. For example, the combination of U.S. dollar-denominated ETFs or money market instruments with“long” forward currency exchange contracts creates a position economically equivalent to an instrument denominatedin the foreign currency itself.
The Fund also may use forward currency contracts to attempt to enhance income or yield. The Fund could use forward
currency contracts to increase its exposure to foreign currencies that Cambria believes might rise in value relative
to the U.S. dollar, or shift its exposure to foreign currency fluctuations from one country to another. For example,
if the Fund owned securities denominated in a foreign currency and Cambria believed that currency would decline
relative to another currency, it might enter into a forward currency contract to sell an appropriate amount of the firstforeign currency, with payment to be made in the second foreign currency. This is accomplished through contractual
agreements to purchase or sell a specified currency at a specified future date and price set at the time of the contract.
Forward currency contracts may involve the sale of U.S. dollars and the purchase of a foreign currency, or may beforeign cross-currency contracts involving the sale of one foreign currency and the purchase of another foreign
currency. Such foreign cross-currency contracts may be considered a hedging strategy rather than a speculative
strategy if the Fund’s commitment to purchase the new (more favorable) currency is limited to the market value of theFund’s securities denominated in the old (less favorable) currency.
With respect to transactions not entered into for hedging purposes, the Fund’s custodian bank maintains, in a separate
account of the Fund, liquid assets, such as cash, short-term securities and other liquid securities (marked to the market
daily), having a value equal to, or greater than, any commitments to purchase currency on a forward basis.
Normally, consideration of the prospect for currency parities will be incorporated into the longer term investment
decisions made with regard to overall diversification strategies. However, Cambria believes that it is important to havethe flexibility to enter into such forward currency contracts when it determines that the best interests of the Fund will
be served.
Conversion. Although the Fund values its assets daily in U.S. dollars, it does not convert its holdings of foreign
currencies into U.S. dollars on a daily basis. The Fund will convert its holdings from time to time, however, and incur
the costs of currency conversion. Foreign exchange dealers do not charge a fee for conversion, but they do realize aprofit based on the difference between the prices at which they buy and sell various currencies. Thus, a dealer may
offer to sell a foreign currency to the Fund at one rate, and offer to buy the currency at a lower rate if the Fund tries
to resell the currency to the dealer.
Settlement of transactions involving foreign currencies might be required to take place within the country issuing theunderlying currency. Thus, the Fund might be required to accept or make delivery of the underlying foreign currency
in accordance with any U.S. or foreign regulations regarding the maintenance of foreign banking arrangements by
U.S. residents and might be required to pay any fees, taxes and charges associated with such delivery assessed in theissuing country.
The value of the Fund’s investments is calculated in U.S. dollars each day that the NYSE is open for business. As
a result, to the extent that the Fund’s assets are invested in instruments denominated in foreign currencies and thecurrencies depreciate relative to the U.S. dollar, the Fund’s NAV per share as expressed in U.S. dollars (and, therefore,
the value of your investment) should decrease. If the U.S. dollar appreciates relative to the other currencies, theopposite should occur.

32

The currency-related gains and losses experienced by the Fund will be based on changes in the value of portfolio
securities attributable to currency fluctuations only in relation to the original purchase price of such securities asstated in U.S. dollars. Gains or losses on shares of the Fund will be based on changes attributable to fluctuations in
the NAV of such shares, expressed in U.S. dollars, in relation to the original U.S. dollar purchase price of the shares.
The amount of appreciation or depreciation in the Fund’s assets also will be affected by the net investment income
generated by the money market instruments in which the Fund invests and by changes in the value of the securities
that are unrelated to changes in currency exchange rates.
Foreign currency transactions occurring in the interbank market might involve substantially larger amounts thanthose involved in the use of such forward currency contracts. Therefore, the Fund could be disadvantaged by having
to deal in the odd lot market (generally consisting of transactions of less than $1 million) for the underlying foreign
currencies at prices that are less favorable than for round lots. There is no systematic reporting of last sale information
for foreign currencies or any regulatory requirement that quotations available through dealers or other market sources
be firm or revised on a timely basis. Quotation information generally is representative of very large transactions in theinterbank market and thus might not reflect odd-lot transactions where rates might be less favorable. The interbank
market in foreign currencies is a global, round-the-clock market. To the extent the U.S. options or futures markets
are closed while the markets for the underlying currencies remain open, significant price and rate movements mighttake place in the underlying markets that cannot be reflected in the markets for the forward currency contracts until
they reopen.
Foreign Government Securities
Foreign government securities include securities issued or guaranteed by foreign governments (including political subdivisions)or their authorities, agencies, or instrumentalities or by supra-national agencies. Different kinds of foreign government
securities have different kinds of government support. For example, some foreign government securities are supported by thefull faith and credit of a foreign national government or political subdivision and some are not. Foreign government securities
of some countries may involve varying degrees of credit risk as a result of financial or political instability in those countries
or the possible inability of the Fund to enforce its rights against the foreign government. As with issuers of other fixed income
securities, sovereign issuers may be unable or unwilling to make timely principal or interest payments.
It is possible that the availability and the marketability (that is, liquidity) of the securities discussed in this section could be
adversely affected by actions of foreign governments to tighten the availability of credit.
Supra-national agencies are agencies whose member nations make capital contributions to support the agencies’ activities.
Examples include the International Bank for Reconstruction and Development (the World Bank), the Asian Development
Bank, the European Union, and the Inter-American Development Bank.
As with other fixed income securities, foreign government securities expose their holders to market risk because their values
typically change as interest rates fluctuate. For example, the value of foreign government securities may fall during times ofrising interest rates. Yields on foreign government securities tend to be lower than those of corporate securities of comparable
maturities.
In addition to investing directly in foreign government securities, the Fund may purchase certificates of accrual or similar
instruments evidencing undivided ownership interests in interest payments and/or principal payments of foreign government
securities. Certificates of accrual and similar instruments may be more volatile than other government securities.
India Risk
Government actions, bureaucratic obstacles and inconsistent economic reform within the Indian government have had asignificant effect on the Indian economy and could adversely affect market conditions, economic growth and the profitabilityof private enterprises in India. Global factors and foreign actions may inhibit the flow of foreign capital on which India isdependent to sustain its growth. Large portions of many Indian companies remain in the hands of their founders (including
members of their families). Corporate governance standards of family-controlled companies may be weaker and lesstransparent, which increases the potential for loss and unequal treatment of investors. India experiences many of the risks
associated with developing economies, including relatively low levels of liquidity, which may result in extreme volatility inthe prices of Indian securities.

33

Religious, cultural and military disputes persist in India and between India and Pakistan (as well as sectarian groups withineach country). Both India and Pakistan have tested nuclear arms, and the threat of deployment of such weapons could hinderdevelopment of the Indian economy, and escalating tensions could impact the broader region, including China.
Latin America Risk
Latin America, including Brazil and Chile, has long suffered from political, economic, and social instability. For investors, thishas meant additional risk caused by periods of regional conflict, political corruption, totalitarianism, protectionist measures,
nationalization, hyperinflation, debt crises and defaults, sudden and large currency devaluation, and intervention by the
military in civilian and economic spheres. For example, the government of Brazil imposes a tax on foreign investment inBrazilian stocks and bonds, which may affect the value of the Fund’s investments in Brazilian issuers. While some Latin
American governments have experienced privatization of state-owned companies and relaxation of trade restrictions, futurefree-market economic reforms are uncertain, and political unrest could result in significant disruption in securities markets
in the region. The economies of certain Latin American countries have experienced high interest rates, economic volatility,
inflation and high unemployment rates. Adverse economic events in one country may have a significant adverse effect on other
Latin American countries.
Commodities (such as oil, gas and minerals) represent a significant percentage of the region’s exports and many economies inthis region are particularly sensitive to fluctuations in commodity prices. Some markets are in areas that have historically beenprone to natural disasters or are economically sensitive to environmental events, and a natural disaster could have a significant
adverse impact on the economies in the geographic region.
Many Latin American countries have high levels of debt, which may stifle economic growth, contribute to prolonged periodsof recession and adversely impact the Fund’s investments. Most countries have been forced to restructure their loans or risk
default on their debt obligations. Interest on debt is subject to market conditions and may reach levels that would impair
economic activity and create a difficult and costly environment for borrowers. Governments may be forced to reschedule or
freeze their debt repayment, which could negatively affect local markets.
Mexico Risk
Investment in Mexican issuers involves risks that are specific to Mexico, including regulatory, political, currency andeconomic risks. The Mexican economy is dependent upon trade with other economies, specifically with the U.S. andcertain Latin American countries. As a result, Mexico is dependent on, among other things, the U.S. economy, and anychange in the price or demand for Mexican exports may have an adverse impact on the Mexican economy. For example,
lower oil prices have negatively impacted Petróleos Mexicanos, the Mexican state-owned petroleum company, which
accounts for a significant percentage of the Mexican government’s tax revenue. Mexico has experienced adverse
economic impacts as a result of earthquakes and hurricanes, as well as outbreaks of violence. Incidents involving
Mexico’s security may have an adverse effect on the Mexican economy and cause uncertainty in its financial markets.
In the past, Mexico has experienced high interest rates, economic volatility and high unemployment rates.
Political and Social Risk. Mexico has been destabilized by local insurrections, social upheavals and violence related
to drug cartels and other organized crime, and the recurrence or continuation of these or similar conditions may
adversely impact the Mexican economy. Recently, Mexican elections have been contentious and have been very
closely decided. Changes in political parties or other Mexican political events may affect the economy and cause
instability.
Currency Instability Risk. Historically, Mexico has experienced substantial economic instability resulting from,among other things, periods of very high inflation and significant devaluations of the Mexican currency, the peso.
Relations with the U.S. Recent political developments in the U.S. have raised potential implications for the current
trade arrangements between the U.S. and Mexico, which could negatively affect the value of securities held by the
Fund.
Colombia Risk
Investments in Colombian issuers and companies that have significant operations in Colombia subject the Fund tolegal, regulatory, political, currency and economic risks specific to Colombia. Economic reforms, including tax,
pension and budget reforms, and the aggressive promotion of free trade agreements with a number of countries,
including the U.S., Canada, Chile, Mexico, Switzerland, the EU countries, Venezuela, South Korea, Turkey, Japanand Israel, have led to recent economic growth in the Colombian economy. There can be no assurance that these34

economic reforms will continue or that they will be effective. There can also be no assurance that the economic
growth rate will be maintained. The Colombian economy depends heavily on oil, coal and other commodity
exports, making it vulnerable to commodity prices. High unemployment and underemployment, income disparity,
currency devaluations and high levels of debt and public spending remain significant challenges to the Colombian
economy. The level of violence associated with internal conflicts and drug trafficking has fallen but remains high byinternational standards. Colombia’s infrastructure requires major improvements to sustain economic expansion. In
addition, the market for Colombian issuers is directly influenced by the flow of international capital and economic
and market conditions of certain countries, especially the U.S. and other countries in Central and South America.
Middle East Risk
Many Middle Eastern countries are prone to political turbulence, which may have an adverse impact on the Fund. Many
economies in the Middle East are highly reliant on income from the sale of oil or trade with countries involved in the sale of oil,and their economies are therefore vulnerable to changes in the market for oil and foreign currency values. As global demandfor oil fluctuates, many Middle Eastern economies may be significantly impacted.
In addition, many Middle Eastern governments have exercised and continue to exercise substantial influence over many aspectsof the private sector. In certain cases, a Middle Eastern country’s government may own or control many companies, including
some of the largest companies in the country. Accordingly, governmental actions in the future could have a significant effecton economic conditions in Middle Eastern countries. This could affect private sector companies and the Fund, as well as thevalue of securities in the Fund’s portfolio.
Certain Middle Eastern markets are in the earliest stages of development. As a result, there may be a high concentration ofmarket capitalization and trading volume in a small number of issuers representing a limited number of industries, as well
as a high concentration of investors and financial intermediaries. Brokers in Middle Eastern countries typically are fewer innumber and less well capitalized than brokers in the United States.
The legal systems in certain Middle Eastern countries also may have an adverse impact on the Fund. For example, the potential
liability of a shareholder in a U.S. corporation with respect to acts of the corporation generally is limited to the amount of theshareholder’s investment. However, the notion of limited liability is less clear in certain Middle Eastern countries. The Fund
therefore may be liable in certain Middle Eastern countries for the acts of a corporation in which it invests for an amountgreater than its actual investment in that corporation. Similarly, the rights of investors in Middle Eastern issuers may be more
limited than those of shareholders of a U.S. corporation. It may be difficult or impossible to obtain or enforce a legal judgment
in a Middle Eastern country. Some Middle Eastern countries prohibit or impose substantial restrictions on investments in theircapital markets, particularly their equity markets, by foreign entities such as the Fund. For example, certain countries may
require governmental approval prior to investment by foreign persons or limit the amount of investment by foreign persons in
a particular issuer. Certain Middle Eastern countries may also limit the investment by foreign persons to only a specific classof securities of an issuer that may have less advantageous terms (including price) than securities of the issuer available forpurchase by nationals.
The manner in which foreign investors may invest in companies in certain Middle Eastern countries, as well as limitations on
those investments, may have an adverse impact on the operations of the Fund. For example, in certain of these countries, theFund may be required to invest initially through a local broker or other entity and then have the shares that were purchased
re-registered in the name of the Fund. Re-registration in some instances may not be possible on a timely basis. This may
result in a delay during which the Fund may be denied certain of its rights as an investor, including rights as to dividends or
to be made aware of certain corporate actions. There also may be instances where the Fund places a purchase order but issubsequently informed, at the time of re-registration, that the permissible allocation of the investment to foreign investors has
been filled.
Substantial limitations may exist in certain Middle Eastern countries with respect to the Fund’s ability to repatriate investment
income or capital gains. The Fund could be adversely affected by delays in, or a refusal to grant, any required governmental
approval for repatriation of capital, as well as by the application to the Fund of any restrictions on investment.
Certain Middle Eastern countries may be heavily dependent upon international trade and, consequently, have been and may
continue to be negatively affected by trade barriers, exchange controls, managed adjustments in relative currency values andother protectionist measures imposed or negotiated by the countries with which they trade. These countries also have been andmay continue to be adversely impacted by economic conditions in the countries with which they trade. In addition, certain
issuers located in Middle Eastern countries in which the Fund invests may operate in, or have dealings with, countries subject

35

to sanctions and/or embargoes imposed by the U.S. government and the United Nations, and/or countries identified by the
U.S. government as state sponsors of terrorism. As a result, an issuer may sustain damage to its reputation if it is identified as
an issuer which operates in, or has dealings with, such countries. The Fund, as an investor in such issuers, will be indirectly
subject to those risks.
Certain Middle Eastern countries have strained relations with other Middle Eastern countries due to territorial disputes,
historical animosities or defense concerns, which may adversely affect the economies of these Middle Eastern countries.
Certain Middle Eastern countries experience significant unemployment, as well as widespread underemployment. Recently,
many Middle Eastern countries have experienced political, economic and social unrest as protestors have called for widespreadreform. These protests may adversely affect the economies of these Middle Eastern countries.
Russia Risk
As a result of recent events involving Ukraine and the Russian Federation, the United States, Canada, the European Union,
Japan, the United Kingdom, and other Western countries have imposed sanctions on certain Russian individuals, corporate
entities and large financial institutions. The United States has imposed additional sanctions on Russia as a result of Russia’sinterference in the U.S. election in 2016 and its use of chemical weapons in 2018 and 2020 to attack Aleksey Navalny and Sergei
Skripal, respectively, each a Russian opposition figure. More recently, in response to Russia’s military invasion of Ukraine
in February 2022, the United States, the European Union, Canada, the United Kingdom, Japan and other countries leviedmore stringent economic sanctions against Russia. See “Investment Objectives, Investment Strategies and Risks — Recent
Events” herein. The United States and other nations or international organizations may impose additional, broader economic
sanctions or take other actions that may adversely affect Russian-related issuers in the future. These sanctions, any future
sanctions or other actions, or even the threat of further sanctions or other actions, may negatively affect the value and liquidityof the Fund’s investments. For example, the Fund may be prohibited from investing in securities issued by Russian companies
subject to such sanctions. In addition, the sanctions may require the Fund to freeze its existing investments in Russiancompanies, prohibiting the Fund from buying, selling or otherwise transacting in these investments. Russia may undertake
countermeasures or retaliatory actions which may further impair the value and liquidity of the Fund’s portfolio and potentiallydisrupt its operations.
These sanctions could negatively impact the Russian economy, resulting in a weaker Russian currency, downgrades in Russia’s
credit rating, and a significant decline in the value and liquidity of Russian securities. Russia’s invasion of Ukraine, thesubsequent war, the world’s response to Russia’s actions through sanctions, and the potential for an escalating military conflict
beyond Ukraine’s borders have increased the volatility in financial markets and could have severe adverse effects on regionaland global economic markets in the future. In particular, the war in Ukraine has had a significant impact on various commodity
markets, including those of oil, natural gas, and agricultural products. These sanctions could impair or eliminate a Fund’sability to invest in accordance with its investment strategy and/or to meet its investment objective. In addition, these sanctions
have required some Funds to stop trading in Russian securities and freeze their existing investments in Russian securities,
thereby prohibiting such Funds from buying, selling, receiving or delivering those securities or other financial instruments.
Further, due to closures of certain markets and restrictions on trading, certain Russian securities held by the Funds have beendifficult to value or valued at zero. It is unknown when, or if, sanctions will be lifted in the future or whether the Funds’ ability
to trade in Russian securities will resume.
For these or other reasons, the Fund could seek to suspend redemptions of Creation Units, including in the event that an
emergency exists in which it is not reasonably practicable for the Fund to dispose of its securities or to determine its NAV. The
Fund could also, among other things, limit or suspend creations of Creation Units. During the period that creations orredemptions are affected, Shares could trade at a significant premium or discount to their NAV. In the case of a period during
which creations are suspended, the Fund could experience substantial redemptions, which may cause the Fund to experience
increased transaction costs and make greater taxable distributions to shareholders of the Fund. The Fund could liquidate all ora portion of its assets, which may be at unfavorable prices.
South Africa Risk
Although South Africa is a developing country with a solid economic infrastructure (in some regards rivaling other developed
countries), certain issues, such as unemployment, access to health care, limited economic opportunity, and other financial
constraints, continue to present obstacles to full economic development. Disparities of wealth, the pace and success of
democratization and capital market development and religious and racial disaffection have also led to social and politicalunrest. South Africa’s currency has recently fluctuated significantly and may be vulnerable to significant devaluation. Therecan be no assurance that initiatives by the government to address these issues will achieve the desired results. South Africa’s
economy is heavily dependent on natural resources and commodity prices. South Africa’s currency may be vulnerable todevaluation. These and other factors could have a negative impact on a Fund’s performance.
36

Turkey Risk
Investments in Turkish issuers are subject to legal, regulatory, political, currency, security and economic risks specific to Turkey.
Among other things, the Turkish economy is heavily dependent on relationships with certain key trading partners, including
EU countries, China and Russia. The Turkish economy has certain significant economic weaknesses, such as its relatively highcurrent account deficit and currency depreciation. Turkey has historically experienced acts of terrorism and strained relations
related to border disputes with certain neighboring countries. The continuation of the conflict on the Turkish-Syrian border,
for example, could have an adverse impact on the Turkish economy. Turkey is subject to considerable degrees of social andpolitical instability. Unanticipated or sudden political, economic or social developments have caused and may cause further
volatility in the Turkish securities markets or currency market and as a result may adversely affect the Fund’s investments.
Illiquid Securities
The Fund may invest up to 15% of its net assets in illiquid securities. For this purpose, “illiquid securities” are securities that
the Fund may not sell or dispose of within seven days in the ordinary course of business at approximately the amount at which
the Fund has valued the securities. A repurchase agreement maturing in more than seven days is considered illiquid, unless it
can be terminated after a notice period of seven days or less.
Cambria also may deem certain securities to be illiquid as a result of Cambria’s receipt from time to time of material, non-public
information about an issuer, which may limit Cambria’s ability to trade such securities for the account of any of its clients,
including the Fund. In some instances, these trading restrictions could continue in effect for a substantial period of time.
At times, the inability to sell illiquid securities can make it more difficult to determine their fair value for purposes of computing
the Fund’s net asset value. The judgment of Cambria normally plays a greater role in valuing these securities than in valuing
publicly traded securities.
Repurchase Agreements
The Fund may enter into repurchase agreements with banks and broker-dealers. A repurchase agreement is an agreement underwhich securities are acquired by the Fund from a securities dealer or bank subject to resale at an agreed upon price on a later
date. The Fund bears a risk of loss in the event that the other party to a repurchase agreement defaults on its obligations andthe Fund is delayed or prevented from exercising its rights to dispose of the collateral securities. Such a default may subject
the Fund to expenses, delays, and risks of loss including: (i) possible declines in the value of the underlying security while theFund seeks to enforce its rights, (ii) possible reduced levels of income and lack of access to income during this period, and(iii) the inability to enforce its rights and the expenses involved in attempted enforcement.
Repurchase agreements may be treated as loans by the SEC staff. The Fund will not enter into repurchase agreements if, as aresult, the aggregate amount of the Fund’s loans would exceed 33 1/3% of its total assets.
Reverse Repurchase Agreements
The Fund may enter into reverse repurchase agreements, which involve the sale of securities held by the Fund subject toits agreement to repurchase the securities at an agreed-upon date or upon demand and at a price reflecting a market rate ofinterest. Reverse repurchase agreements are subject to the Fund’s limitation on borrowings and may be entered into only withbanks or securities dealers or their affiliates. While a reverse repurchase agreement is outstanding, the Fund will maintain the
segregation, either on its records or with the Trust’s custodian, of cash or other liquid securities, marked to market daily, in
an amount at least equal to its obligations under the reverse repurchase agreement. Under the 1940 Act, the Fund may electto treat reverse repurchase agreements either as (i) borrowings subject to the asset coverage requirement of Section 18 of the1940 Act or (ii) derivatives transactions for purposes of Rule 18f-4 under the 1940 Act including, as applicable, the VaR test
to limit leverage risk. Although there is no limit on the percentage of total assets the Fund may invest in reverse repurchaseagreements, the use of reverse repurchase agreements is not a principal strategy of the Fund.
Reverse repurchase agreements involve the risk that the buyer of the securities sold by the Fund might be unable to deliver
them when the Fund seeks to repurchase. If the buyer of securities under a reverse repurchase agreement files for bankruptcy
or becomes insolvent, the buyer or trustee or receiver may receive an extension of time to determine whether to enforce theFund’s obligation to repurchase the securities, and the Fund’s use of the proceeds of the reverse repurchase agreement may
effectively be restricted pending such decision.

37

Securities Lending
The Fund may make secured loans of its portfolio securities; however, securities loans will not be made if, as a result, theaggregate amount of all outstanding securities loans by the Fund exceeds 33 1/3% of its total assets (including the market valueof collateral received). For purposes of complying with the Fund’s investment policies and restrictions, collateral received inconnection with securities loans is deemed an asset of the Fund to the extent required by law. The Fund continues to receive
dividends or interest, as applicable, on the securities loaned and simultaneously earns either interest on the investment of the
cash collateral or fee income if the loan is otherwise collateralized.
To the extent the Fund engages in securities lending, securities loans will be made to broker-dealers that Cambria believes to beof relatively high credit standing pursuant to agreements requiring that the loans continuously be collateralized by cash, liquid
securities, or shares of other investment companies with a value at least equal to the market value of the loaned securities. As
with other extensions of credit, the Fund bears the risk of delay in the recovery of the securities and of loss of rights in thecollateral should the borrower fail financially. The Fund also bears the entire risk of loss on any reinvested collateral received
in connection with securities lending.
Voting rights or rights to consent with respect to the loaned securities pass to the borrower. The Fund has the right to call loans
at any time on reasonable notice. However, the Fund bears the risk of delay in the return of the security, impairing the Fund’sability to vote on such matters. Cambria will retain lending agents on behalf of the Fund based on a percentage of the Fund’s
return on its securities lending. The Fund may also pay various fees in connection with securities loans, including shipping fees
and custodian fees. The costs of lending securities are not reflected in the Fund’s Annual Fund Operating Expenses.
Short Sales
A short sale is a transaction in which the Fund sells a security it does not own. To complete such a transaction, the Fund must
borrow the security to make delivery to the buyer. The Fund is then obligated to replace the security borrowed by borrowing thesame security from another lender, purchasing it at the market price at the time of replacement or paying the lender an amountequal to the cost of purchasing the security. The price at such time may be more or less than the price at which the security wassold by the Fund. Until the security is replaced, the Fund is required to repay the lender any dividends it receives, or interest
which accrues, during the period of the loan. To borrow the security, the Fund also may be required to pay a premium, which
would increase the cost of the security sold. The net proceeds of the short sale will be retained by the broker, to the extent
necessary to meet margin requirements, until the short position is closed out. The Fund also will incur transaction costs ineffecting short sales.
Whenever the Fund engages in short sales, it earmarks or segregates liquid securities or cash in an amount that, when combinedwith the amount of collateral deposited with the broker in connection with the short sale (other than the proceeds of the shortsale), equals the current market value of the security sold short. The earmarked or segregated assets are marked-to-market
daily.
The Fund will incur a loss as a result of a short sale if the price of the security increases between the date of the short sale andthe date on which the Fund replaces the borrowed security. The Fund will realize a gain if the price of the security declines inprice between those dates. The amount of any gain will be decreased, and the amount of any loss increased, by the amount of
the premium, dividends or interest the Fund may be required to pay, if any, in connection with a short sale. Short sales may besubject to unlimited losses as the price of a security can rise infinitely.

38

PORTFOLIO TURNOVER“Portfolio Turnover Rate” is defined under the rules of the SEC as the lesser of the value of the securities purchased or of the
securities sold, excluding all securities whose maturities at the time of acquisition were one-year or less, divided by the averagemonthly value of such securities owned during the year. Based on this definition, instruments with a remaining maturity ofless than one-year are excluded from the calculation of the portfolio turnover rate. Instruments excluded from the calculationof portfolio turnover generally would include the futures contracts and option contracts in which a Fund invests because suchcontracts generally have a remaining maturity of less than one-year.
The value of portfolio securities received or delivered as a result of in-kind creations or redemptions of each Fund’s shares also
is excluded from the calculation of the Fund’s portfolio turnover rate. As a result, each Fund’s reported portfolio turnover may
be low despite relatively high portfolio activity which would, in turn, produce correspondingly greater expenses for the Fund,
including brokerage commissions or dealer mark-ups and other transaction costs on the sale of securities and reinvestments
in other securities. Generally, the higher the rate of portfolio turnover of a fund, the higher these transaction costs borne by
the fund and its long-term shareholders. Such sales may result in the realization of taxable capital gains (including short-term
capital gains, which, when distributed, are generally taxed to shareholders at ordinary income tax rates).
The following table reflects the portfolio turnover rate for each Fund for the fiscal periods and/or years ended April 30, 2023
and 2024.

Fund
Cambria Shareholder Yield ETF
Cambria Foreign Shareholder Yield ETF
Cambria Global Value ETF
Cambria Global Momentum ETF3
Cambria Global Asset Allocation ETF
Cambria Value and Momentum ETF
Cambria Global Tail Risk ETF4
Cambria Emerging Shareholder Yield ETF
Cambria Tail Risk ETF5
Cambria Trinity ETF
Cambria Cannabis ETF
Cambria Global Real Estate ETF
Cambria Micro and SmallCap Shareholder Yield
ETF
Cambria Tactical Yield ETF
Cambria LargeCap Shareholder Yield ETF
1
2
3

4

5

2023
41%
34%
94%
307%
0%
71%
62%
43%
129%
102%
23%
94%

2024﻿
50%﻿
44%﻿
36%﻿
166%﻿
13%﻿
63%﻿
3%﻿
32%﻿
13%﻿
69%﻿
13%﻿
77%﻿

Commencement of
Operations1
May 14, 2013
Dec. 3, 2013
Mar. 12, 2014
Nov. 4, 2014
Dec. 10, 2014
Sept. 9, 2015
Feb. 23, 2016
July 14, 2016
Apr. 6, 2017
Sept. 10, 2018
July 24, 2019
Sept. 24, 2020

N/A
N/A
N/A

8%2
0%2
N/A

Jan. 5, 2024
Jan. 5, 2024
July 12, 2024

Each Fund typically commences operations one Business Day after its inception date.
For the period from the Fund’s commencement of operations to April 30, 2024.
During the fiscal year ended April 30, 2024, the Cambria Global Momentum ETF, which rebalances monthly pursuing asystematic trend and momentum strategy, experienced lower turnover due to changes in market conditions and momentum
factor persistence.
During the fiscal year ended April 30, 2024, the Cambria Global Tail Risk ETF experienced lower portfolio turnover due todecreased activity in the Fund.
During the fiscal year ending April 30, 2024, the Cambria Tail Risk ETF experienced lower portfolio turnover due primarily
to the Treasury component roll.

39

MANAGEMENT OF THE FUNDS
Trustees and Officers
The business and affairs of the Trust are managed by its officers under the oversight of its Board. The Board sets broad policies
for the Trust and may appoint Trust officers. The Board oversees the performance of Cambria and the Trust’s other service
providers. Each Trustee serves until his or her successor is duly elected or appointed and qualified.
The Board is comprised of four Trustees. One Trustee and certain of the officers of the Trust are directors, officers or employees
of Cambria. The other Trustees are not “interested persons” (as defined in Section 2(a)(19) of the Investment Company Act)of the Trust (the “Independent Trustees”). The fund complex includes all funds advised by Cambria (the “Fund Complex”).
The Trustees, their age (by year of birth), term of office and length of time served, their principal business occupations during
the past five years, the number of portfolios in the Fund Complex overseen and other directorships, if any, held by each
Trustee, are shown below. The officers, their age (by year of birth), term of office and length of time served and their principal
business occupations during the past five years, are shown below. Unless noted otherwise, the address of each Trustee and each
Officer is: c/o Cambria ETF Trust, 3300 Highland Avenue, Manhattan Beach, CA 90266.
Trustees

Name and Yearof Birth
Interested Trustee*
Mebane Faber
YOB: 1977

Position(s) Heldwith Trust, Term of
Office, and Lengthof Time Served
Chairperson of theBoard, Trustee, andPresident of the Trust
since 2018; Vice
President of the Trust(2013 – 2018); no set
term

Independent Trustees
Cullen Roche
Trustee; no set term
YOB: 1980

Dennis G. Schmal
YOB: 1947

Trustee since 2013;
no set term

Numberof Funds
in FundComplexPrincipal Occupation Overseen
During Past 5 Years by Trustee

Other Directorships
Held by Trustee

Co-Founderand Chief
Investment Officer(2006 – present),
Chief Executive
Officer(2018 – present),
Cambria Investment
Management, L.P.

15﻿

None.

Founder and Chief
Investment Officer,
Orcam Financial
Group, d/b/a
Discipline Funds(investment firm)(2012 – present).
Retired.

15﻿

None.

15﻿

Trustee, AssetMark Mutual Funds(since 2007); Trustee, Wells Fargo
GAI Hedge Funds (2007 – 2019);
Director and Chairman, Owens
Realty Mortgage Inc. (real estate)(2013 – 2019); Director, Blue Calypso(e-commerce) (2015 – 2018).

40

Name and Yearof BirthThomas (Taz) M.
Turner, Jr.**
YOB: 1977

Position(s) Heldwith Trust, Term of
Office, and Lengthof Time Served
Trustee; no set term

Numberof Funds
in FundComplexPrincipal Occupation Overseen
Other Directorships
During Past 5 Years by Trustee
Held by Trustee
Founder and Portfolio
15﻿
Chairman and Chief Executive
Manager, Southshore
Officer, CordovaCann Inc.
Capital Partners(Canadian-domiciled cannabis retail)(investment firm)(since 2017).
(since 2010).

*

Mr. Faber is an “interested person,” as defined by the Investment Company Act, because of his employment with andownership interest in Cambria.
** Messrs. Faber and Turner are first cousins, but they are not immediate family members for the purpose of identifying“interested persons” of the Trust as defined in the 1940 Act.
Officers

Name and Year of Birth
Aaron Perkovich﻿
YOB: 1973﻿

Position(s) Held with Trust,Term of Office, and Length ofTime Served
Treasurer and Principal Financial
Officer since Sept. 2023; no set
term﻿

Jonathan Keetz
YOB: 1988

Vice President since Nov. 2020;
no set term

Douglas Tyre
YOB: 1980

Chief Compliance Officer since
May 2018; no set term

Principal Occupation
During Past 5 Years
Head of Fund Administration (since 2023), Fund
Administration Manager (2022 – 2023), Tidal ETF
Services LLC; Assistant Director — Investments,
Mason Street Advisors, LLC (2021 – 2022); Vice
President, U.S. Bancorp Fund Services, LLC(2006 – 2021).
Chief Operating Officer (since 2020), Portfolio
Manager (since 2024), and Vice President(2015 – 2020), Cambria Investment Management,
L.P.
Senior Principal Consultant, ACA Group,
Compliance (May 2022 – Present); ComplianceDirector, Foreside Financial Group, LLC(April 2022 – May 2022); Compliance Director(2019 – 2022), Assistant Compliance Director(2018 – 2019) and Manager (2014 – 2017),
Cipperman Compliance Services, LLC.

Additional Information About the Trustees
The following provides information additional to that set forth in the table above regarding other relevant qualifications,experience, attributes or skills applicable to each Trustee.
Mebane Faber: Mr. Faber has extensive experience in the investment management industry, including as a portfolio
manager, an author of multiple investment strategy books, and host of his own wealth management podcast.
Cullen Roche: Mr. Roche has extensive experience in the investment management industry, including as a portfolio
manager and an author well-known for his research on the monetary system and portfolio construction. He is the founderand Chief Investment Officer of an SEC-registered investment adviser, and he serves as the portfolio manager for thefirm’s exchange-traded fund. Mr. Roche has consulted on portfolio management as a discretionary and non-discretionary
advisor for over 15 years.

41

Dennis G. Schmal: Mr. Schmal has extensive experience in the investment management industry, including as a memberof senior management of the investment company audit practice at a large public accounting firm, as well as service on
multiple boards of directors overseeing public companies, registered investment companies and private companies andfunds.
Taz Turner: Mr. Turner has extensive experience in the investment management industry, including over 20 years ofexperience investing in global equity and debt securities in both public and private markets on behalf of various hedge
funds and private equity firms. In 2010, he founded the investment firm Southshore Capital Partners, and he serves as
the firm’s General Partner and portfolio manager for the firm’s global investment fund.
The Board has determined that each Trustee on an individual basis and in combination with the other Trustees is qualified to serve,and should serve, on the Board. To make this determination the Board considered a variety of criteria, none of which in isolation
was controlling. Among other things, the Board considered each Trustee’s experience, qualifications, attributes and skills.
Board Structure
Mr. Faber is considered to be an Interested Trustee and serves as Chairman of the Board. The Chairman’s responsibilities
include: setting an agenda for each meeting of the Board; presiding at all meetings of the Board and, if present, meetings of the
Independent Trustees; and, serving as a liaison between the other Trustees, Trust officers, management personnel and counsel.
The Board believes that having an interested Chairman, who is familiar with Cambria and its operations, while also having
two-thirds of the Board composed of Independent Trustees, strikes an appropriate balance that allows the Board to benefit fromthe insights and perspective of a representative of management while empowering the Independent Trustees with the ultimate
decision-making authority. The Board has not appointed a lead Independent Trustee at this time. The Board does not believethat an independent Chairman or lead Independent Trustee would enhance the Board’s effectiveness, as the relatively small sizeof the Board allows for diverse viewpoints to be shared and for effective communications between and among Independent
Trustees and management so that meetings proceed efficiently. Independent Trustees have effective control over the Board’s
agenda because they form a majority of the Board and can direct Trust officers, Cambria, and the Fund’s third-party service
providers to give presentations and address agenda topics at Board meetings.
The Board normally holds four regularly scheduled meetings each year, at least one of which is in person. The Board may
hold special meetings, as needed, either in person or by telephone, to address matters arising between regular meetings. The
Independent Trustees meet separately at each regularly scheduled in-person meeting of the Board; during a portion of eachsuch separate meeting management is not present. The Independent Trustees may also hold special meetings, as needed, eitherin person or by telephone.
The Board conducts a self-assessment on an annual basis, as part of which it considers whether the structure of the Boardand its Committees is appropriate under the circumstances. Based on such self-assessment, among other things, the Board
considers whether its current structure is appropriate. As part of this self-assessment, the Board considers several factors,
including the number of funds overseen by the Board, their investment objectives, and the responsibilities entrusted to Cambria
and other service providers with respect to the oversight of the day-to-day operations of the Trust and the Funds.
The Board sets broad policies for the Trust and may appoint Trust officers. The Board oversees the performance of Cambria andthe Trust’s other service providers. As part of its oversight function, the Board monitors Cambria’s risk management, including,as applicable, its management of investment, compliance and operational risks, through the receipt of periodic reports andpresentations. The Board has not established a standing risk committee. Rather, the Board relies on Trust officers, advisorypersonnel and service providers to manage applicable risks and report exceptions to the Board in order to enable it to exercise
its oversight responsibility. To this end, the Board receives reports from such parties at least quarterly, including, but not limited
to, investment and/or performance reports, distribution reports, Rule 12b-1 reports, valuation and internal controls reports.
Similarly, the Board receives quarterly reports from the Trust’s chief compliance officer (“CCO”), including, but not limited to,a report on the Trust’s compliance program, and the Independent Trustees have an opportunity to meet separately each quarterwith the CCO. The CCO typically provides the Board with updates regarding the Trust’s compliance policies and procedures,
including any enhancements to them. The Board expects all parties, including, but not limited to, Cambria, other service
providers and the CCO, to inform the Board on an intra-quarter basis if a material issue arises that requires the Board’s oversight.
The Board generally exercises its oversight as a whole, but has delegated certain oversight functions to an Audit Committee.
The function of the Audit Committee is discussed in detail below.

42

Committees
The Board currently has two standing committees: an Audit Committee and a Nominating Committee. Each Independent
Trustee serves on each of these committees.
The purposes of the Audit Committee are to: (1) oversee generally each Fund’s accounting and financial reporting policies
and practices, their internal controls and, as appropriate, the internal controls of certain service providers; (2) oversee thequality, integrity, and objectivity of each Fund’s financial statements and the independent audit thereof; (3) assist the full Board
with its oversight of the Trust’s compliance with legal and regulatory requirements that relate to each Fund’s accounting andfinancial reporting, internal controls and independent audits; (4) approve, prior to appointment, the engagement of the Trust’s
independent auditors and, in connection therewith, to review and evaluate the qualifications, independence and performanceof the Trust’s independent auditors; and (5) act as a liaison between the Trust’s independent auditors and the full Board. During
the fiscal year ended April 30, 2024, the Audit Committee met two times.
The purposes of the Nominating Committee are, among other things, to: (1) identify and recommend for nomination
candidates to serve as Trustees and/or on Board committees who are not “interested persons” as defined in Section 2(a)(19) of the Investment Company Act (“Interested Person”) of the Trust and who meet any independence requirements of
Exchange Rule 5.3(k)(1) or the applicable rule of any other exchange on which shares of the Trust are listed; (2) evaluate
and make recommendations to the full Board regarding potential trustee candidates who are Interested Persons of the Trust;and (3) review periodically the workload and capabilities of the Trustees and, as the Committee deems appropriate, to makerecommendations to the Board if such a review suggests that changes to the size or composition of the Board and/or its
committees are warranted. The Committee does not consider potential candidates for nomination identified by shareholders.
During the fiscal year ended April 30, 2024, the Nominating Committee did not meet.
Compensation of Trustees. The Independent Trustees determine the amount of compensation that they receive. In determining
compensation for the Independent Trustees, the Independent Trustees take into account a variety of factors including, among
other things, their collective significant work experience (e.g., in business and finance, government or academia). The
Independent Trustees also recognize that these individuals’ advice and counsel are in demand by other organizations, thatthese individuals may reject other opportunities because of the time demands of their duties as Independent Trustees, and thatthey undertake significant legal responsibilities. The Independent Trustees also consider the compensation paid to independent
board members of other registered investment company complexes of comparable size.
The Independent Trustees are paid $ 10,000 per quarter for attendance at meetings of the Board and the Chairman of the Audit
Committee receives an additional $1,250 per quarter. The Trust’s officers and any interested Trustees receive no compensation
directly from the Trust. All Trustees are reimbursed for their travel expenses and other reasonable out-of-pocket expenses
incurred in connection with attending Board meetings. The Trust does not accrue pension or retirement benefits as part of theFunds’ expenses, and Trustees are not entitled to benefits upon retirement from the Board.
The following table reflects compensation paid to the Trustees for the fiscal year ended April 30, 2024:

Independent Trustees
Cullen Roche2
Dennis G. Schmal
Taz Turner2Interested Trustee
Mebane Faber3123Compensation1
$25,000﻿
$45,000﻿
$25,000﻿

Compensation
Deferred1
$0﻿
$0﻿
$0﻿

Total Compensationfrom the Fund Complex
Paid to Trustee1
$25,000﻿
$45,000﻿
$25,000﻿

$0

$0

$0

Trustee compensation is allocated across the series of the Fund Complex on the basis of assets under management. Under
the Funds’ Management Agreements, however, Cambria ultimately pays the compensation and expenses of the Trustees.
Messrs. Roche and Turner were elected to serve as new Independent Trustees effective as of August 25, 2023.
Mr. Faber is an “interested person,” as defined by the Investment Company Act, because of his employment with andownership interest in Cambria.

43Equity Ownership of Trustees. The following table shows the dollar amount range of each Trustee’s “beneficial ownership”
of shares of the Funds and each series of the Trust as of the end of the most recently completed calendar year. Dollar amountranges disclosed are established by the SEC. “Beneficial ownership” is determined in accordance with Rule 16a-1(a)(2) underthe 1934 Act. The Trustees and officers of the Trust collectively own less than 1% of the outstanding shares of the Trust.

Name of Trustee
Interested Trustee
Mebane Faber

Independent Trustees
Cullen Roche2
Dennis G. Schmal
Taz Turner2
12

Aggregate Dollar Rangeof Equity Securities in
All Registered Investment
Companies Overseen by
Trustee in Family of
Investment Companies1

Name of Fund

Dollar Range of Equity
Securities in the Funds1

Shareholder Yield ETF
Foreign Shareholder Yield ETF
Emerging Shareholder Yield ETF
Global Value ETF
Global Momentum ETF
Value and Momentum ETF
Global Asset Allocation ETF
Tail Risk ETF
Trinity ETF
Global Real Estate ETF
Global Tail Risk ETF
Cannabis ETF

$10,001 – $50,000
$10,001 – $50,000
$10,001 – $50,000
$50,001 – $100,000
$50,001 – $100,000﻿
$10,001 – $50,000
$50,001 – $100,000
$1 – $10,000
Over – $100,000
$1 – $10,000
$1 – $10,000
$1 – $10,000

Over $100,000

n/a
n/a
n/a

None
None
None

None
None
None

Dollar ranges for Mebane Faber are based on a December 31, 2023 valuation date.
Messrs. Roche and Turner were elected to serve as Independent Trustees effective as of August 25, 2023.

As of December 31, 2023, none of the Independent Trustees or their immediate family members beneficially owned any
securities in any investment adviser or principal underwriter of the Trust, or in any person (other than a registered investmentcompany) directly or indirectly controlling, controlled by, or under common control with an investment adviser or principal
underwriter of the Trust.
Codes of Ethics
The Board, on behalf of the Trust, has adopted a Code of Ethics pursuant to Rule 17j-1 under the Investment Company Act.
In addition, Cambria, Tidal, and the Distributor each have adopted a Code of Ethics pursuant to Rule 17j-1. These Codes of
Ethics (each, a “Code of Ethics” and, collectively, the “Codes of Ethics”) apply to the personal investing activities of trustees,
directors, officers and certain employees (“access persons”). Rule 17j-1 and the Codes of Ethics are designed to prevent
unlawful practices in connection with the purchase or sale of securities by access persons. Under each Code of Ethics, accesspersons are permitted to engage in personal securities transactions, including in securities that may be purchased or held by theFunds, but the access persons are required to report their personal securities transactions for monitoring purposes. In addition,certain access persons are required to obtain approval before investing in private placements and are prohibited from investingin IPOs. Copies of the Codes of Ethics are on file with the SEC and available to the public.
Proxy Voting
The Board has delegated to Cambria the responsibility to vote proxies related to the securities held in the Funds’ portfolios.
Under this authority, Cambria is required by the Board to vote proxies related to portfolio securities in the best interests of each
Fund and its shareholders. Cambria has subsequently delegated the authority and responsibility to vote proxies for the Funds’
securities to the Sub-Adviser pursuant to the Sub-Advisory Agreement described in greater detail below. The Sub-Adviser
will vote such proxies in accordance with its proxy policies and procedures, which are included in Appendix A to this SAI.

44

Information regarding how a Fund voted proxies relating to portfolio securities during the most recent 12-month period
ended June 30 will be available without charge by calling 855-ETF-INFO (383-4636) or by accessing the SEC’s website at
http://www.sec.gov.
CONTROL PERSONS AND PRINCIPAL HOLDERS OF SECURITIES
Although the Trust does not have information concerning the beneficial ownership of shares held in the names of DTC
Participants, as of August 1, 2024, the name, address and percentage ownership of each DTC Participant that owned of record
5% or more of the outstanding shares of a Fund is set forth in the table below:

Fund Name
Cambria Shareholder Yield ETF

Cambria Foreign Shareholder Yield ETF

Participant Name and Address
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210
Raymond James & Associates Inc.
880 Carilion Parkway
PO Box 14508
Saint Petersburg, FL 33716
Morgan Stanley Smith Barney2000 Westchester Ave.
Purchase, NY 10577
LPL Financial Corporation
4707 Executive Drive
San Diego, CA 92121
Pershing LLC
One Pershing Plaza
Jersey City, NJ 07399
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210
Pershing LLC
One Pershing Plaza
Jersey City, NJ 07399﻿
Raymond James & Associates Inc.
880 Carilion Parkway
PO Box 14508
U.S. Bank National Association
425 Walnut St.
Cincinnati, OH 45202﻿

45

Percentage ofOwnership
31.44%﻿

18.57%﻿

8.52%﻿

8.20%

7.45%﻿

6.92%﻿

36.24%﻿

22.39%﻿

9.08%﻿

8.04%﻿

7.78%﻿

Fund Name
Cambria Emerging Shareholder Yield ETF

Cambria Global Tail Risk ETF

Participant Name and Address
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210
Raymond James & Associates Inc.
880 Carilion Parkway
PO Box 14508
Saint Petersburg, FL 33716
U.S. Bank National Association
425 Walnut St.
Cincinnati, OH 45202
LPL Financial Corporation
4707 Executive Drive
San Diego, CA 92121
Pershing LLC
One Pershing Plaza
Jersey City, NJ 07399
Goldman Sachs & Co. LLC
200 West Street
New York, NY 10282
BofA Securities, Inc.
One Bryant Park
New York, NY 10036
JP Morgan Securities LLC/JPMC
383 Madison Ave.
New York, NY 10179
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
Morgan Stanley & Co. LLC
1585 Broadway
New York, NY 10036
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210

46

Percentage ofOwnership
40.22%﻿

18.54%﻿

8.15%﻿

6.51%

6.07%

5.69%﻿

31.05%﻿

16.53%﻿

14.45%﻿

12.40%

10.41%﻿

7.08%﻿

Fund Name
Cambria Global Value ETF

Cambria Global Momentum ETF

Cambria Value and Momentum ETF

﻿Participant Name and Address
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
The Bank of New York Mellon
240 Greenwich Street
New York, NY 10286
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210
Interactive Brokers Retail Equity Clearing
8 Greenwich Office Park
Greenwich, CT 06831
U.S. Bank National Association
425 Walnut St.
Cincinnati, OH 45202﻿
Vanguard Marketing Corporation
100 Vanguard Blvd
Malvern, PA 19355
The Bank of New York Mellon
240 Greenwich Street
New York, NY 10286
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105﻿
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210
Apex Clearing Corporation
350 North St. Paul Street #1300
Dallas, TX 75201
LPL Financial Corporation
4707 Executive Drive
San Diego, CA 92121
Pershing LLC
One Pershing Plaza
Jersey City, NJ 07399
The Bank of New York Mellon
240 Greenwich Street
New York, NY 10286
U.S. Bank National Association
425 Walnut St.
Cincinnati, OH 45202﻿
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105﻿
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210
LPL Financial Corporation
4707 Executive Drive
San Diego, CA 92121

47

Percentage ofOwnership
23.56%﻿

19.17%﻿

10.81%﻿

9.03%﻿

7.43%﻿

6.38%﻿

39.65%﻿

14.57%﻿

11.31%﻿

9.48%﻿

6.48%

6.20%﻿

40.09%﻿

22.42%﻿

14.53%﻿

5.59%﻿

5.28%﻿

Fund Name
Cambria Global Asset Allocation ETF

Cambria Tail Risk ETF

Cambria Trinity ETF

﻿Cambria Cannabis ETF

Participant Name and Address
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
LPL Financial Corporation
4707 Executive Drive
San Diego, CA 92121﻿
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210﻿
Wells Fargo Clearing Services, LLC
2801 Market Street H0006 – 09B
St. Louis, MO 63103
Vanguard Marketing Corporation
100 Vanguard Blvd
Malvern, PA 19355﻿
The Bank of New York Mellon
240 Greenwich Street
New York, NY 10286
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210
Vanguard Marketing Corporation
100 Vanguard Blvd
Malvern, PA 19355
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
Interactive Brokers Retail Equity Clearing
8 Greenwich Office Park
Greenwich, CT 06831﻿
Morgan Stanley Smith Barney2000 Westchester Ave.
Purchase, NY 10577﻿
Vanguard Marketing Corporation
100 Vanguard Blvd
Malvern, PA 19355

48

Percentage ofOwnership
45.89%﻿

22.73%﻿

13.62%﻿

36.40%﻿

24.75%﻿

10.48%﻿

7.80%﻿

43.46%

23.32%

15.73%﻿

5.64%

25.24%

22.96%﻿

18.57%﻿

5.78%﻿

5.63%﻿

Fund Name
Cambria Global Real Estate ETF

Participant Name and Address
U.S. Bank National Association
425 Walnut St.
Cincinnati, OH 45202﻿
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
The Bank of New York Mellon
240 Greenwich Street
New York, NY 10286
U.S. Bank National Association
425 Walnut St.
Cincinnati, OH 45202
Goldman Sachs International
Plumtree Court
25 Shoe Lane
London, X0 EC4A 4AU
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
U.S. Bank National Association
425 Walnut St.
Cincinnati, OH 45202
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105
U.S. Bank National Association
425 Walnut St.
Cincinnati, OH 45202﻿
National Financial Services LLC
200 Seaport Boulevard
Boston, MA 02210﻿
Goldman Sachs & Co. LLC
200 West Street
New York, NY 10282
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105

Cambria Micro and SmallCap Shareholder Yield
ETF

Cambria Tactical Yield ETF

Cambria LargeCap Shareholder Yield ETF﻿49

Percentage ofOwnership
31.01%﻿

29.42%﻿

25.71%﻿

56.59%

26.86%

7.43%

39.37%

34.36%﻿

11.70%﻿

47.99%﻿

34.45%﻿

9.07%﻿

6.19%﻿

INVESTMENT MANAGEMENT AND OTHER SERVICES
Investment Advisory Agreement
Under an investment advisory agreement between Cambria and the Trust, on behalf of each Fund (the “Management
Agreement”), each Fund pays Cambria a fee at an annualized rate, which is calculated daily and paid monthly, based on its
average daily net assets, set forth in the table below:
Fund
Cambria Shareholder Yield ETF
Cambria Foreign Shareholder Yield ETF
Cambria Emerging Shareholder Yield ETF
Cambria Global Tail Risk ETF
Cambria Global Value ETF
Cambria Global Momentum ETF
Cambria Value and Momentum ETF
Cambria Global Asset Allocation ETF
Cambria Tail Risk ETF
Cambria Trinity ETF
Cambria Cannabis ETF
Cambria Global Real Estate ETF
Cambria Micro and SmallCap Shareholder Yield ETF
Cambria Tactical Yield ETF
Cambria LargeCap Shareholder Yield ETF

Advisory Fee
0.59%
0.59%
0.59%
0.59%
0.59%
0.59%
0.59%
0.00%
0.59%
0.00%
0.59%1
0.59%
0.59%
0.59%
0.59%

Cambria has agreed to waive 17 basis points (0.17%) of its management fees for the Fund until at least August 31, 2025,
and this agreement may be terminated only by, or with the consent of, the Trust’s Board of Trustees.

1

For the fiscal years ended April 30, 2022, 2023, and 2024 the Funds paid the following amounts in advisory fees to Cambria:

Fund Name
Cambria Shareholder Yield ETF
Cambria Foreign Shareholder Yield ETF
Cambria Global Value ETF
Cambria Global Momentum ETF
Cambria Global Asset Allocation ETF
Cambria Value and Momentum ETF
Cambria Global Tail Risk ETF
Cambria Emerging Shareholder Yield ETF
Cambria Tail Risk ETF
Cambria Trinity ETF
Cambria Cannabis ETF
Cambria Global Real Estate ETF
Cambria Micro and SmallCap Shareholder Yield
ETF
Cambria Tactical Yield ETF
Cambria LargeCap Shareholder Yield ETF
*
(a)

2022
$2,150,027﻿
$265,155﻿
$719,120﻿
$378,641﻿
$0
$141,841﻿
$36,017﻿
$485,218﻿
$2,014,320﻿
$0
$121,402﻿(a)$111,800﻿

2023
$3,717,386﻿
$592,687﻿
$618,488﻿
$883,989﻿
$0
$523,313﻿
$28,175﻿
$702,946﻿
$2,019,152﻿
$0
$60,895﻿(a)$126,185﻿

2024
$5,443,898﻿
$1,311,347﻿
$715,705﻿
$902,819﻿
$0
$361,069﻿
$19,129﻿$1,375,996﻿
$825,641﻿
$0
$35,246﻿(a)$136,983﻿

Commencement of
Operations
May 14, 2013
Dec. 3, 2013
Mar. 12, 2014
Nov. 4, 2014
Dec. 10, 2014
Sept. 9, 2015
Feb. 23, 2016
July 14, 2016
Apr. 6, 2017
Sept. 10, 2018
July 24, 2019
Sept. 24, 2020

N/A
N/A
N/A

N/A
N/A
N/A

$40,180*
$16,175*
N/A

Jan. 5, 2024
Jan. 5, 2024
July 12, 2024

Advisory fees paid for the period from the Fund’s commencement of operations.
Net of fee waiver.

50

Cambria manages the investment and the reinvestment of the assets of each of the Funds, in accordance with the investment
objectives, policies, and limitations of the Funds, subject to the general supervision and control of the Board. Cambria is a
registered investment adviser under the Investment Advisers Act of 1940 and is a limited partnership organized under the lawsof Delaware. The address of Cambria is 3300 Highland Avenue, Manhattan Beach, California 90266. Mebane Faber, Sofia
Reyes Descendants Trust, Lillian Elizabeth Richardson Trust, Cambria Investments Holdings, LLC, and Cambria Investments
Holdings II, LLC are limited partners of the Adviser, and Cambria GP, LLC is the Adviser’s general partner. Cambria GP, LLC
shares the address of the Adviser. Mebane Faber is the sole manager of, and controls, Cambria GP, LLC. Cambria GP, LLC
controls the Adviser as its sole general partner. Cambria was founded in 2006 and provides investment advisory services toregistered and unregistered investment companies, individuals (including high net worth individuals), pensions and charitableorganizations.
Under the Management Agreement, with respect to all Funds except Cambria Emerging Shareholder Yield ETF and Cambria
Global Value ETF, Cambria bears all of the costs of the Funds, except for the advisory fee, payments under each Fund’s 12b-1
plan, brokerage expenses, acquired fund fees and expenses, taxes, interest (including borrowing costs and dividend expenses
on securities sold short), litigation expenses and other extraordinary expenses (including litigation to which the Trust or a Fund
may be a party and indemnification of the Trustees and officers with respect thereto). Under the Management Agreement,
Cambria bears all of the costs of the Cambria Emerging Shareholder Yield ETF and Cambria Global Value ETF, except for
the advisory fee, payments under each Fund’s 12b-1 plan, brokerage expenses, custodial expenses, acquired fund fees andexpenses, taxes, interest (including borrowing costs and dividend expenses on securities sold short), litigation expenses andother extraordinary expenses (including litigation to which the Trust or a Fund may be a party and indemnification of theTrustees and officers with respect thereto).
The Management Agreement provides that Cambria will not be liable for any error of judgment or mistake of law or for any
loss suffered by the Trust in connection with the matters to which the Management Agreement relates, but will be liable to
the Trust and its shareholders only for willful misfeasance, bad faith, or gross negligence on its part in the performance of its
duties or from reckless disregard of its obligations or duties thereunder.
The Management Agreement also provides that Cambria may engage in other businesses, devote time and attention to any
other business whether of a similar or dissimilar nature, and render investment advisory services to others.
The Management Agreement with respect to a Fund will remain in effect for two (2) years from its effective date and thereafter
continue in effect for as long as its continuance is specifically approved at least annually, by (1) the vote of the Trustees orby a vote of a majority of the shareholders of a Fund, and (2) by the vote of a majority of the Trustees who are not parties tothe Management Agreement or Interested Persons of any person thereto, cast in person at a meeting called for the purpose of
voting on such approval. The Management Agreement provides that it may be terminated at any time, without the paymentof any penalty, by the Board of Trustees or by a majority of the outstanding shares of the Fund, on 60 days’ written notice toCambria, and by Cambria upon 60 days’ written notice and that it shall be automatically terminated if it is assigned.
Investment Sub-Advisory Agreement
The Sub-Adviser is an SEC-registered investment adviser and a Delaware limited liability company located at 234 W. Florida
Street, Suite 203, Milwaukee, Wisconsin 53204. The Sub-Adviser is the parent company of Tidal ETF Services LLC. The
Sub-Adviser was founded in, and has been managing investment companies, since March 2012. The Sub-Adviser is dedicated tounderstanding, researching and managing assets within the expanding ETF universe. As of August 1, 2024, the Sub-Adviser had
assets under management of approximately $ 18.6 billion and served as the investment adviser or sub-adviser for 159 registeredfunds. Under a sub-advisory agreement between Cambria and Tidal Investments LLC (the “Sub-Advisory Agreement”), theAdviser pays the Sub-Adviser a portion of its fee, which is calculated daily and paid monthly, at the following fee rate: 3 basis
points on the first $2 billion of aggregate Fund assets; and 2.5 basis points on aggregate Fund assets above $2 billion.

51

For the fiscal year ended April 30, 2024 Cambria paid the following amounts to Tidal in sub-advisory fees:

Fund Name
Cambria Shareholder Yield ETF
Cambria Foreign Shareholder Yield ETF
Cambria Global Value ETF
Cambria Global Momentum ETF
Cambria Global Asset Allocation ETF
Cambria Value and Momentum ETF
Cambria Global Tail Risk ETF
Cambria Emerging Shareholder Yield ETF
Cambria Tail Risk ETF
Cambria Trinity ETF
Cambria Cannabis ETF
Cambria Global Real Estate ETF
Cambria Micro and SmallCap Shareholder Yield ETF
Cambria Tactical Yield ETF
Cambria LargeCap Shareholder Yield ETF

2024*
$153,425.90﻿
$45,956.79﻿
$22,118.45﻿
$28,163.65﻿
$9,515.87﻿
$12,215.08﻿
$2,696.41﻿
$50,680.43﻿
$16,411.49﻿
$22,127.61﻿
$3,304.16﻿
$4,435.05﻿
$2,043.08﻿**
$822.47﻿**
N/A

Commencement of
Operations
May 14, 2013
Dec. 3, 2013
Mar. 12, 2014
Nov. 4, 2014
Dec. 10, 2014
Sept. 9, 2015
Feb. 23, 2016
July 14, 2016
Apr. 6, 2017
Sept. 10, 2018
July 24, 2019
Sept. 24, 2020
Jan. 5, 2024
Jan. 5, 2024
July 12, 2024*

The Sub-Adviser began serving as sub-adviser to each fund, except for the Cambria Global Tail Risk ETF, on October 23,
2023. The Sub-Adviser began serving as sub-adviser to the Cambria Global Tail Risk ETF, on November 16, 2023.
** Advisory fees paid for the period from the Fund’s commencement of operations.
The Sub-Advisory Agreement with respect to a Fund will remain in effect for two (2) years from its effective date andthereafter continue in effect for as long as its continuance is specifically approved at least annually, by (1) the vote of theTrustees or by a vote of a majority of the shareholders of a Fund, and (2) by the vote of a majority of the Trustees who are notparties to the Sub-Advisory Agreement or Interested Persons of any person thereto, cast in person at a meeting called for the
purpose of voting on such approval. The Sub-Advisory Agreement provides that it may be terminated at any time, without
the payment of any penalty, (i) by the Board of Trustees, including a majority of the Independent Trustees, or by the vote ofa majority of the outstanding shares of a Fund, on sixty (60) days’ written notice to Cambria and Tidal, or (ii) by Cambria or
Tidal on sixty (60) days’ written notice to the Trust and the other party. In addition, the Sub-Advisory Agreement shall be
automatically terminated if it is assigned.
The Trust is in the process of applying for exemptive relief from the SEC, which, if obtained, will permit the Adviser, subject tocertain conditions, to terminate the existing Sub-Adviser or hire new sub-advisers for each Fund, to materially amend the termsof particular agreements with sub-advisers or to continue the employment of a sub-adviser after events that would otherwise
cause an automatic termination of a sub-advisory agreement. Consequently, under the exemptive order, the Adviser will havethe right to hire, terminate and replace a sub-adviser to a Fund when the Board and the Adviser feel that a change would benefit
the Fund. Within 90 days of retaining a new sub-adviser, shareholders of any affected Fund will receive notification of thechange. This structure, known as a “manager of managers” structure, enables the Funds to operate with greater efficiency andwithout incurring the expense and delays associated with obtaining shareholder approval of sub-advisory agreements. The
structure does not permit investment advisory fees paid by a Fund to be increased or change the Adviser’s obligations under theinvestment advisory agreement, including the Adviser’s responsibility to monitor and oversee sub-advisory services furnished
to a Fund, without shareholder approval. Furthermore, any sub-advisory agreements with affiliates of a Fund or the Adviser
will require shareholder approval. Until the Adviser and the Trust obtain this relief, each Fund will continue to submit thesematters to shareholders for their approval to the extent required by applicable law.
Administrator
Tidal ETF Services LLC (“Tidal” or the “Administrator”), a Tidal Financial Group company and an affiliate of the Sub-Adviser,
located at 234 West Florida Street, Suite 203, Milwaukee, Wisconsin 53204, serves as the administrator to each Fund. Pursuant
to a Fund Administration Servicing Agreement between the Trust and Tidal, Tidal provides the Trust with, or arranges for,administrative and management services (other than investment advisory services) to be provided to the Trust and the Board,52

such as, but not limited to, clerical and general back office services; bookkeeping, internal accounting and secretarial services;
the calculation of the dollar amounts of gross and net income from securities lending activities received and the related fees
and/or compensation paid by each applicable Fund during the most recent fiscal year are set forth in the following table.
Employee of Tidal to serve as the Trust’s principal financial officer, coordinates the payment of certain Fund-related expenses,
and manages the Trust’s relationships with certain of its service providers. As compensation for the services it provides, Tidal
receives a fee based on each Fund’s average daily net assets. Tidal also is entitled to certain out-of-pocket expenses for theservices mentioned above.
Sub-Administrator, Fund Accountant and Transfer Agent
U.S. Bancorp Fund Services, LLC, d/b/a U.S. Bank Global Fund Services (“Global Fund Services” or the “Sub-Administrator” or
the “Transfer Agent”), located at 615 East Michigan Street, Milwaukee, Wisconsin 53202, serves as the Funds’ sub-administrator
and fund accountant as well as transfer agent to each Fund’s assets. Pursuant to a Partial Fund Administration Servicing
Agreement and a Fund Accounting Servicing Agreement between Global Fund Services and the Trust, Global Fund Services
provides the Trust with administrative and management services (other than investment advisory services) and accounting
services, including portfolio accounting services, tax accounting services and furnishing financial reports. In this capacity,
Global Fund Services does not have any responsibility or authority for the management of the Funds, the determination of
investment policy, or for any matter pertaining to the distribution of Shares. Pursuant to a Transfer Agent Servicing Agreement,
Global Fund Services has agreed to: (1) issue and redeem shares of each Fund in Creation Units, (2) make dividend and other
distributions to shareholders of each Fund, (3) maintain shareholder accounts, and (4) make periodic reports to the Funds. As
compensation for each of these services, Global Fund Services receives a fee based on the Funds’ average daily net assets,
subject to a minimum annual fee. Global Fund Services also is entitled to certain out-of-pocket expenses for the services
mentioned above, including pricing expenses.
Custodian
U.S. Bank National Association (“U.S. Bank” or the “Custodian”), located at 1555 N. Rivercenter Drive, Milwaukee, Wisconsin
53212, serves as custodian to each Fund’s assets. U.S. Bank is the parent company of Global Fund Services. As custodian,
U.S. Bank has agreed to: (1) make receipts and disbursements of money on behalf of a Fund, (2) collect and receive allincome and other payments and distributions on account of a Fund’s portfolio investments, and (3) make periodic reports
to a Fund concerning the Fund’s operations. U.S. Bank does not exercise any supervisory function over the purchase andsale of securities. As compensation for these services, the Custodian receives certain out-of-pocket costs, transaction fees
and asset-based fees which are accrued daily and paid monthly by Cambria from its fees, except that the Cambria Emerging
Shareholder Yield ETF and Cambria Global Value ETF bear their own Custodial expenses.
Securities Lending Activities
U.S. Bank also serves as securities lending agent to the Funds (the “Securities Lending Agent”). The Securities Lending
Agent is responsible for the implementation and administration of the Funds’ securities lending program pursuant toa securities lending agency agreement between the Trust, on behalf of the Funds, and the Securities Lending Agent(the “Securities Lending Agreement”). The Securities Lending Agent acts as agent to the Funds to lend available securities
with any person on its list of approved borrowers. The Securities Lending Agent (i) determines whether a loan shall be madeand negotiates and establishes the terms and conditions of the loan with the borrower; (ii) ensures that all substitute interest,
dividends, and other distributions paid with respect to loan securities is credited to the Fund’s relevant account on the datesuch amounts are delivered by the borrower to the Securities Lending Agent; (iii) receives and holds, on the Fund’s behalf,collateral from borrowers to secure obligations of borrowers with respect to any loan of available securities; (iv) marks
loaned securities and collateral to their market value each business day based upon the market value of the loaned securities
and collateral at the close of business employing the most recently available pricing information and receives and delivers
collateral to maintain the value of the collateral at no less than 100% of the market value of the loaned securities; (v) at thetermination of a loan, returns the collateral to the borrower upon the return of the loaned securities to the Securities Lending
Agent; (vi) invests cash collateral in accordance with the Securities Lending Agreement; and (viii) maintains such records as
were reasonably necessary to account for loans that are made and the income derived therefrom and makes available to theFund a monthly statement describing the loans outstanding, including an accounting of all securities lending transactions.
For the period from May 1, 2023, to September 5, 2023, Brown Brothers Harriman & Co. (“BBH”), the Funds’ prior custodian,served as securities lending agent to the Funds. U.S. Bank has served as Securities Lending Agent to the Funds since April 8,
2024.

53

The dollar amounts of gross and net income from securities lending activities received and the related fees and/or compensation
paid by each applicable Fund during the most recent fiscal year ended April 30, 2024, are set forth in the following table.
SYLD
FYLD
EYLD
FAIL
GVAL GMOM VAMOGAA
TRTY
TOKE BLDG MYLD TYLD LYLD
Gross Income
from Securities
Lending
Activities(including
income fromcash collateralreinvestment)
$638,099﻿ $ 338,706﻿ $159,286 $13,941 $63,149 $387,551 $76,659﻿ $194,081﻿ $214,924﻿ $128,057﻿ $7,856
$—
$—
N/A
Fees and/orCompensation for
Securities Lending
Activities andRelated Services
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A
N/A
N/A
Share of Revenue
Generated by
the Securities
Lending
Program Paid
to the Securities
Lending Agent(“Revenue Split”) $53,160﻿ $ 22,678﻿ $17,446
$136 $6,974 $33,741
$937﻿ $10,886﻿ $14,165﻿ $20,113﻿ $1,240
$—
$—
N/A
Fees Paid for
Cash CollateralManagement
Services(including
fees deductedfrom a pooled
cash collateralreinvestment
vehicle) not
included in
Revenue Split
$23,915﻿ $10,032﻿
$4,203
$780 $2,210 $17,571 $3,066﻿
$8,885﻿
$8,384﻿
$3,478﻿
$155
$—
$—
N/A
Administrative
Fees not included
in Revenue Split
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A
N/A
N/A
Indemnification
Fee not included
in Revenue Split
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A
N/A
N/A
Rebates Paid to
Borrowers
$357,244﻿ $214,882﻿ $ 67,851 $12,480 $26,060 $201,271 $68,903﻿ $130,632﻿ $135,576﻿ $23,673﻿ $1,500
$—
$—
N/A
Other Fees notincluded in
Revenue Split
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A﻿
N/A
N/A
N/A
Aggregate Fees/
Compensationfor Securities
Lending
Activities
$434,318﻿ $247,592﻿ $ 89,500﻿ $13,396 $35,244﻿ $252,583 $72,906﻿ $150,403﻿ $158,125﻿ $47,264﻿ $2,895
$—
$—
N/A
Net Income fromSecurities
Lending
Activities
$203,781﻿ $91,114﻿ $ 69,786﻿
$545 $27,905﻿ $134,968 $3,753﻿ $43,679﻿ $56,799﻿ $80,793﻿ $4,961
$—
$—
N/A

54

PORTFOLIO MANAGERS
The following table provides information about the other accounts, in addition to the Funds, for which the portfolio managers
have day-to-day management responsibility. None of the other accounts managed by the portfolio managers are subject to a
performance-based advisory fee. The reporting information is provided as of August 1, 2024:
Number of Accounts Total Assets Managed
Managed($ millions)Type of AccountMebane Faber
Registered Investment Companies
Other Pooled Investment Vehicles
Other Accounts
Jonathan Keetz
Registered Investment Companies
Other Pooled Investment Vehicles
Other Accounts

15
0
273

$2,649﻿
$0﻿
$30﻿

15
0
273

$2,649
$0
$30

Potential Conflicts of Interest
Each portfolio manager’s management of “other accounts” may give rise to potential conflicts of interest in connection withhis management of the Funds’ investments, on the one hand, and the investments of the other accounts, on the other. The otheraccounts may have the same investment objective as the Funds. Therefore, a potential conflict of interest may arise as a resultof the identical investment objectives, whereby a portfolio manager could favor one account over another. Another potential
conflict could include a portfolio manager’s knowledge about the size, timing and possible market impact of Fund trades,
whereby a portfolio manager could use this information to the advantage of other accounts and to the disadvantage of theFunds. Cambria has established policies and procedures to ensure that the purchase and sale of securities among all accounts
it manages are fairly and equitably allocated. There can be no assurance, however, that these policies and procedures will beeffective.
Compensation
Mr. Faber owns an equity interest in Cambria and his compensation is determined by the advisory fee revenue generated by
the firm’s assets under management. Thus, portfolio manager compensation is aligned with the interests of Cambria’s clients,
including the Funds and their investors, because it is in the portfolio manager’s best interests to grow the assets of its clients,
including the Funds, by delivering strong performance to each. He may also earn a bonus each year based on the profitabilityof Cambria.
Mr. Keetz receives a base salary and may also earn a bonus each year based on the profitability of Cambria. In addition, he has
an equity interest in Cambria and his compensation is determined by the advisory fee revenue generated by the firm’s assets
under management. Thus, portfolio manager compensation is aligned with the interests of Cambria’s clients, including theFunds and their investors, because it is in the portfolio manager’s best interests to grow the assets of its clients, including theFunds, by delivering strong performance to each.

55

PORTFOLIO TRANSACTIONS AND BROKERAGE
Brokerage Transactions
Portfolio changes will generally be implemented through in-kind transactions for Creation Units; however, the Adviser or
Sub-Adviser, as applicable, may execute brokerage transactions for a Fund and a Fund may incur brokerage commissions,particularly during the early stages of the Funds’ development or in the case of transactions involving realized losses. Also, aFund may accept cash as part or all of an In-Kind Creation or Redemption Basket, in which case Cambria may need to execute
brokerage transactions for a Fund. Generally, equity securities, including securities of underlying ETFs, are bought and soldthrough brokerage transactions for which commissions are payable. Purchases from underwriters will include the underwriting
commission or concession, and purchases from dealers serving as market makers will include a dealer’s mark-up or reflect a
dealer’s mark-down. Money market securities and other debt securities are usually bought and sold directly from the issuer oran underwriter or market maker for the securities. Generally, the Funds will not pay brokerage commissions for such purchases.
When a debt security is bought from an underwriter, the purchase price will usually include an underwriting commission orconcession. The purchase price for securities bought from dealers serving as market makers will similarly include the dealer’s
mark-up or reflect a dealer’s mark-down. When a Fund executes transactions in the over-the-counter market, it will generally
deal with primary market makers unless prices that are more favorable are otherwise obtainable.
In addition, the Adviser or Sub-Adviser, as applicable, may place a combined order, often referred to as “bunching,” for two or
more accounts it manages, including the Funds, engaged in the purchase or sale of the same security or other instrument if, in
its judgment, joint execution is in the best interest of each participant and will result in best price and execution. Transactions
involving commingled orders are allocated in a manner deemed equitable to each account or Fund. Although it is recognized
that, in some cases, the joint execution of orders could adversely affect the price or volume of the security that a particular
account or a Fund may obtain, it is the opinion of the Adviser or Sub-Adviser, as applicable, that the advantages of combinedorders outweigh the possible disadvantages of separate transactions. In addition, in some instances a Fund effecting the larger
portion of a combined order may not benefit to the same extent as participants effecting smaller portions of the combinedorder. Nonetheless, the Adviser or Sub-Adviser, as applicable, believes that the ability of a Fund to participate in higher
volume transactions will generally be beneficial to the Fund.
The following table reflects the brokerage commissions paid by the Funds for the fiscal years ended April 30, 2022, 2023, and
2024:

Fund
Cambria Shareholder Yield ETF
Cambria Foreign Shareholder Yield ETF
Cambria Global Value ETF
Cambria Global Momentum ETF
Cambria Global Asset Allocation ETF
Cambria Value and Momentum ETF
Cambria Global Tail Risk ETF
Cambria Emerging Shareholder Yield ETF
Cambria Tail Risk ETF
Cambria Trinity ETF
Cambria Cannabis ETF
Cambria Global Real Estate ETF
Cambria Micro and SmallCap Shareholder
Yield ETF
Cambria Tactical Yield ETF
Cambria LargeCap Shareholder Yield ETF*

2022﻿$77,777﻿
$57,564﻿
$4,561﻿$21,386﻿
$2,825﻿
$13,281﻿
$308﻿
$98,860﻿
$5,441﻿$5,822﻿
$31,967﻿
$26,090﻿

2023﻿
$107,004﻿
$39,290﻿
$157,241﻿
$180,766﻿
$240﻿
$35,896﻿
$1,106﻿$115,680﻿
$11,669﻿
$37,417﻿
$11,436﻿
$20,627﻿

2024﻿
$191,725﻿
$111,273﻿
$69,698﻿
$153,307﻿
$3,919﻿
$23,555﻿
$146﻿
$181,730﻿
$2,484﻿
$48,445﻿
$35,634﻿
$23,282﻿

Commencement of
Operations
May 13, 2013
Dec. 2, 2013
Mar. 11, 2014
Nov. 3, 2014
Dec. 9, 2014
Sept. 8, 2015
Feb. 23, 2016
July 14, 2016
Apr. 5, 2017
Sept. 10, 2018
July 24, 2019
Sept. 24, 2020

N/A
N/A
N/A

N/A
N/A
N/A

$2,853*
$0*
N/A

Jan. 5, 2024
Jan. 5, 2024
July 12, 2024

Brokerage commissions paid for the period from the Fund’s commencement of operations.

Brokerage Selection
The Trust does not expect to use one particular broker-dealer to effect the Trust’s portfolio transactions. When one or morebroker-dealers is believed capable of providing the best combination of price and execution, the Adviser or Sub-Adviser
may not select a broker-dealer based on the lowest commission rate available for a particular transaction. In such cases, the56Adviser or Sub-Adviser may pay a higher commission than otherwise obtainable from other brokers in return for brokerageor research services provided to the Adviser or Sub-Adviser consistent with Section 28(e) of the 1934 Act, which provides
that the Adviser or Sub-Adviser may cause a Fund to pay a broker-dealer a commission for effecting a transaction in excessof the amount of commission another broker-dealer would have charged as long as the Adviser or Sub-Adviser makes agood faith determination that the amount of commission is reasonable in relation to the value of the brokerage and researchservices provided by the broker-dealer. To the extent the Adviser or Sub-Adviser obtains brokerage and research services thatit otherwise would acquire at its own expense, the Adviser or Sub-Adviser may have an incentive to place a greater volume oftransactions or pay higher commissions than would otherwise be the case.
The Adviser or Sub-Adviser, as applicable, will only obtain brokerage and research services from broker-dealers in arrangementsthat are consistent with Section 28(e) of the 1934 Act. The types of products and services that the Adviser or Sub-Adviser may
obtain from broker-dealers through such arrangements will include research reports and other information on the economy,
industries, sectors, groups of securities, individual companies, statistical information, political developments, technical market
action, pricing and appraisal services, credit analysis, risk measurement analysis, performance and other analysis. The Adviser
or Sub-Adviser may use products and services provided by brokers in servicing all of its client accounts and not all suchproducts and services may necessarily be used in connection with the account that paid commissions to the broker-dealer
providing such products and services. Any advisory or other fees paid to the Adviser or Sub-Adviser are not reduced as a resultof the receipt of brokerage and research services.
In some cases, the Adviser or Sub-Adviser may receive a product or service from a broker that has both a “research” and a“non-research” use. When this occurs, the Adviser or Sub-Adviser will make a good faith allocation between the research andnon-research uses of the product or service. The percentage of the service that is used for research purposes may be paid forwith brokerage commissions, while the Adviser or Sub-Adviser will use its own funds to pay for the percentage of the service
that is used for non-research purposes. In making this good faith allocation, the Adviser or Sub-Adviser faces a potential
conflict of interest, but each of the Adviser and Sub-Adviser believes that its allocation procedures are reasonably designed toappropriately allocate the anticipated use of such products and services to research and non-research uses.
Directed Brokerage
For the fiscal year ended April 30, 2024, none of the Funds, nor Cambria, nor the Sub-Adviser paid any commissions on
brokerage transactions directed to brokers pursuant to an agreement or understanding with a broker, or otherwise through aninternal allocation procedure, whereby the broker provides research or other brokerage services to Cambria or the Sub-Adviser.
Brokerage with Fund Affiliates
Although not expected, the Funds may execute brokerage or other agency transactions through registered broker-dealer
affiliates of the Fund, Cambria, the Sub-Adviser, or the Distributor for a commission in conformity with the Investment
Company Act, the 1934 Act and rules promulgated by the SEC. Under the Investment Company Act and the 1934 Act, affiliatedbroker-dealers are permitted to receive and retain compensation for effecting portfolio transactions for a Fund on an exchange
if a written contract is in effect between the affiliate and the Fund expressly permitting the affiliate to receive and retain suchcompensation. These rules further require that commissions paid to the affiliate by a Fund for exchange transactions not exceed“usual and customary” brokerage commissions. The rules define “usual and customary” commissions to include amounts thatare “reasonable and fair compared to the commission, fee or other remuneration received or to be received by other brokers inconnection with comparable transactions involving similar securities being purchased or sold on a securities exchange during acomparable period of time.” The Board, including those who are not “interested persons” of the Funds, has adopted proceduresfor evaluating the reasonableness of commissions paid to affiliates and reviews these procedures periodically.
For the fiscal year or period ended April 30, 2024, no Fund paid any commissions to affiliated broker-dealers.
Securities of “Regular Broker-Dealers”
The Funds are required to identify any securities of their “regular brokers and dealers” (as such term is defined in theInvestment Company Act) (or the parent of the regular broker-dealers) that the Funds may hold at the close of their mostrecent fiscal year. “Regular brokers and dealers” of the Trust are the ten brokers or dealers that, during the most recent fiscal
year: (i) received the greatest dollar amounts of brokerage commissions from the Trust’s portfolio transactions; (ii) engaged
as principal in the largest dollar amounts of portfolio transactions of the Trust; or (iii) sold the largest dollar amounts of theTrust’s shares. For the fiscal year ended April 30, 2024, the Funds did not hold any securities of their “regular brokers anddealers.”

57

THE DISTRIBUTOR
The Distributor is ALPS Distributors, Inc. (the “Distributor”), 1290 Broadway, Suite 1000, Denver, Colorado 80203.
Shares will be continuously offered for sale by the Trust through the Distributor only in Creation Units, as described below
under “Transactions in Creation Units.” Shares in less than Creation Units are not distributed by the Distributor. The Distributor
also acts as agent for the Trust. The Distributor will deliver a Prospectus to persons purchasing Shares in Creation Units andwill maintain records of both orders placed with it and confirmations of acceptance furnished by it. The Distributor is abroker-dealer registered under the 1934 Act and a member of the Financial Industry Regulatory Authority, Inc. The Distributor
has no role in determining the investment policies of the Funds or which securities are to be purchased or sold by the Funds.
The Board has adopted a Distribution and Service Plan pursuant to Rule 12b-1 under the Investment Company Act (the“Plan”). In accordance with its Plan, each Fund is authorized to pay an amount up to 0.25% of its average daily net assets
each year for certain distribution-related activities. In addition, if the payment of management fees by a Fund is deemed to beindirect financing by the Fund of the distribution of its shares, such payment is authorized by the Plan. The Plan specificallyrecognizes that Cambria may use its legitimate profits to pay for expenses incurred in connection with providing services
intended to result in the sale of Shares. Cambria may pay amounts to third parties for distribution or marketing services onbehalf of the Funds.
The Plan was adopted in order to permit the implementation of the Funds’ method of distribution. No fees are currently paidby any Fund under the Plan, however, and there are no current plans to impose such fees. In the event such fees were to be
charged, over time they would increase the cost of an investment in a Fund because they would be paid on an ongoing basis. If
fees were charged under the Plan, the Trustees would receive and review at the end of each quarter a written report provided
by the Distributor of the amounts expended under the Plan and the purpose for which such expenditures were made. The Plan
is a compensation plan, which means that, if the Plan were activated, the Distributor would be compensated regardless of its
expenses, as opposed to a reimbursement plan which would reimburse only for expenses incurred.
The Plan will remain in effect for a period of one year and is renewable from year to year with respect to a Fund, so long as its
continuance is approved at least annually (1) by the vote of a majority of the Trustees and (2) by a vote of the majority of those
Independent Trustees who have no direct or indirect financial interest in the Plan (“Rule 12b-1 Trustees”), cast in person at a
meeting called for the purpose of voting on such approval. The Plan may not be amended to increase materially the amount offees paid by any Fund unless such amendment is approved by an Investment Company Act majority vote of the outstanding
shares and by the Fund Trustees in the manner described above. The Plan is terminable with respect to a Fund at any time bya vote of a majority of the Rule 12b-1 Trustees or by an Investment Company Act majority vote of the outstanding shares.
Payments to Financial Intermediaries
A Fund, at its own expense, may pay additional compensation to financial intermediaries for shareholder-related services,
including administrative, recordkeeping and shareholder communication services. In addition, pursuant to any applicable12b-1 plan, the Fund may pay compensation to financial intermediaries for distribution-related services. For example,
compensation may be paid to make Fund shares available to sales representatives and/or customers of a fund supermarket
platform or a similar program sponsor or for services provided in connection with such fund supermarket platforms andprograms. To the extent that a Fund pays all or a portion of such compensation, the payment is designed to compensate thefinancial intermediary for distribution activities and for providing services that would otherwise be provided by the Fund’stransfer agent and/or administrator.
Cambria or another affiliate of the Funds, out of its own resources and not as an expense of the Funds, may provide additional
compensation to financial intermediaries. Such compensation is sometimes referred to as “revenue sharing.” Compensation
received by a financial intermediary from Cambria or another Fund affiliate may include payments for shareholder servicing,marketing and/or training expenses incurred by the financial intermediary, including expenses incurred by the financial
intermediary in educating its salespersons with respect to Fund shares. For example, such compensation may include
reimbursements for expenses incurred in attending educational seminars regarding the Fund, including travel and lodging
expenses. It may also cover costs incurred by financial intermediaries in connection with their efforts to sell Fund shares,
including costs incurred in compensating registered sales representatives and preparing, printing and distributing sales
literature.

58

The amount of compensation paid to different financial intermediaries may vary. The compensation paid to a financial
intermediary may be based on a variety of factors, including average assets under management in accounts distributed and/or
serviced by the financial intermediary, gross sales by the financial intermediary and/or the number of accounts serviced by thefinancial intermediary that invest in the Funds.
Any compensation received by a financial intermediary, whether from the Funds or their affiliates, and the prospect of receivingsuch compensation, may provide the financial intermediary with an incentive to recommend the shares of the Fund over otherpotential investments. Similarly, the compensation may cause financial intermediaries to elevate the prominence of the Fund
within its organization by, for example, placing it on a list of preferred funds.
ACCOUNTING AND LEGAL SERVICE PROVIDERS
Independent Registered Public Accounting Firm
Cohen & Company, Ltd., 1350 Euclid Avenue, Suite 800, Cleveland, Ohio, 44115, serves as the Funds’ independent registeredpublic accounting firm. The independent registered public accounting firm is responsible for auditing the annual financial
statements of the Funds and reviewing the tax returns.
Legal Counsel
Morgan, Lewis & Bockius LLP, located at 1111 Pennsylvania Avenue, N.W., Washington, D.C. 20004, serves as legal counsel
to the Trust.

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ADDITIONAL INFORMATION CONCERNING SHARES
Organization and Description of Shares of Beneficial Interest
The Trust is a Delaware statutory trust and registered open-end investment company. The Trust was organized on September 9,2011 and has authorized capital of unlimited Shares of beneficial interest of no par value that may be issued in more than one
class or series. Currently, the Trust consists of eighteen funds, fifteen of which have commenced operations, and three of whichhave not commenced operations, as of the date of this SAI. Each of the Funds is actively managed. The Board may designate
additional series and classify Shares of a particular series into one or more classes of that series.
Under Delaware law, the Trust is not required to hold an annual shareholders meeting if the Investment Company Act does
not require such a meeting. Generally, there will not be annual meetings of Trust shareholders, but if requested in writing by
shareholders of at least 25% of the outstanding Shares of a Fund, the Trust will call a meeting of shareholders of the relevant
Fund. Shareholders holding two-thirds of Shares outstanding of the relevant Fund may remove Trustees from office by votes
cast at a meeting of Trust shareholders or by written consent.
All Shares are freely transferable. Shares will not have preemptive rights or cumulative voting rights, and none of the Shares
will have any preference to conversion, exchange, dividends, retirements, liquidation, redemption, or any other feature. Shares
have equal voting rights. The Trust Instrument confers upon the Board the power, by resolution, to alter the number of Sharesconstituting a Creation Unit or to specify that Shares of a Fund may be individually redeemable. The Trust reserves the rightto adjust the stock prices of Shares to maintain convenient trading ranges for investors. Any such adjustments would beaccomplished through stock splits or reverse stock splits that would have no effect on the value of an investor’s investment in
the Fund.
The Trust Instrument of the Trust disclaims liability of the shareholders or the officers of the Trust for acts or obligations of
the Trust that are binding only on the assets and property of the Trust. The Trust Instrument provides for indemnification outof a Fund’s property for all loss and expense of the Fund’s shareholders being held personally liable solely by reason of his or
her being or having been a shareholder and not because of his or her acts or omissions or for some other reason. The risk of aTrust shareholder incurring financial loss on account of shareholder liability is limited to circumstances in which a Fund itself
would not be able to meet the Trust’s obligations and this risk should be considered remote.
If a Fund does not grow to a size to permit it to be economically viable, the Fund may cease operations. In such an event,shareholders may be required to liquidate or transfer their Shares at an inopportune time and shareholders may lose money on
their investment.
Book Entry Only System
The following information supplements and should be read in conjunction with the section in the Prospectus entitled “Book
Entry.”
DTC acts as Securities Depository for Shares. Shares of the Funds are represented by securities registered in the name of DTC
or its nominee and deposited with, or on behalf of, DTC.
DTC, a limited purpose trust company, was created to hold securities of its participants (the “DTC Participants”) and to
facilitate the clearance and settlement of securities transactions among the DTC Participants in such securities throughelectronic book entry changes in accounts of the DTC Participants, thereby eliminating the need for physical movement of
securities certificates. DTC Participants include securities brokers and dealers, banks, trust companies, clearing corporations
and certain other organizations, some of whom (and/or their representatives) own DTC. More specifically, DTC is owned by anumber of its DTC Participants and by NYSE and FINRA. Access to the DTC system is also available to others such as banks,
brokers, dealers and trust companies that clear through or maintain a custodial relationship with a DTC Participant, either
directly or indirectly (the “Indirect Participants”).
Beneficial ownership of Shares is limited to DTC Participants, Indirect Participants and persons holding interests through
DTC Participants and Indirect Participants. Ownership of beneficial interests in Shares (owners of such beneficial interests
are referred to herein as “Beneficial Owners”) is shown on, and the transfer of ownership is effected only through, records
maintained by DTC (with respect to DTC Participants) and on the records of DTC Participants (with respect to Indirect
Participants and Beneficial Owners that are not DTC Participants). Beneficial Owners will receive from or through the DTC
Participant a written confirmation relating to their purchase and sale of Shares.

60

Conveyance of all notices, statements and other communications to Beneficial Owners is effected as follows. Pursuant to
the Depositary Agreement between the Trust and DTC, DTC is required to make available to the Trust upon request and fora fee to be charged to the Trust a listing of the Shares of a Fund held by each DTC Participant. The Trust shall inquire ofeach such DTC Participant as to the number of Beneficial Owners holding Shares, directly or indirectly, through such DTC
Participant. The Trust shall provide each such DTC Participant with copies of such notice, statement or other communication,in such form, number and at such place as such DTC Participant may reasonably request, in order that such notice, statement
or communication may be transmitted by such DTC Participant, directly or indirectly, to such Beneficial Owners. In addition,
the Trust shall pay to each such DTC Participant a fair and reasonable amount as reimbursement for the expenses attendant tosuch transmittal, all subject to applicable statutory and regulatory requirements.
Fund distributions shall be made to DTC or its nominee, Cede & Co., as the registered holder of all Shares. DTC or its
nominee, upon receipt of any such distributions, shall immediately credit DTC Participants’ accounts with payments in amounts
proportionate to their respective beneficial interests in Shares of a Fund as shown on the records of DTC or its nominee.
Payments by DTC Participants to Indirect Participants and Beneficial Owners of Shares held through such DTC Participants
will be governed by standing instructions and customary practices, and will be the responsibility of such DTC Participants.
The Trust has no responsibility or liability for any aspect of the records relating to or notices to Beneficial Owners, orpayments made on account of beneficial ownership interests in such Shares, or for maintaining, supervising or reviewing any
records relating to such beneficial ownership interests, or for any other aspect of the relationship between DTC and the DTC
Participants or the relationship between such DTC Participants and the Indirect Participants and Beneficial Owners owning
through such DTC Participants.
DTC may decide to discontinue providing its service with respect to Shares at any time by giving reasonable notice to the Trustand discharging its responsibilities with respect thereto under applicable law. Under such circumstances, the Trust shall takeaction to find a replacement for DTC to perform its functions at a comparable cost.

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TRANSACTIONS IN CREATION UNITS
Each Fund sells and redeems Shares in Creation Units on a continuous basis through the Distributor, without a sales load, at
the NAV next determined after receipt of an order in proper form on any Business Day. As of the date of this SAI, the NYSE
observes the following holidays: New Year’s Day, Martin Luther King, Jr. Day, Presidents’ Day, Good Friday, Memorial Day,
Juneteenth, Independence Day, Labor Day, Thanksgiving Day and Christmas Day. No Fund will issue fractional Creation
Units. Shares of the Funds will only be issued against full payment, as further described in the Prospectus and this SAI.
A Creation Unit is an aggregation of Shares. The Board may declare a split or a consolidation in the number of Shares
outstanding of a Fund or Trust, and make a corresponding change in the number of Shares in a Creation Unit.
To purchase or redeem any Creation Units from a Fund, you must be, or transact through, an Authorized Participant. In order tobe an Authorized Participant, you must be either a broker-dealer or other participant (“Participating Party”) in the Continuous
Net Settlement System (“Clearing Process”) of the National Securities Clearing Corporation (“NSCC”) or a participant in
DTC with access to the DTC system (“DTC Participant”), and you must execute an agreement (“Participant Agreement”) with
the Distributor that governs transactions in the Fund’s Creation Units.
Transactions by an Authorized Participant that is a Participating Party using the NSCC system are referred to as transactions“through the Clearing Process.” Transactions by an Authorized Participant that is a DTC Participant using the DTC system arereferred to as transactions “outside the Clearing Process.” Notwithstanding the foregoing, the Trust may, but is not required
to, permit Orders until 4:00 p.m., Eastern time, or until the market close (in the event the Exchange closes early). In the caseof custom orders (Cash, Cash in Lieu, or Negotiated), the order must be received by the Distributor no later than 3:00 p.m.,
Eastern time on the trade date. A custom order may be placed by an Authorized Participant in the event that the Trust permits
or requires the substitution of securities or the substitution of an amount of cash to be added to the Cash Component to replace
any Deposit Security which may not be available in sufficient quantity for delivery or which may not be eligible for trading
by such Authorized Participant or the investor for which it is acting or other relevant reason. The date on which an order tocreate Creation Unit Aggregations (or an order to redeem Creation Unit Aggregations, as discussed below) is placed is referred
to as the “Transmittal Date.” Orders must be transmitted by an Authorized Participant by telephone or other transmission
method acceptable to the Distributor pursuant to procedures set forth in the Participant Agreement, as described below (seethe “Placement of Creation Orders Using Clearing Process” and the “Placement of Creation Orders Outside Clearing Process”
sections). Severe economic or market disruptions or changes, or telephone or other communication failure may impede theability to reach the Distributor or an Authorized Participant.
Investors who are not Authorized Participants but want to transact in Creation Units may contact the Distributor for the namesof Authorized Participants. An Authorized Participant may require investors to enter into a separate agreement to transact
through it for Creation Units and may require orders for purchases of shares placed with it to be in a particular form. Investors
should be aware that their broker may not be an Authorized Participant and, therefore, may need to place any order to purchaseor redeem Creation Units through another broker or person that is an Authorized Participant, which may result in additionalcharges. There are expected to be a limited number of Authorized Participants at any one time.
Orders must be transmitted by an Authorized Participant by telephone or other transmission method acceptable to the Distributor
pursuant to procedures set forth in the Participant Agreement. Market disruptions and telephone or other communication
failures may impede the transmission of orders.
Purchasing Creation Units
Fund Deposit. The consideration for a Creation Unit of a Fund is the Fund Deposit. The Fund Deposit will consist of the
In-Kind Creation Basket and Cash Component, or an all cash payment (“Cash Value”), as determined by Cambria to be in
the best interest of the Fund. Because any short positions in the Fund’s portfolio cannot be transferred in-kind, they will be
represented by cash in the Cash Component and not in the In-Kind Creation Basket. Generally, the Global Tail Risk ETF andTail Risk ETF will effect redemptions, in whole or in part, for the Cash Value of the Creation Units.
The Cash Component will typically include a “Balancing Amount” reflecting the difference, if any, between the NAV of a
Creation Unit and the market value of the securities in the In-Kind Creation Basket. If the NAV per Creation Unit exceeds themarket value of the securities in the In-Kind Creation Basket, the purchaser pays the Balancing Amount to a Fund. By contrast,
if the NAV per Creation Unit is less than the market value of the securities in the In-Kind Creation Basket, a Fund pays the
Balancing Amount to the purchaser. The Balancing Amount ensures that the consideration paid by an investor for a Creation
Unit is exactly equal to the value of the Creation Unit.
62

The Transfer Agent, in a portfolio composition file sent via the NSCC, generally makes available on each Business Day,
immediately prior to the opening of business on the Exchange (currently 9:30 a.m., Eastern time), a list of the names and therequired number of shares of each security in the In-Kind Creation Basket to be included in the current Fund Deposit for each
Fund (based on information about the Fund’s portfolio at the end of the previous Business Day) (subject to amendment or
correction). If applicable, the Transfer Agent, through the NSCC, also makes available on each Business Day, the estimatedCash Component or Cash Value, effective through and including the previous Business Day, per Creation Unit.
The announced Fund Deposit is applicable, subject to any adjustments as described below, for purchases of Creation Units of
the Funds until such time as the next-announced Fund Deposit is made available. From day to day, the composition of the
In-Kind Creation Basket may change as, among other things, corporate actions and investment decisions by Cambria are
implemented for a Fund’s portfolio. All questions as to the composition of the In-Kind Creation Basket and the validity, form,
eligibility, and acceptance for deposit of any securities shall be determined by a Fund, and the Fund’s determination shall befinal and binding. Each Fund reserves the right to accept a nonconforming (i.e., custom) Fund Deposit.
Payment of any stamp duty or the like shall be the sole responsibility of the Authorized Participant purchasing a Creation Unit.
The Authorized Participant must ensure that all Deposit Securities properly denote change in beneficial ownership.
Cash in lieu. A Fund may, in its sole discretion, permit or require the substitution of an amount of cash (“cash in lieu”) to be
added to the Cash Component to replace any security in the In-Kind Creation Basket. A Fund may permit or require cash in lieu:(a)in the case of bonds, for minor differences when it is impossible to break up bonds beyond certain minimum
sizes needed for transfer and settlement;(b)

for minor differences when rounding is necessary to eliminate fractional shares or lots that are not tradeable
round lots;(c)

TBA Transactions, short position and other positions that cannot be transferred in kind will be excluded
from the Fund Deposit instruments; or(d)to the extent the Fund determines, on a given Business Day, to use a representative sampling of the Fund’s
portfolio.

In addition, purchases of Creation Units may be made in whole or in part on a cash basis, rather than in kind, under thefollowing circumstances:(a)to the extent there is a Balancing Amount;(b)if, on a given Business Day, the Fund announces before the open of trading that all purchases or all purchases
and redemptions on that day will be made entirely in cash;(c)if, upon receiving a purchase order from an Authorized Participant, the Fund determines to require thepurchase to be made entirely in cash;(d)if, on a given Business Day, the Fund requires all Authorized Participants purchasing Shares on that day todeposit cash in lieu of some or all of the Fund Deposit instruments solely because:(i)such instruments are not eligible for transfer either through the NSCC or DTC; or(ii)

in the case of the Fund’s foreign holdings, such instruments are not eligible for trading due to local
trading restrictions, local restrictions on securities transfers or other similar circumstances;(e)

if the Fund permits an Authorized Participant to deposit cash in lieu of some or all of the Fund Deposit
instruments because such instruments are not available in sufficient quantity; or(f)

if the Fund permits a “custom” order, which is an order in which an Authorized Participant is permitted todeposit cash in lieu of some or all of the Fund Deposit instruments because such instruments are not eligible
for trading by an Authorized Participant or the investor on whose behalf the Authorized Participant is acting.

63

Each Fund will comply with the federal securities laws in accepting securities in the In-Kind Creation Basket, including thesecurities in the In-Kind Creation Basket that are sold in transactions that would be exempt from registration under the 1933
Act. All orders involving cash in lieu are considered to be “custom orders.”
Order Cut-Off Time. For an order involving a Creation Unit to be effectuated at a Fund’s NAV on a particular day, it must
be received by the Distributor by or before the deadline for such order (“Order Cut-Off Time”). The Order Cut-Off Time forcreation and redemption orders for the Funds is generally expected to be 4:00 p.m. Eastern time for In-Kind Creation and
Redemption Baskets, and 3:00 p.m. Eastern time for Cash Value transactions. Accordingly, In-Kind Creation and Redemption
Baskets are expected to be accepted until the close of regular trading on the Exchange on each Business Day, which is usually
4:00 p.m. Eastern time. On days when the Exchange or bond markets close earlier than normal (such as the day before aholiday), the Order Cut-Off Time is expected to track the Exchange closing and be similarly earlier than normal.
Custom orders typically clear outside the Clearing Process and, therefore, like other orders outside the Clearing Process, may
need to be transmitted early on the relevant Business Day to be effectuated at that day’s NAV. A custom order may be placed
when, for example, an Authorized Participant cannot transact in a security in the In-Kind Creation or Redemption Basket andadditional cash is included in a Fund Deposit or Fund Redemption in lieu of such security. Custom orders may be required tobe received by the Distributor by 3:00 p.m. Eastern time to be effectuated based on a Fund’s NAV on that Business Day.
In all cases, cash and securities should be transferred to a Fund by the “Settlement Date,” which is generally the Business
Day immediately following the Transmittal Date for cash and securities. Persons placing custom orders or orders involving
Cash Value should be aware of time deadlines imposed by intermediaries, such as DTC and/or the Federal Reserve Bank wire
system, which may delay the delivery of cash and securities by the Settlement Date.
Placement of Creation Orders. All purchase orders must be placed by or through an Authorized Participant. To order aCreation Unit, an Authorized Participant must submit an irrevocable purchase order to the Distributor. In-kind (portions of)purchase orders will be processed through the Clearing Process when it is available. The Clearing Process is an enhanced
clearing process that is available only for certain securities and only to DTC Participants that are also participants in the
Clearing Process of the NSCC. In-kind (portions of) purchase orders not subject to the Clearing Process will go througha manual clearing process run by DTC. Fund Deposits that include government securities must be delivered through theFederal Reserve Bank wire transfer system (“Federal Reserve System”). Fund Deposits that include cash may be delivered
through the Clearing Process or the Federal Reserve System. Certain orders for the Funds may be made outside the Clearing
Process. In-kind deposits of securities for such orders must be delivered through the Federal Reserve System (for government
securities) or through DTC (for corporate securities).
Orders Using Clearing Process. In connection with creation orders made through the Clearing Process, the Distributortransmits, on behalf of the Authorized Participant, such trade instructions as are necessary to effect the creation order. Pursuant
to such trade instructions, the Authorized Participant agrees to deliver the requisite Fund Deposit to the Trust, together withsuch additional information as may be required by the Distributor. An order to create Creation Units through the Clearing
Process is deemed received by the Distributor on the Business Day the order is placed (“Transmittal Date”) if (i) such orderis received by the Distributor by the Closing Time on such Transmittal Date and (ii) all other procedures set forth in theParticipant Agreement are properly followed. Cash Components will be delivered using either the Clearing Process or theFederal Reserve System, as described below.
Orders Outside Clearing Process. Fund Deposits made outside the Clearing Process must state that the DTC Participant is
not using the Clearing Process and that the creation of Creation Units will instead be effected through a transfer of securities
and cash directly through DTC. With respect to such orders, the Fund Deposit transfer must be ordered by the DTC Participanton the Transmittal Date in a timely fashion so as to ensure the delivery of the requisite number of securities in the In-Kind
Creation Basket (whether standard or custom) through DTC to the relevant Trust account by 11:00 a.m., Eastern time, (the“DTC Cut-Off Time”) on the Business Day immediately following the Transmittal Date. The amount of cash equal to the
Cash Component, along with any cash in lieu and Transaction Fee, must be transferred directly to the Custodian through theFederal Reserve Bank wire transfer system in a timely manner so as to be received by the Custodian no later than 12:00 p.m.,
Eastern time, on the Business Day immediately following the Transmittal Date. The delivery of corporate securities throughDTC must occur by 3:00 p.m., Eastern time, on the Business Day immediately following the Transmittal Date. The deliveryof government securities through the Federal Reserve System must occur by 3:00 p.m., Eastern time, on the Business Day
immediately following the Transmittal Date.

64An order to create Creation Units outside the Clearing Process is deemed received by the Distributor on the Transmittal Dateif (i) such order is received by the Distributor by the Closing Time on such Transmittal Date and (ii) all other procedures set
forth in the Participant Agreement are properly followed. If the Custodian does not receive both the required In-Kind Creation
Basket by the DTC Cut-Off Time and the Cash Component by the appointed time, such order may be canceled. Upon written
notice to the Distributor, a canceled order may be resubmitted the following Business Day using a Fund Deposit as newly
constituted to reflect the then-current In-Kind Creation Basket and Cash Component. Except as described in the section titled“Settlement of Foreign Securities and Regular Foreign Holidays,” the delivery of Creation Units so created will occur no later
than the Business Day following the day on which the order is deemed received by the Distributor. Authorized Participants that
submit a canceled order will be liable to a Fund for any losses resulting therefrom.
Orders involving foreign securities are expected to be settled outside the Clearing Process. Thus, upon receipt of an irrevocablepurchase order, the Distributor will notify Cambria and the Custodian of such order. The Custodian, who will have caused
the appropriate local sub-custodian(s) of a Fund to maintain an account into which an Authorized Participant may deliver theFund Deposit (or cash in lieu), with adjustments determined by a Fund, will then provide information of the order to such
local sub-custodian(s). The Authorized Participant must also make available on or before the Settlement, by means satisfactory
to a Fund, immediately available or same day funds in U.S. dollars estimated by the Fund to be sufficient to pay the CashComponent and Transaction Fee.
While, as stated above, Creation Units are generally delivered no later than the Business Day following the day on which theorder is deemed received by the Distributor, as discussed in the section titled “Settlement of Foreign Securities and Regular
Foreign Holidays,” the Cambria Foreign Shareholder Yield ETF, Cambria Emerging Shareholder Yield ETF, Cambria Global
Tail Risk ETF, Cambria Global Value ETF, Cambria Global Momentum ETF, Cambria Cannabis ETF, and Cambria Global
Real Estate ETF may settle Creation Unit transactions on a basis other than the one described above in order to accommodate
foreign market holiday schedules, to account for different treatment among foreign and U.S. markets of dividend record dates
and ex-dividend dates (that is the last day the holder of a security can sell the security and still receive dividends payable on
the security), and in certain other circumstances.
Acceptance of Orders for Creation Units. The Trust reserves the right to reject a creation order transmitted to it by theDistributor in respect of a Fund if: (i) the order is not in proper form; (ii) the investor(s), upon obtaining the Shares, would
own 80% or more of the currently outstanding Shares of a Fund; (iii) the securities delivered do not conform to the In-Kind
Creation Basket for the relevant date; (iv) acceptance of the Fund Deposit would, in the opinion of counsel, be unlawful; (v) the
acceptance or receipt of the order for a Creation Unit would, in the opinion of counsel to the Trust, be unlawful; or (vi) in
the event that circumstances that are outside the control of the Trust, Custodian, Distributor and Cambria make it practically
impossible to process creation orders. Examples of such circumstances include acts of God; public service or utility problems
resulting in telephone, telecopy and computer failures; fires, floods or extreme weather conditions; market conditions or
activities causing trading halts; systems failures involving computer or other information systems affecting the Trust, Cambria,
the Distributor, DTC, NSCC, the Custodian or sub-custodian or any other participant in the creation process; and similar
extraordinary events. The Distributor shall notify an Authorized Participant of its rejection of the order. A Fund, the Custodian,
any sub-custodian and the Distributor are under no duty, however, to give notification of any defects or irregularities inthe delivery of Fund Deposits, and they shall not incur any liability for the failure to give any such notification. Given theimportance of the ongoing issuance of Creation Units to maintaining a market price that is at or close to the underlying NAVof a Fund, the Trust does not intend to suspend acceptance of orders for Creation Units.
Issuance of a Creation Unit. Once a Fund has accepted a creation order, upon next determination of a Fund’s NAV, a Fund will
confirm the issuance of a Creation Unit, against receipt of payment, at such NAV. The Distributor will transmit a confirmationof acceptance to the Authorized Participant that placed the order.
Except as provided below, a Creation Unit will not be issued until a Fund obtains good title to the In-Kind Creation Basket
securities and the Cash Component, along with any cash in lieu and Transaction Fee. Except as described in the section titled“Settlement of Foreign Securities and Regular Foreign Holidays,” the delivery of Creation Units will generally occur no later
than the Business Day following the Transmittal Date for securities.
In certain cases, Authorized Participants will create and redeem Creation Units on the same trade date. In these instances, theTrust reserves the right to settle these transactions on a net basis.

65

With respect to orders involving foreign securities, when the applicable local sub-custodian(s) has confirmed to the Custodianthat the In-Kind Creation Basket (or cash in lieu) has been delivered to a Fund’s account at the applicable sub-custodian(s), theDistributor and Cambria shall be notified of such delivery, and the Fund will issue and cause the delivery of the Creation Unit.
Creation Units may be created in advance of receipt by the Trust of all or a portion of the applicable In-Kind Creation Basket,
provided the purchaser tenders an initial deposit consisting of any available securities in the In-Kind Creation Basket and cash
equal to the sum of the Cash Component and at least 115% of the market value, as adjusted from time to time by Cambria,of the In-Kind Creation Basket securities not delivered (“Additional Cash Deposit”). Such initial deposit will have a value
greater than the NAV of the Creation Unit on the date the order is placed. The order shall be deemed to be received on theTransmittal Date provided that it is placed in proper form prior to 4:00 p.m., Eastern time, on such date, and federal funds inthe appropriate amount are deposited with the Custodian by the DTC Cut-Off Time the following Business Day. If the order is
not placed in proper form by 4:00 p.m., Eastern time, or federal funds in the appropriate amount are not received by the DTC
Cut-Off Time the next Business Day, then the order will be canceled or deemed unreceived and the Authorized Participant
effectuating such transaction will be liable to a Fund for any losses resulting therefrom.
To the extent securities in the In-Kind Creation Basket remain undelivered, pending delivery of such securities additional cash
will be required to be deposited with the Trust as necessary to maintain an Additional Cash Deposit equal to at least 115% (asadjusted by Cambria) of the daily marked-to-market value of the missing securities. To the extent that either such securities arestill not received by 1:00 p.m., Eastern time, on the Business Day following the day on which the purchase order is deemed
received by the Distributor or a marked-to-market payment is not made within one Business Day following notification to thepurchaser and/or Authorized Participant that such a payment is required, the Trust may use the cash on deposit to purchase themissing securities, and the Authorized Participant effectuating such transaction will be liable to a Fund for any costs incurred
therein or losses resulting therefrom, including any Transaction Fee, any amount by which the actual purchase price of themissing securities exceeds the Additional Cash Deposit or the market value of such securities on the day the purchase order
was deemed received by the Distributor, as well as brokerage and related transaction costs. The Trust will return any unused
portion of the Additional Cash Deposit once all of the missing securities have been received by the Trust. The delivery ofCreation Units so created will occur no later than the Business Day following the day on which the purchase order is deemed
received by the Distributor.
Transaction Fees
To compensate the Trust for costs incurred in connection with creation and redemption transactions, investors will be required
to pay to the Trust a Transaction Fee as follows:Standard
Transaction
Fee*
$700
$2,500
$3,500
$500
$3,500
$500
$700
$500
$500
$300﻿
$500
$1,500
$300
$300
$300

Fund
Cambria Shareholder Yield ETF
Cambria Foreign Shareholder Yield ETF
Cambria Emerging Shareholder Yield ETF
Cambria Global Tail Risk ETF
Cambria Global Value ETF
Cambria Global Momentum ETF
Cambria Value and Momentum ETF
Cambria Global Asset Allocation ETF
Cambria Tail Risk ETF
Cambria Trinity ETF
Cambria Cannabis ETF
Cambria Global Real Estate ETF
Cambria Micro and SmallCap Shareholder Yield ETF
Cambria Tactical Yield ETF
Cambria LargeCap Shareholder Yield ETF*

The Transaction Fee may be higher for transactions outside the Clearing Process.

66

Variable
ChargeNone
Up to 2.0%
Up to 2.0%
Up to 2.0%
Up to 2.0%
Up to 2.0%
None
None
None
None
Up to 2.0%
Up to 2.0%
Up to 2.0%
Up to 2.0%
Up to 2.0%

The Standard Transaction Fee applies to in-kind purchases of the Fund effected through the Clearing Process on any Business
Day, regardless of the number of Creation Units purchased or redeemed that day (assuming, in the case of multiple orders on
the same day, that the orders are received at or near the same time). A Transaction Fee of up to four times the standard fee may
apply to creation and redemption transactions that occur outside the Clearing Process. As shown in the table above, certain
Fund Deposits consisting of a Cash Value will be subject to a variable charge of up to 2% including the standard Transaction
Fee. With cash received from the variable charge, Cambria will purchase the necessary securities for the Fund’s portfolio andreturn any unused portion thereof to the investor. The Transaction Fee for redemptions of Creation Units will not exceed 2%of the value of the Creation Unit(s) redeemed.
Cambria may adjust or waive the Transaction Fee from time to time. The Standard Creation/Redemption Transaction Fee
is based, in part, on the number of holdings in a Fund’s portfolio and may be adjusted on a quarterly basis if the number ofholdings increase. Investors will also be responsible for the costs associated with transferring the securities in the In-Kind
Creation (and Redemption) Baskets to (and from) the account of the Trust. Further, investors who, directly or indirectly, use
the services of a broker or other intermediary to compose a Creation Unit in addition to an Authorized Participant to effect atransaction in Creation Units may be charged an additional fee for such services.
Cash Purchase Method. When cash purchases of Creation Units are available or specified for a Fund, they will be effected inessentially the same manner as in-kind purchases. In the case of a cash purchase, the investor must pay the cash equivalent of
the Fund Deposit. In addition, cash purchases may be subject to Transaction Fees.
Redeeming Creation Units
Fund Redemptions. Fund Shares may be redeemed only in Creation Units at their NAV next determined after receipt of aredemption request in proper form by a Fund through the Transfer Agent and only on a Business Day. The redemption proceeds
for a Creation Unit will consist of the In-Kind Redemption Basket and a Cash Redemption Amount, or an all cash payment(“Cash Value”), in all instances equal to the value of a Creation Unit. Because short positions cannot be transferred in kind,
however, any short positions in a Fund’s portfolio will be represented by cash in the Cash Redemption Amount and not in the
In-Kind Redemption Basket.
There can be no assurance that there will be sufficient liquidity in Shares in the secondary market to permit assembly of a
Creation Unit. In addition, investors may incur brokerage and other costs in connection with assembling a Creation Unit.
The Cash Redemption Amount will typically include a Balancing Amount, reflecting the difference, if any, between the NAVof a Creation Unit and the market value of the securities in the In-Kind Redemption Basket. If the NAV per Creation Unit
exceeds the market value of the securities in the In-Kind Redemption Basket, a Fund pays the Balancing Amount to theredeeming investor. By contrast, if the NAV per Creation Unit is less than the market value of the securities in the In-Kind
Redemption Basket, the redeeming investor pays the Balancing Amount to a Fund.
The composition of the In-Kind Creation Basket will normally be the same as the composition of the In-Kind Redemption
Basket. Otherwise, the In-Kind Redemption Basket will be made available by Cambria or the Transfer Agent. Each Fundreserves the right to accept a nonconforming (i.e., custom) Fund Redemption.
In lieu of an In-Kind Redemption Basket and Cash Redemption Amount, Creation Units may be redeemed consisting solelyof cash in an amount equal to the NAV of a Creation Unit, which amount is referred to as the Cash Value. Such redemptions
for the Funds may be subject to a variable charge, as explained above. If applicable, information about the Cash Value will bemade available by Cambria or the Transfer Agent.
From day to day, the composition of the In-Kind Redemption Basket may change as, among other things, corporate actions are
implemented for a Fund’s portfolio. All questions as to the composition of the In-Kind Redemption Basket and the validity,
form, eligibility, and acceptance for deposit of any securities shall be determined by a Fund, and the Fund’s determination shallbe final and binding.
The right of redemption may be suspended or the date of payment postponed: (i) for any period during which the NYSE
is closed (other than customary weekend and holiday closings); (ii) for any period during which trading on the NYSE issuspended or restricted; (iii) for any period during which an emergency exists as a result of which disposal of the Shares ordetermination of a Fund’s NAV is not reasonably practicable; or (iv) in such other circumstances as permitted by the SEC,
including as described below.

67Cash in lieu. A Fund may, in its sole discretion, permit or require the substitution of an amount of cash to be added to the Cash
Redemption Amount to replace any security in the In-Kind Redemption Basket. A Fund may permit or require cash in lieu:(a)in the case of bonds, for minor differences when it is impossible to break up bonds beyond certain minimum
sizes needed for transfer and settlement;(b)

for minor differences when rounding is necessary to eliminate fractional shares or lots that are not tradeable
round lots;(c)

TBA Transactions, short position and other positions that cannot be transferred in kind will be excluded
from the Fund Redemption instruments; or(d)to the extent the Fund determines, on a given Business Day, to use a representative sampling of the Fund’s
portfolio.

In addition, redemptions of Creation Units may be made in whole or in part on a cash basis, rather than in kind, under thefollowing circumstances:(a)to the extent there is a Balancing Amount;(b)if, on a given Business Day, the Fund announces before the open of trading that all redemptions or allpurchases and redemptions on that day will be made entirely in cash;(c)if, upon receiving a redemption order from an Authorized Participant, the Fund determines to require theredemption to be made entirely in cash;(d)if, on a given Business Day, the Fund requires all Authorized Participants redeeming Shares on that day toreceive cash in lieu of some or all of the Fund Redemption instruments solely because:

(e)

(i)

such instruments are not eligible for transfer either through the NSCC or DTC; or(ii)

in the case of the Fund’s foreign holdings, such instruments are not eligible for trading due to local
trading restrictions, local restrictions on securities transfers or other similar circumstances; orif the Fund permits a “custom” order, which is an order in which an Authorized Participant is permitted toreceive cash in lieu of some or all of the Fund Redemption instruments because:(i)such instruments are not eligible for trading by an Authorized Participant or the investor on whose
behalf the Authorized Participant is acting; or(ii)a holder of Shares of the Fund’s foreign holdings would be subject to unfavorable income tax
treatment if the holder receives redemption proceeds in kind.

Each Fund will comply with the federal securities laws in satisfying redemptions with the applicable In-Kind Redemption
Basket, including the securities in the In-Kind Redemption Basket that are sold in transactions that would be exempt fromregistration under the 1933 Act. All redemption orders involving cash in lieu are considered to be “custom redemptions.”
Placement of Redemption Orders. Redemptions must be placed to the Transfer Agent through the Distributor. In addition,
redemption orders must be processed either through the DTC process or the Clearing Process. To redeem a Creation Unit, an
Authorized Participant must submit an irrevocable redemption order to the Distributor.
An Authorized Participant submitting a redemption order is deemed to represent to a Fund that, as of the close of that Business
Day, it (or its client) will own (within the meaning of Rule 200 of Regulation SHO) or has arranged to borrow for delivery to
the Trust on or prior to the settlement date of the redemption request, the requisite number of Shares of the relevant Fund to
be redeemed as a Creation Unit. In either case, the Authorized Participant is deemed to acknowledge that: (i) it (or its client)has full legal authority and legal right to tender for redemption the requisite number of Shares of the applicable Fund and toreceive the entire proceeds of the redemption; and (ii) if such Shares submitted for redemption have been loaned or pledged
to another party or are the subject of a repurchase agreement, securities lending agreement or any other arrangement affecting

68

legal or beneficial ownership of such Shares being tendered, there are no restrictions precluding the tender and delivery ofsuch Shares (including borrowed shares, if any) for redemption, free and clear of liens, on the redemption settlement date. A
Fund reserves the absolute right, in its sole discretion, to verify these representations, but will typically require verification
with respect to a redemption request from a Fund in connection with higher levels of redemption activity and/or short interestin the Fund. If the Authorized Participant, upon receipt of a verification report, does not provide sufficient verification of therequested representations, the redemption order will not be considered to be in proper form and may be rejected by a Fund.
In certain cases, Authorized Participants will create and redeem Creation Units on the same trade date. In these instances, theTrust reserves the right to settle these transactions on a net basis.
Placement of Redemption Orders Using Clearing Process. Orders to redeem Creation Units through the Clearing Process
are deemed received by the Trust on the Transmittal Date if (i) such order is received by the Transfer Agent not later than theOrder Cut-Off Time on such Transmittal Date, and (ii) all other procedures set forth in the Participant Agreement are properly
followed. Orders deemed received will be effectuated based on the NAV of a Fund as next determined. An order to redeem
Creation Units using the Clearing Process made in proper form but received by the Trust after the Order Cut-Off Time will
be deemed received on the next Business Day and will be effected at the NAV next determined on such next Business Day.
In connection with such orders, the Distributor transmits on behalf of the Authorized Participant such trade instructions as
are necessary to effect the redemption. Pursuant to such trade instructions, the Authorized Participant agrees to deliver therequisite Creation Unit(s) to a Fund, together with such additional information as may be required by the Distributor. Cash
Redemption Amounts will be delivered using either the Clearing Process or the Federal Reserve System. The applicable
In-Kind Redemption Basket and the Cash Redemption Amount will be transferred to the investor by the second NSCC
business day following the date on which such request for redemption is deemed received.
Placement of Redemption Orders Outside Clearing Process. Orders to redeem Creation Units outside the Clearing Process
must state that the DTC Participant is not using the Clearing Process and that redemption of Creation Units will instead beeffected through transfer of Shares directly through DTC. Such orders are deemed received by the Trust on the Transmittal
Date if: (i) such order is received by the Transfer Agent not later than the Order Cut-Off Time on the Transmittal Date; (ii) suchorder is accompanied or followed by the delivery of both (a) the Creation Unit(s), which delivery must be made through DTC
to the Custodian no later than the DTC Cut-Off Time on the Business Day immediately following the Transmittal Date and(b) the Cash Redemption Amount by 12:00 p.m., Eastern time, on the Business Day immediately following the Transmittal
Date; and (iii) all other procedures set forth in the Participant Agreement are properly followed. After the Trust has deemedsuch an order received, the Trust will initiate procedures to transfer, and expect to deliver, the requisite In-Kind Redemption
Basket and/or any Cash Redemption Amount owed to the redeeming party by the Business Day following the Transmittal Dateon which such redemption order is deemed received by the Trust.
Orders involving foreign securities are expected to be settled outside the Clearing Process. Thus, upon receipt of an irrevocableredemption order, the Distributor will notify Cambria and the Custodian. The Custodian will then provide information of theredemption to the Fund’s local sub-custodian(s). The redeeming Authorized Participant, or the investor on whose behalf it isacting, will have established appropriate arrangements with a broker-dealer, bank or other custody provider in each jurisdictionin which the securities are customarily traded and to which such securities (and any cash in lieu) can be delivered from a Fund’s
accounts at the applicable local sub-custodian(s).
The calculation of the value of the In-Kind Redemption Basket and the Cash Redemption Amount to be delivered/received
upon redemption will be made by the Custodian computed on the Business Day on which a redemption order is deemed
received by the Trust. Therefore, if a redemption order in proper form is submitted to the Transfer Agent by a DTC Participant
or an Authorized Participant with the ability to transact through the Federal Reserve System, as applicable, not later than
Closing Time on the Transmittal Date, and the requisite number of Shares of the relevant Fund are delivered to the Custodianprior to the DTC Cut-Off-Time, then the value of the In-Kind Redemption Basket and the Cash Redemption Amount to bedelivered/received will be determined by the Custodian on such Transmittal Date. If, however, either: (i) the requisite numberof Shares of the relevant Fund are not delivered by the DTC Cut-Off-Time, as described above, or (ii) the redemption order is
not submitted in proper form, then the redemption order will not be deemed received as of the Transmittal Date. In such case,the value of the In-Kind Redemption Basket and the Cash Redemption Amount to be delivered/received will be computed on
the Business Day following the Transmittal Date provided that the Fund Shares of the relevant Fund are delivered through DTC
to the Custodian by 11:00 a.m., Eastern time, the following Business Day pursuant to a properly submitted redemption order.

69

The Authorized Participant may request the redeeming beneficial owner of the Shares to complete an order form or to enter
into agreements with respect to such matters as compensating cash payment, beneficial ownership of shares or delivery
instructions.
Delivery of Redemption Basket. Once a Fund has accepted a redemption order, upon next determination of the Fund’s NAV,
the Fund will confirm the issuance of an In-Kind Redemption Basket, against receipt of the Creation Unit(s) at such NAV, any
cash in lieu and Transaction Fee. A Creation Unit tendered for redemption and the payment of the Cash Redemption Amount,any cash in lieu and Transaction Fee will be effected through DTC. The Authorized Participant, or the investor on whose behalf
it is acting, will be recorded on the book-entry system of DTC.
In certain cases, Authorized Participants will create and redeem Creation Units on the same trade date. In these instances, theTrust reserves the right to settle these transactions on a net basis.
Cash Redemption Method. When cash redemptions of Creation Units are available or specified for a Fund, they will beeffected in essentially the same manner as in-kind redemptions. In the case of a cash redemption, the investor will receive the
cash equivalent of the In-Kind Redemption Basket minus any Transaction Fees.
Settlement of Foreign Securities and Regular Foreign Holidays
The Funds generally intend to effect deliveries of Creation Units and portfolio securities on a basis of the Transmittal Date(“T”) plus one Business Day (i.e., days on which the national securities exchange is open) (“T+1”). The Funds may effectdeliveries of Creation Units and portfolio securities on a basis other than T+1 in order to accommodate local holiday schedules,
to account for different treatment among foreign and U.S. markets of dividend record dates and ex-dividend dates or undercertain other circumstances. Given that foreign securities settle in accordance with the normal rules of settlement of suchsecurities in the applicable foreign market, coupled with foreign market holiday schedules, the Settlement Date may be up to
14 calendar days after the Transmittal Date in certain circumstances.
The ability of the Trust to effect in-kind creations and redemptions within one Business Day of receipt of an order in good form
is subject, among other things, to the condition that, within the time period from the date of the order to the date of delivery of
the securities, there are no days that are holidays in the applicable foreign market. In such cases, the local market settlement
procedures will not commence until the end of the local holiday periods. For every occurrence of one or more intervening
holidays in the applicable foreign market that are not holidays observed in the U.S. equity market, the redemption settlement
cycle will be extended by the number of such intervening holidays. In addition to holidays, other unforeseeable closings in aforeign market due to emergencies may also prevent the Trust from delivering securities within normal settlement periods. The
proclamation of new holidays, the treatment by market participants of certain days as “informal holidays” (e.g., days on which
no or limited securities transactions occur, as a result of substantially shortened trading hours), the elimination of existing
holidays or changes in local securities delivery practices could affect the information set forth herein at some time in the future.
Because the Funds’ portfolio securities may trade on days that the Funds’ Exchange is closed or on days that are notBusiness Days for the Funds, Authorized Participants may not be able to redeem their Shares, or to purchase and sell Shares on
the Exchange, on days when the NAV of the Funds could be significantly affected by events in the relevant non-U.S. markets.
DETERMINATION OF NET ASSET VALUE
The net asset value, or NAV, of Shares is calculated each business day as of the close of regular trading on the NYSE, generally
4:00 p.m. Eastern time. A Fund’s NAV per Share is computed by dividing the net assets by the number of Shares outstanding.
For further information, see the “Net Asset Value” section of the Prospectus, which is incorporated by reference here.

70

TAXATION
The following is only a summary of certain additional U.S. federal income tax considerations generally affecting the Funds
and their shareholders that is intended to supplement the tax information contained in the Prospectus. No attempt is made topresent a detailed explanation of the tax treatment of the Funds or their shareholders, and the discussion here does not address
investors subject to special rules, such as investors who hold shares through an individual retirement account, 401(k) or othertax-advantaged account. The discussion here and in the Prospectus is not intended as a substitute for careful tax planning.
Shareholders are urged to consult their tax advisors with specific reference to their own tax situations, including their state,
local, and foreign tax liabilities.
The following general discussion of certain federal income tax consequences is based on the Code and the regulations issued
thereunder as in effect on the date of this SAI. New legislation, as well as administrative changes or court decisions, may
significantly change the conclusions expressed herein, and may have a retroactive effect with respect to the transactions
contemplated herein.
Qualification as a Regulated Investment Company. For federal income tax purposes, each Fund has elected (or intends toelect) and intends to qualify each year to be treated as a RIC under Subchapter M of the Code. By following such a policy, each
Fund expects to eliminate or reduce to a nominal amount the federal taxes to which it may be subject. A Fund that qualifies as
a RIC will generally not be subject to federal income taxes on the net investment income and net realized capital gains that theFund timely distributes to its shareholders. The Board reserves the right not to maintain the qualification of a Fund as a RIC if
it determines such course of action to be beneficial to shareholders.
In order to qualify as a RIC under the Code, each Fund must distribute annually to its shareholders at least 90% of its
net investment income (which, includes dividends, taxable interest, and the excess of net short-term capital gains over net
long-term capital losses, less operating expenses) and at least 90% of its net tax exempt interest income, for each tax year, if
any (the “Distribution Requirement”) and also must meet certain additional requirements. Among these requirements are thefollowing: (i) at least 90% of each Fund’s gross income each taxable year must be derived from dividends, interest, paymentswith respect to certain securities loans, and gains from the sale or other disposition of stock, securities, or foreign currencies,
or other income (including but not limited to gains from options, futures or forward contracts) derived with respect to its
business of investing in such stock, securities, or currencies, and net income derived from an interest in a qualified publicly
traded partnership (the “Qualifying Income Test”); and (ii) at the close of each quarter of each Fund’s taxable year: (A) atleast 50% of the value of each Fund’s total assets must be represented by cash and cash items, U.S. government securities,
securities of other RICs and other securities, with such other securities limited, in respect to any one issuer, to an amount not
greater than 5% of the value of each Fund’s total assets and that does not represent more than 10% of the outstanding voting
securities of such issuer, including the equity securities of a qualified publicly traded partnership, and (B) not more than 25%of the value of each Fund’s total assets is invested, including through corporations in which a Fund owns a 20% or more voting
stock interest in the securities (other than U.S. government securities or the securities of other RICs) of any one issuer or the
securities (other than the securities of another RIC) of two or more issuers that a Fund controls and which are engaged in thesame or similar trades or businesses or related trades or businesses, or the securities of one or more qualified publicly tradedpartnerships (the “Asset Test”).
If a Fund fails to satisfy the Qualifying Income or Asset Tests in any taxable year, such Fund may be eligible for relief
provisions if the failures are due to reasonable cause and not willful neglect and if a penalty tax is paid with respect to eachfailure to satisfy the applicable requirements. Additionally, relief is provided for certain de minimis failures of the Asset Test
where the Fund corrects the failure within a specified period. In order to be eligible for the relief provisions with respect to a
failure to meet the Asset Test, the Funds may be required to dispose of certain assets. If a Fund fails to maintain qualification
as a RIC for a tax year, and the relief provisions are not available, the Fund would be subject to federal tax on all of its taxable
income at the regular corporate rate (currently 21%), without any deduction for dividends to shareholders. In such event,distributions (including capital gains distributions) would be taxable as ordinary income to shareholders to the extent of such
Fund’s current and accumulated earnings and profits and non-corporate shareholders may be eligible for taxation at reduced
rates for qualified dividend income and corporate shareholders may benefit from the dividends received deduction available insome circumstances. In addition, the Funds could be required to recognize unrealized gains, pay substantial taxes and interest,and make substantial distributions before requalifying as a RIC. If a Fund determines that it will not qualify for treatment as a
RIC, the Fund will establish procedures to reflect the anticipated tax liability in the Fund’s NAV.

71

The Funds intend to distribute annually to shareholders substantially all of its investment company taxable income (computed
without regard to the dividends paid deduction) and any realized net capital gain (after taking into account any capital loss
carryovers). If a Fund failed to satisfy the Distribution Requirement for any taxable year, the Fund would be taxed as a regular
corporation, with consequences generally similar to those described above. If a Fund meets the Distribution Requirement but
retains some or all of its income or gains, it will be subject to federal income tax to the extent any such income or gains are
not distributed.
A Fund may elect to treat part or all of any “qualified late year loss” as if it had been incurred in the succeeding taxable
year in determining the Fund’s taxable income, net capital gain, net short-term capital gain, and earnings and profits. The
effect of this election is to treat any such “qualified late year loss” as if it had been incurred in the succeeding taxable year
in characterizing Fund distributions for any calendar year. A “qualified late year loss” generally includes net capital loss, net
long-term capital loss, or net short-term capital loss incurred after October 31 of the current taxable year (commonly referred
to as “post-October losses”) and certain other late-year losses.
The treatment of capital loss carryovers for the Funds is similar to the rules that apply to capital loss carryovers of individuals,
which provide that such losses are carried over indefinitely. If a Fund has a “net capital loss” (that is, capital losses in excess ofcapital gains) the excess of the Fund’s net short-term capital losses over its net long-term capital gains is treated as a short-term
capital loss arising on the first day of the Fund’s next taxable year, and the excess (if any) of the Fund’s net long-term capital
losses over its net short-term capital gains is treated as a long-term capital loss arising on the first day of the Fund’s next taxable
year. The carryover of capital losses may be limited under the general loss limitation rules if a Fund experiences an ownershipchange as defined in the Code.
Federal Excise Tax. Notwithstanding the Distribution Requirement described above, which generally requires a Fund to
distribute at least 90% of its annual investment company taxable income and the excess of its exempt interest income (but does
not require any minimum distribution of net capital gain), a 4% non-deductible excise tax will be imposed to the extent a Fundfails to distribute by the end of the calendar year at least 98% of its ordinary taxable income and 98.2% of capital gain net
income (excess of capital gains over capital losses) for the one-year period ending on October 31 of such year (including any
retained amount from the prior calendar year on which a Fund paid no federal income tax). Each Fund intends to make sufficient
distributions to avoid liability for this excise tax but can make no assurance that such tax will be completely eliminated. For
example, a Fund may receive delayed or corrected tax reporting statements from its investments that cause such Fund to accrue
additional income and gains after such Fund has already made its excise tax distributions for the year. In such a situation, aFund may incur an excise tax liability resulting from such delayed receipt of such tax information statements. In addition, aFund may in certain circumstances be required to liquidate Fund investments in order to make sufficient distributions to avoid
federal excise tax liability at a time when the investment adviser might not otherwise have chosen to do so, and liquidation of
investments in such circumstances may affect the ability of a Fund to satisfy the requirement for qualification as a RIC.
Distributions to Shareholders. The Funds receive income generally in the form of dividends on investments. This income,plus net short-term capital gains, if any, less expenses incurred in the operation of a Fund, constitutes the Fund’s net investment
income from which dividends may be paid to you. Any distributions by a Fund from such income will be taxable to you as
ordinary income or at the lower capital gains rates that apply to individuals receiving qualified dividend income (as discussed
below), whether you take them in cash or in additional shares.
Distributions by the Funds are currently eligible for the reduced maximum tax rate to individuals of 20% (lower rates apply
to individuals in lower tax brackets) to the extent that the Funds receive qualified dividend income on the securities they holdand the Funds report the distributions as qualified dividend income. Qualified dividend income is, in general, dividend income
from taxable domestic corporations and certain foreign corporations (e.g., foreign corporations incorporated in a possession of
the United States or in certain countries with a comprehensive tax treaty with the United States, or the stock of which is readily
tradable on an established securities market in the United States). A dividend will not be treated as qualified dividend income
to the extent that: (i) the shareholder has not held the shares on which the dividend was paid for more than 60 days during the
121-day period that begins on the date that is 60 days before the date on which the shares become “ex-dividend” (which isthe day on which declared distributions (dividends or capital gains) are deducted from each Fund’s assets before it calculates
the net asset value) with respect to such dividend, (ii) each Fund has not satisfied similar holding period requirements withrespect to the securities it holds that paid the dividends distributed to the shareholder), (iii) the shareholder is under anobligation (whether pursuant to a short sale or otherwise) to make related payments with respect to substantially similar or
related property, or (iv) the shareholder elects to treat such dividend as investment income under section 163(d)(4)(B) of72

the Code. Therefore, if you lend your shares in a Fund, such as pursuant to a securities lending arrangement, you may lose
the ability to treat dividends (paid while the shares are held by the borrower) as qualified dividend income. Distributions that
the Funds receive from an underlying fund taxable as a RIC or from a REIT will be treated as qualified dividend income only
to the extent so reported by such underlying fund or REIT. A Fund’s investment strategies may limit its ability to distributedividends eligible for treatment as qualified dividend income.
Distributions by the Funds of their net short-term capital gains will be taxable as ordinary income. Capital gain distributions
consisting of a Fund’s net capital gains will be taxable as long-term capital gains for individual shareholders currently set at a
maximum rate of 20% regardless of how long you have held your shares in such Fund.
In the case of corporate shareholders, Fund distributions (other than capital gain distributions) generally qualify for thedividends received deduction to the extent such distributions are so reported and do not exceed the gross amount of qualifying
dividends received by such Fund for the year. Generally, and subject to certain limitations (including certain holding period
limitations), a dividend will be treated as a qualifying dividend if it has been received from a domestic corporation. A Fund’sinvestment strategies may limit its ability to distribute dividends eligible for the dividends received deduction.
To the extent that a Fund makes a distribution of income received by such Fund in lieu of dividends (a “substitute payment”)
with respect to securities on loan pursuant to a securities lending transaction, such income will not constitute qualified dividend
income to individual shareholders and will not be eligible for the dividends received deduction for corporate shareholders.
A RIC that receives business interest income may pass through its net business interest income for purposes of the tax
rules applicable to the interest expense limitations under Section 163(j) of the Code. A RIC’s total “Section 163(j) Interest
Dividend” for a tax year is limited to the excess of the RIC’s business interest income over the sum of its business interest
expense and its other deductions properly allocable to its business interest income. A RIC may, in its discretion, designate allor a portion of ordinary dividends as Section 163(j) Interest Dividends, which would allow the recipient shareholder to treat
the designated portion of such dividends as interest income for purposes of determining such shareholder’s interest expense
deduction limitation under Section 163(j) of the Code. This can potentially increase the amount of a shareholder’s interest
expense deductible under Section 163(j) of the Code. In general, to be eligible to treat a Section 163(j) Interest Dividend asinterest income, you must have held your shares in a Fund for more than 180 days during the 361-day period beginning on thedate that is 180 days before the date on which the share becomes ex-dividend with respect to such dividend. Section 163(j)Interest Dividends, if so designated by a Fund, will be reported to your financial intermediary or otherwise in accordance withthe requirements specified by the IRS.
If, for any calendar year, the total distributions made exceed a Fund’s current and accumulated earnings and profits, the excess
will, for federal income tax purposes, be treated as a tax-free return of capital to each shareholder up to the amount of theshareholder’s basis in his or her Shares, and thereafter as gain from the sale of Shares. The amount treated as a tax-free return ofcapital will reduce the shareholder’s adjusted basis in his or her Shares, thereby increasing his or her potential gain or reducing
his or her potential loss on the subsequent sale of his or her Shares.
A dividend or distribution received shortly after the purchase of shares reduces the NAV of the shares by the amount of thedividend or distribution and, although in effect a return of capital, will be taxable to the shareholder. If the NAV of shareswere reduced below the shareholder’s cost by dividends or distributions representing gains realized on sales of securities,
such dividends or distributions would be a return of investment though taxable to the shareholder in the same manner asother dividends or distributions.
The Funds (or your broker) will inform you of the amount of your ordinary income dividends, qualified dividend income andcapital gain distributions, if any, and will advise you of their tax status for federal income tax purposes shortly after the closeof each calendar year. Distributions may be subject to state and local taxes. If you have not held Fund shares for a full year, theFunds may report and distribute to you, as ordinary income, qualified dividend income or capital gain, a percentage of incomethat is not equal to the actual amount of such income earned during the period of your investment in the Funds.
Dividends declared to shareholders of record in October, November or December and actually paid in January of the following
year will be treated as having been received by shareholders on December 31 of the calendar year in which declared. Under
this rule, therefore, a shareholder may be taxed in one year on dividends or distributions actually received in January of thefollowing year.

73Sales, Exchanges or Redemptions. A sale or exchange of Shares or redemption of Creation Units may give rise to a gain or
loss. In general, any gain or loss realized upon a taxable disposition of Shares by a shareholder will generally be treated ascapital gain or loss if the Shares are capital assets in the shareholder’s hands, and will be long-term capital gain or loss if the
Shares have been held for more than 12 months, and short-term capital gain or loss if the Shares are held for 12 months orless. Any loss realized on a sale or exchange of Shares of a Fund may be disallowed if other substantially identical Shares are
acquired (whether through the automatic reinvestment of dividends or otherwise) within a sixty-one (61) day period beginning
thirty (30) days before and ending thirty (30) days after the date that the Shares are disposed of. In such a case, the basis of
the Shares acquired must be adjusted to reflect the disallowed loss. Any loss upon the sale or exchange of Shares held for six(6) months or less is treated as long-term capital loss to the extent of any long-term capital gain dividends received by theshareholders.
An Authorized Participant who exchanges securities for Creation Units generally will recognize gain or loss from the exchange.
The gain or loss will be equal to the difference between the market value of the Creation Unit(s) at the time of the exchange andthe sum of the exchanger’s aggregate basis in the securities surrendered plus (or minus) the amount of cash paid (or received)for such Creation Unit(s). The ability of Authorized Participants to receive a full or partial cash redemption of Creation Units of
the Fund may limit the tax efficiency of the Fund. A person who redeems one or more Creation Units will generally recognize
a gain or loss equal to the difference between the exchanger’s basis in the Creation Unit(s) and the aggregate market valueof the securities received plus (or minus) the amount of cash received (or paid) for such Creation Unit(s). The IRS, however,
may assert that a loss that is realized by an Authorized Participant upon an exchange of securities for Creation Unit(s) may not
be deducted currently under the rules governing “wash sales” (for an Authorized Participant that does not mark-to-market its
holdings) or on the basis that there has been no significant change in economic position.
The Trust on behalf of a Fund has the right to reject an order for a purchase of Shares of a Fund if the purchaser (or a groupof purchasers) would, upon obtaining the Shares so ordered, own 80% or more of the outstanding Shares of the Fund and if,
pursuant to Section 351 of the Code, the Fund would have a basis in the securities different from the market value of suchsecurities on the date of deposit. The Trust also has the right to require information necessary to determine beneficial Shareownership for purposes of the 80% determination. If a Fund issues Creation Units to a purchaser (or a group of purchasers)
who would, upon obtaining the Shares so ordered, own 80% or more of the outstanding Shares of the Fund, the purchaser (ora group of purchasers) may not recognize gain or loss upon the exchange of securities for Creation Units.
Authorized Participants purchasing or redeeming Creation Units should consult their own tax advisers with respect to the tax
treatment of any creation or redemption transaction and whether the wash sales rule applies and when a loss may be deductible.
Cost Basis Reporting. The cost basis of Shares acquired by purchase will generally be based on the amount paid for the
Shares and then may be subsequently adjusted for other applicable transactions as required by the Code. The difference
between the selling price and the cost basis of Shares generally determines the amount of the capital gain or loss realized on thesale or exchange of Shares. Contact the broker through whom you purchased your Shares to obtain information with respect
to the available cost basis reporting methods and elections for your account.
Net Investment Income Tax. Certain net investment income received by an individual having adjusted gross income inexcess of $200,000 (or $250,000 for married individuals filing jointly) will be subject to a U.S. federal tax of 3.8 percent.
Undistributed net investment income of trusts and estates in excess of a specified amount also will be subject to this tax. Any
taxable dividends (including capital gain distributions) paid by a Fund, and gain realized on the sale or redemption of Fund
shares, will constitute investment income of the type subject to this tax.
Tax Treatment of Complex Securities. The tax principles applicable to transactions in financial instruments that may beengaged in by a Fund are complex and, in some cases, uncertain. Such transactions and investments may affect a Fund’s ability
to qualify as a RIC and/or cause a Fund to recognize taxable income prior to the receipt of cash, thereby requiring the Fundto liquidate other positions or to borrow money so as to make sufficient distributions to shareholders to avoid corporate-leveltax. Moreover, some or all of the taxable income recognized may be ordinary income or short-term capital gain, so thatthe distributions may be taxable to shareholders as ordinary income. In limited cases, the tax rules applicable to a Fund’sinvestment in complex securities may subject the Funds to U.S. federal income tax on income from certain of their foreign
securities. In turn, these rules may affect the amount, timing or character of the income distributed to you by the Funds. To theextent a Fund invests in an underlying fund that is taxable as a RIC, the following discussion regarding the tax treatment ofcomplex securities will also apply to the underlying funds that also invest in such complex securities and investments.

74

Certain derivative investments by a Fund, such as exchange-traded products and OTC derivatives may not produce qualifying
income for purposes of the Qualifying Income Test described above, which must be met in order for the Fund to maintain its
status as a RIC under the Code. In addition, the determination of the value and the identity of the issuer of such derivative
investments are often unclear for purposes of the Asset Test described above. Each Fund intends to carefully monitor suchinvestments to ensure that any non-qualifying income does not exceed permissible limits and to ensure that they are adequately
diversified under the Asset Test. A Fund, however, may not be able to accurately predict the non-qualifying income from theseinvestments and there are no assurances that the IRS will agree with the Fund’s determination of the Asset Test with respect
to such derivatives.
Special rules govern the federal income tax treatment of certain transactions denominated in a currency other than the U.S. dollar
or determined by reference to the value of one or more currencies other than the U.S. dollar. These special rules of the Codemay, among other things, affect the character of gains and losses realized by the Fund (i.e., may affect whether gains or losses
are ordinary or capital), accelerate recognition of income to the Fund and defer losses. These rules could therefore affect thecharacter, amount and timing of distributions to shareholders. These provisions also may require a Fund to mark-to-market
certain types of positions in its portfolio (i.e., treat them as if they were closed out) which may cause the Fund to recognize
income without receiving cash with which to make distributions in amounts necessary to satisfy the Distribution Requirement
and for avoiding the excise tax described above. With respect to transactions covered by the special rules, foreign currency gainor loss is calculated separately from any gain or loss on the underlying transaction and is normally taxable as ordinary income
or loss. These gains or losses increase or decrease the amount of a Fund’s investment company taxable income available to be
distributed to its shareholders as ordinary income, rather than increasing or decreasing the amount of that Fund’s net capital
gain. A taxpayer may elect to treat as capital gain or loss foreign currency gain or loss arising from certain identified forward
contracts that are capital assets in the hands of the taxpayer and that are not part of a straddle. The Funds intend to monitor theirtransactions, intend to make the appropriate tax elections, and intend to make the appropriate entries in their books and records
when they acquire any foreign currency or forward foreign currency contract in order to mitigate the effect of these rules so as
to prevent disqualification of a Fund as a RIC and minimize the imposition of income and excise taxes.
Additionally, the Treasury Department has authority to issue regulations that would exclude foreign currency gains from the
Qualifying Income Test described above if such gains are not directly related to a Fund’s business of investing in stock or
securities (or options and futures with respect to stock or securities). Accordingly, regulations may be issued in the future that
could treat some or all of a Fund’s non-U.S. currency gains as non-qualifying income, thereby potentially jeopardizing theFund’s status as a RIC for all years to which the regulations are applicable.
Each Fund is required for federal income tax purposes to mark-to-market and recognize as income for each taxable year its
net unrealized gains and losses on certain futures and options contracts subject to section 1256 of the Code (“Section 1256
Contracts”) as of the end of the year as well as those actually realized during the year. Gain or loss from Section 1256
Contracts on broad-based indexes required to be marked to market will be 60% long-term and 40% short-term capital gainor loss. Application of this rule may alter the timing and character of distributions to shareholders. A Fund may be required
to defer the recognition of losses on Section 1256 Contracts to the extent of any unrecognized gains on offsetting positions
held by the Fund. These provisions may also require the Funds to mark-to-market certain types of positions in their portfolios(i.e., treat them as if they were closed out), which may cause a Fund to recognize income without receiving cash with which to
make distributions in amounts necessary to satisfy the Distribution Requirement described above and for avoiding the excise
tax discussed above. Accordingly, in order to avoid certain income and excise taxes, a Fund may be required to liquidate its
investments at a time when the investment adviser might not otherwise have chosen to do so.
Offsetting positions held by a Fund involving certain derivative instruments, such as options, forwards, and futures, as well as
its long and short positions in portfolio securities, may be considered to constitute “straddles” for federal income tax purposes.
In general, straddles are subject to certain rules that may affect the amount, character and timing of a Fund’s gains and losses
with respect to the straddle positions by requiring, among other things, that: (1) any loss realized on disposition of one positionof a straddle may not be recognized to the extent that the Fund has unrealized gains with respect to the other positions instraddle; (2) the Fund’s holding period in straddle positions be suspended while the straddle exists (possibly resulting in again being treated as short-term rather than long-term capital gain); (3) the losses recognized with respect to certain straddle
positions that are part of a mixed straddle and are non-Section 1256 Contracts be treated as 60% long-term and 40% short-term
capital loss; (4) losses recognized with respect to certain straddle positions that would otherwise constitute short-term capital
losses be treated as long-term capital losses; and (5) the deduction of interest and carrying charges attributable to certain
straddle positions may be deferred. Various elections are available to the Funds, which may mitigate the effects of the straddle
rules, particularly with respect to mixed straddles.

75

If a Fund enters into a “constructive sale” of any appreciated financial position in its portfolio, the Fund will be treated as if
it had sold and immediately repurchased the property and must recognize gain (but not loss) with respect to that position. A
constructive sale of an appreciated financial position occurs when a Fund enters into certain offsetting transactions with respect
to the same or substantially identical property, including, but not limited to: (i) a short sale; (ii) an offsetting notional principal
contract; (iii) a futures or forward contract; or (iv) other transactions identified in future Treasury Regulations. The characterof the gain from constructive sales will depend upon a Fund’s holding period in the appreciated financial position. Losses
realized from a sale of a position that was previously the subject of a constructive sale will be recognized when the position issubsequently disposed of. The character of such losses will depend upon a Fund’s holding period in the position beginning withthe date the constructive sale was deemed to have occurred and the application of various loss deferral provisions in the Code.
Constructive sale treatment does not apply to certain closed transactions, including if such a transaction is closed on or before
the 30th day after the close of a Fund’s taxable year and the Fund holds the appreciated financial position unhedged throughout
the 60-day period beginning with the day such transaction was closed.
With respect to investments in “Separate Trading of Registered Interest and Principal of Securities” or STRIPS, Treasury
Receipts, and other zero coupon securities which are sold at original issue discount and thus do not make periodic cash interest
payments, a Fund will be required to include as part of its current income the imputed interest on such obligations eventhough the Fund has not received any interest payments on such obligations during that period. Because each Fund intends todistribute all of its net investment income to its shareholders, a Fund may have to sell Fund securities to distribute such imputed
income which may occur at a time when the Adviser would not have chosen to sell such securities and which may result intaxable gain or loss.
Any market discount recognized by the Funds on a bond is taxable as ordinary income. A market discount bond is a bondacquired in the secondary market at a price below redemption value or adjusted issue price if issued with original issue
discount. Absent an election by a Fund to include the market discount in income as it accrues, gain on the Fund’s dispositionof such an obligation will be treated as ordinary income rather than capital gain to the extent of the accrued market discount.
A Fund may invest in inflation-linked debt securities. Any increase in the principal amount of an inflation-linked debt security
will be original interest discount, which is taxable as ordinary income and is required to be distributed, even though the Fund
will not receive the principal, including any increase thereto, until maturity. As noted above, if a Fund invests in such securities
it may be required to liquidate other investments, including at times when it is not advantageous to do so, in order to satisfy its
distribution requirements and to eliminate any possible taxation at the Fund level.
A Fund may invest in U.S. REITs. Investments in U.S. REIT equity securities may require a Fund to accrue and distributeincome not yet received. To generate sufficient cash to make the requisite distributions, a Fund may be required to sell securities
in its portfolio (including when it is not advantageous to do so) that it otherwise would have continued to hold. A Fund’sinvestments in REIT equity securities may at other times result in a Fund’s receipt of cash in excess of the REIT’s earnings; if
a Fund distributes these amounts, these distributions could constitute a return of capital to such Fund’s shareholders for federal
income tax purposes. Dividends paid by a REIT, other than capital gain distributions, will be taxable as ordinary income up to
the amount of the REIT’s current and accumulated earnings and profits. Capital gain dividends paid by a REIT to a Fund willbe treated as long-term capital gains by the Fund and, in turn, may be distributed by the Fund to its shareholders as a capitalgain distribution. Dividends received by a Fund from a REIT generally will not constitute qualified dividend income or qualify
for the dividends received deduction. If a REIT is operated in a manner such that it fails to qualify as a REIT, an investmentin the REIT would become subject to double taxation, meaning the taxable income of the REIT would be subject to federal
income tax at the regular corporate rate without any deduction for dividends paid to shareholders and the dividends would betaxable to shareholders as ordinary income (or possibly as qualified dividend income) to the extent of the REIT’s current andaccumulated earnings and profits.
“Qualified REIT dividends” (i.e., ordinary REIT dividends other than capital gain dividends and portions of REIT dividends
designated as qualified dividend income eligible for capital gain tax rates) are eligible for a 20% deduction by non-corporate
taxpayers. This deduction, if allowed in full, equates to a maximum effective tax rate of 29.6% (37% top rate applied to income
after 20% deduction). Distributions by a Fund to its shareholders that are attributable to qualified REIT dividends received bysuch Fund and which such Fund properly reports as “section 199A dividends,” are treated as “qualified REIT dividends” in thehands of non-corporate shareholders. A section 199A dividend is treated as a qualified REIT dividend only if the shareholder
receiving such dividend holds the dividend-paying RIC shares for at least 46 days of the 91-day period beginning 45 days
before the shares become ex-dividend, and is not under an obligation to make related payments with respect to a position in
substantially similar or related property. A Fund is permitted to report such part of its dividends as section 199A dividends
as are eligible but is not required to do so. Unless later extended or made permanent, this 20% deduction will no longer beavailable for taxable years beginning after December 31, 2025.

76

REITs in which a Fund invests often do not provide complete and final tax information to the Funds until after the time that theFunds issue a tax reporting statement. As a result, a Fund may at times find it necessary to reclassify the amount and characterof its distributions to you after it issues your tax reporting statement. When such reclassification is necessary, a Fund (or yourbroker) will send you a corrected, final Form 1099-DIV to reflect the reclassified information. If you receive a corrected
Form 1099-DIV, use the information on this corrected form, and not the information on the previously issued tax reportingstatement, in completing your tax returns.
If a Fund owns shares in certain foreign investment entities, referred to as “passive foreign investment companies” or “PFICs,”the Fund will generally be subject to one of the following special tax regimes: (i) the Fund may be liable for U.S. federal income
tax, and an additional interest charge, on a portion of any “excess distribution” from such foreign entity or any gain from thedisposition of such shares, even if the entire distribution or gain is paid out by the Fund as a dividend to its shareholders; (ii) if
the Fund were able and elected to treat a PFIC as a “qualified electing fund” or “QEF,” the Fund would be required each year toinclude in income, and distribute to shareholders in accordance with the Distribution Requirement set forth above, the Fund’s
pro rata share of the ordinary earnings and net capital gains of the PFIC, whether or not such earnings or gains are distributed
to the Fund; or (iii) the Fund may be entitled to mark-to-market annually shares of the PFIC, and in such event would be
required to distribute to shareholders any such mark-to-market gains in accordance with the Distribution Requirement set forth
above. Amounts included in income each year by a Fund arising from a QEF election, will be “qualifying income” under the
Qualifying Income Test (as described above) even if not distributed to such Fund, if such Fund derives such income from its
business of investing in stock, securities or currencies. Each Fund intends to make the appropriate tax elections, if possible,
and take any additional steps that are necessary to mitigate the effect of these rules.
Foreign Taxes. Investment income received by the Funds from sources within foreign countries and gains they realize on thedisposition of foreign securities may be subject to foreign income taxes withheld at the source, which would reduce the yieldon the Funds stock or securities. The U.S. has entered into tax treaties with many foreign countries that may entitle the Funds
to a reduced rate of such taxes or exemption from taxes on such income. It is impossible to know the effective rate of foreign
tax in advance since the amount of the Funds’ assets to be invested within various countries cannot be determined. If more than
50% of the value of a Fund’s total assets at the close of its taxable year consists of stocks or securities of foreign issuers, that
Fund will be eligible and intends to file an election with the IRS that may enable shareholders, in effect, to receive either the
benefit of a foreign tax credit, or a deduction from such taxes, with respect to any foreign and U.S. possessions income taxes
paid by the Fund, subject to certain limitations. However, there can be no assurance that a Fund will be able to do so. Pursuant
to this election, you will be required to (1) include in gross income (in addition to taxable dividends actually received) your pro
rata share of foreign taxes paid by that Fund, (2) treat your pro rata share of such foreign taxes as having been paid by you and(3) either deduct such pro rata share of foreign taxes in computing your taxable income or treat such foreign taxes as a credit
against federal income taxes. You may be subject to rules that limit or reduce your ability to fully deduct or claim a credit foryour pro rata share of the foreign taxes paid by the Fund in which you invest. If a Fund makes the election, such Fund (or yourbroker) will report annually to their shareholders the respective amounts per share of the Fund’s income from sources within,and taxes paid to, foreign countries and U.S. possessions.
Foreign tax credits, if any, received by a Fund as a result of an investment in another RIC (including an ETF which is taxable
as a RIC) will not be passed through to you unless the Fund qualifies as a “qualified fund-of-funds” under the Code. If theCambria Global Momentum ETF, Cambria Trinity ETF, Cambria Global Tail Risk ETF, and Cambria Global Asset Allocation
ETF are “qualified fund-of-funds” they will be eligible to file an election with the IRS that will enable them to pass along
these foreign tax credits to their shareholders. The Cambria Global Momentum ETF, Cambria Trinity ETF, Cambria Global
Tail Risk ETF, and Cambria Global Asset Allocation ETF will be treated as “qualified fund of funds” under the Code if at least
50% of the value of their total assets (at the close of each quarter of their respective taxable year) is represented by interests
in other RICs.
To the extent a Fund invests in an underlying fund (including an ETF) that indicates that such underlying fund intends to satisfy
the tax requirements to be treated as a RIC under the Code, the Fund may be able to receive the benefits of a “qualified fund offunds” as described above. If, however, an underlying fund loses its status as a RIC under the Code, a Fund would no longer bepermitted to count its investment in such underlying fund for purposes of satisfying the requirements to be a “qualified fund offunds.” In addition, an underlying fund that loses its status as a RIC would be treated as a regular corporation subject to entity
level taxation prior to making any distributions to a Fund which would affect the amount, timing and character of such income
distributed by an underlying fund to a Fund.

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Tax-Exempt Shareholders. Certain tax-exempt shareholders, including qualified pension plans, individual retirement
accounts, salary deferral arrangements, 401(k)s, and other tax-exempt entities, generally are exempt from federal income
taxation except with respect to their unrelated business taxable income (“UBTI”). Tax-exempt entities are not permitted tooffset losses from one trade or business against the income or gain of another trade or business. Certain net losses incurred prior
to January 1, 2018 are permitted to offset gain and income created by an unrelated trade or business, if otherwise available.
Under current law, the Funds generally serve to block UBTI from being realized by their tax-exempt shareholders. However,notwithstanding the foregoing, the tax-exempt shareholder could realize UBTI by virtue of an investment in a Fund where, forexample: (i) the Fund invests in residual interests of Real Estate Mortgage Investment Conduits (“REMICs”), (ii) the Fundinvests in a REIT that is a taxable mortgage pool (“TMP”) or that has a subsidiary that is a TMP or that invests in the residualinterest of a REMIC, or (iii) shares in the Fund constitute debt-financed property in the hands of the tax-exempt shareholder
within the meaning of section 514(b) of the Code. Charitable remainder trusts are subject to special rules and should consult
their tax advisor. The IRS has issued guidance with respect to these issues and prospective shareholders, especially charitableremainder trusts, are strongly encouraged to consult their tax advisors regarding these issues.
A Fund’s shares held in a tax-qualified retirement account will generally not be subject to federal taxation on income andcapital gains distributions from a Fund until a shareholder begins receiving payments from their retirement account. Because
each shareholder’s tax situation is different, shareholders should consult their tax advisor about the tax implications of aninvestment in the Funds.
Backup Withholding. The Funds (or financial intermediaries, such as brokers, through which a shareholder holds Shares)
will be required in certain cases to impose “backup withholding” at a rate of 24% and remit to the U.S. Treasury the amountwithheld on amounts paid to shareholders who have failed to provide a correct tax identification number in the manner required,
who are subject to backup withholding by the IRS for failure properly to include on their return payments of taxable interest
or dividends, who have failed to certify to the Funds when required to do so that they are not subject to backup withholding,or who have failed to certify to the Funds that they are a U.S. person (including a resident alien). Backup withholding is not an
additional tax and any amounts withheld may be credited against a shareholder’s ultimate federal income tax liability if proper
documentation is provided.
Non-U.S. Investors. Any non-U.S. investors in the Funds may be subject to U.S. withholding and estate tax and areencouraged to consult their tax advisors prior to investing in the Funds. Except as described below, dividends paid by aFund to non-U.S. Shareholders (i.e., nonresident alien individuals and foreign corporations, partnerships, trusts and estates)
are generally subject to withholding tax at a 30% rate or a reduced rate specified by an applicable income tax treaty to theextent derived from taxable ordinary income. In order to obtain a reduced rate of withholding, a non-U.S. Shareholder will be
required to provide an IRS Form W-8BEN or W-8BEN-E certifying its entitlement to benefits under a treaty. The withholding
tax does not apply to regular dividends paid to a non-U.S. Shareholder who provides a Form W-8ECI, certifying that thedividends are effectively connected with the non-U.S. Shareholder’s conduct of a trade or business within the United States.
Instead, the effectively connected dividends will be subject to regular U.S. income tax as if the non-U.S. Shareholder were a
U.S. Shareholder. A non-U.S. corporation receiving effectively connected dividends may also be subject to additional “branch
profits tax” imposed at a rate of 30% (or lower treaty rate). A non-U.S. Shareholder who fails to provide an IRS Form W-8BEN
or other applicable form may be subject to backup withholding at the appropriate rate.
In general, withholding tax will not apply to any distributions to a non-U.S. Shareholder of net long-term capital gains over net
short-term capital loss or upon such a shareholder’s sale or other disposition of Shares. A Fund may, under certain circumstances,
report all or a portion of a dividend as an “interest-related dividend” or a “short-term capital gain dividend,” which would
generally be exempt from this 30% U.S. withholding tax, provided certain other requirements are met. Short-term capital gain
dividends received by a nonresident alien individual who is present in the U.S. for a period or periods aggregating 183 daysor more during the taxable year are not exempt from this 30% withholding tax. Gains realized by foreign shareholders fromthe sale or other disposition of shares of a Fund generally are not subject to U.S. taxation, unless the recipient is an individual
who is physically present in the U.S. for 183 days or more per year. Foreign shareholders who fail to provide an applicable IRS
form may be subject to backup withholding on certain payments from the Fund. Backup withholding will not be applied to
payments that are subject to the 30% (or lower applicable treaty rate) withholding tax described in this paragraph. Different tax
consequences may result if the foreign shareholder is engaged in a trade or business within the United States. In addition, the tax
consequences to a foreign shareholder entitled to claim the benefits of a tax treaty may be different than those described above.
Under legislation known as “FATCA” (the Foreign Account Tax Compliance Act), a U.S. withholding tax of 30% will apply to
payments to certain foreign entities of U.S.-source interest and dividends unless various U.S. information reporting and due
diligence requirements that are different from, and in addition to, the beneficial owner certification requirements described78

above have been satisfied. A non-U.S. shareholder may be exempt from the withholding described in this paragraph under anapplicable intergovernmental agreement between the U.S. and a foreign government, provided that the shareholder and theapplicable foreign government comply with the terms of the agreement. The Fund will not pay an additional amounts in respect
to any amounts withheld. Non-U.S. shareholders should consult their tax advisers regarding the effect, if any, of this legislationon their ownership and sale or disposition of a Fund’s common shares.
Tax Shelter Reporting Regulations. Under U.S. Treasury regulations, generally, if a shareholder recognizes a loss of$2 million or more for an individual shareholder or $10 million or more for a corporate shareholder, the shareholder mustfile with the IRS a disclosure statement on Form 8886. Direct shareholders of portfolio securities are in many cases exceptedfrom this reporting requirement, but under current guidance, shareholders of a RIC such as a Fund are not excepted. Future
guidance may extend the current exception from this reporting requirement to shareholders of most or all RICs. The fact thata loss is reportable under these regulations does not affect the legal determination of whether the taxpayer’s treatment of theloss is proper. Shareholders should consult their tax advisors to determine the applicability of these regulations in light of theirindividual circumstances.
State Taxes. Depending upon state and local law, distributions by a Fund to its shareholders and the ownership of such shares
may be subject to state and local taxes. Rules of state and local taxation of dividend and capital gains distributions from RICs
often differ from the rules for federal income taxation described above. It is expected that a Fund will not be liable for any
corporate excise, income or franchise tax in Delaware if it qualifies as a RIC for federal income tax purposes.
Many states grant tax-free status to dividends paid to you from interest earned on direct obligations of the U.S. government,
subject in some states to minimum investment requirements that must be met by a Fund. Investment in Ginnie Mae or
Fannie Mae securities, banker’s acceptances, commercial paper, and repurchase agreements collateralized by U.S. government
securities do not generally qualify for such tax-free treatment. The rules on exclusion of this income are different for corporateshareholders. Shareholders are urged to consult their tax advisors regarding state and local taxes applicable to an investment
in a Fund.
General Considerations. The federal income tax discussion set forth above is for general information only. Prospective
investors should consult their tax advisors regarding the specific federal income tax consequences of purchasing, holding anddisposing of Shares, as well as the effect of state, local and foreign tax law and any proposed tax law changes.
FINANCIAL STATEMENTS
The audited financial statements of each Fund for the fiscal year ended April 30, 2024, including the Notes thereto and thereport of Cohen & Company, Ltd., the Funds’ independent registered public accounting firm, are incorporated by reference tothe Funds’ annual report to shareholders dated April 30, 2024.

79

Appendix A
Proxy Voting Policies and Procedures for the Trust
Tidal Investments LLC(the “Company” or the “Sub-Adviser”)
Proxy Voting Policies
1.

GeneralAs a fiduciary, an investment adviser with proxy voting authority has a duty to monitor corporate events and to vote proxies,
as well as a duty to cast votes in the best interest of clients and not subrogate client interests to its own interests. Rule 206(4)-6
under the Advisers Act (the “Proxy Voting Rule”) places specific requirements on registered investment advisers with proxyvoting authority. Because the Company has discretionary authority over the securities held by each series of Cambria ETF
Trust as well as various other advisory Client accounts (together, the “Clients”), the Company is viewed as having proxyvoting authority and is subject to the Proxy Voting Rule. To meet the obligations under this rule, the Company has adopted
and implemented policies and procedures reasonably designed to ensure the Company votes proxies in the best interest of its
Clients and addresses how it will resolve any conflict of interest that may arise when voting proxies. Additionally, the Company
will: (i) maintain certain records required to be maintained by the Proxy Voting Rule relating to all voted proxies; (ii) disclose
its proxy voting policies and procedures to Clients and upon request providing Clients with a copy of it; and (iii) inform Clientsas to how they can obtain information from the Company as to how their securities were voted.
The Company has adopted the following Proxy Voting Guidelines (the “Guidelines”) in an effort to comply with the Proxy
Voting Rule.
The Portfolio Managers and the Chief Compliance Officer (or their Designated Persons) will generally adhere to the following
procedures (subject to limited exception):a.

A written record of each proxy received by the Sub-Adviser will be maintained in the Sub-Adviser’s files;b.

The Portfolio Management Team (or designee) will determine which of the Advisory Clients hold the security towhich the proxy relates;c.

Confirm that the proxy materials received relate to the correct number of shares, as of the record date;d.

Confirm if there are any conflicts of interest related to the proxy in question in accordance with the general guidelines
below. If a conflict is identified, the Portfolio Managers and the Chief Compliance Officer together will make adetermination as to whether the conflict is material.

e.

If the conflict is not material, the Sub-Adviser will proceed to vote the proxy. The Sub-Adviser also has the flexibility
to abstain from a particular proxy vote if doing so would be in the best interests of the Clients, taking into accountassociated costs, benefits, and interests of the Clients.

The Company may retain a third party to assist it in coordinating and voting proxies with respect to Client securities (which
may include the Client’s prime broker(s)). If so, the Chief Compliance Officer shall monitor the third party to assure that all
proxies are being properly voted and appropriate records are being retained. The Company bases its voting decisions on its
policy guidelines which are driven by considerations of the best interests of its Clients and mutual fund shareholders. The
Company will generally vote in favor of management positions however they must coincide with the best interests of its Clientsand fund shareholders.
2.

Conflicts of Interest

As stated above, in evaluating how to vote a proxy, the Sub-Adviser will first determine whether there is a conflict of interest
related to the proxy in question between the Sub-Adviser and the Advisory Clients. This examination will include (but will
not be limited to) an evaluation of whether the Sub-Adviser (or any affiliate of the Sub-Adviser) has any relationship with thecompany (or an affiliate of the company) to which the proxy relates outside an investment in such company by an Advisory
Client managed by the Sub-Adviser.

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If a conflict is identified and deemed to be material, the Sub-Adviser will generally seek to mitigate the conflict by either
appointing an independent third party to vote the proxy or disclosing the conflict to affected Advisory Clients and/or
Investors.
3.

Recordkeeping

Pursuant to the Proxy Voting Rule, the Company shall retain the following five (5) types of records relating to proxy voting:(i) proxy voting policy and procedures, including any proxy advisory firm’s proxy voting policy and procedures; (ii) proxystatements received for Client securities; (iii) records of votes cast on behalf of Clients; (iv) written Client requests for proxyvoting information and written adviser responses to any Client request (whether oral or written) for proxy voting information;and (v) any documents prepared by the Company that were material to making a proxy voting decision or that memorialized
the basis for the decision.
These records shall be maintained and preserved in an easily accessible place for a period of not less than six (6) years from theend of the Company’s fiscal year during which the last entry was made in the records, the first two (2) years in an appropriate
office of the Company. The Company may rely on proxy statements filed on the SEC’s EDGAR system or on proxy statements
and records of votes cast by the Company maintained by a third party, such as a proxy voting service (provided the Company
had obtained an undertaking from the third party to provide a copy of the proxy statement or record promptly on request). The
CCO is responsible for ensuring all Clients, who have given the Company proxy voting authority, are voted and for maintaining
a record of all proxies voted.

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Appendix B
Description Of Securities Ratings
Corporate and Municipal Long-Term Bond Ratings
Standard & Poor’s (“S&P”) Corporate and Municipal Long-Term Bond Ratings:
The following descriptions of S&P’s long-term corporate and municipal bond ratings have been published by Standard &Poor’s Financial Service LLC.
AAA - An obligation rated ‘AAA’ has the highest rating assigned by S&P. The obligor’s capacity to meet its financial
commitment on the obligation is extremely strong.
AA - An obligation rated ‘AA’ differs from the highest-rated obligations only to a small degree. The obligor’s capacity to meetits financial commitment on the obligation is very strong.
A - An obligation rated ‘A’ is somewhat more susceptible to the adverse effects of changes in circumstances and economic
conditions than obligations in higher-rated categories. However, the obligor’s capacity to meet its financial commitment on the
obligation is still strong.
BBB - An obligation rated ‘BBB’ exhibits adequate protection parameters. However, adverse economic conditions or changing
circumstances are more likely to lead to a weakened capacity of the obligor to meet its financial commitment on the obligation.
BB, B, CCC, CC, and C - Obligations rated ‘BB’, ‘B’, ‘CCC’, ‘CC’, and ‘C’ are regarded as having significant speculative
characteristics. ‘BB’ indicates the least degree of speculation and ‘C’ the highest. While such obligations will likely have somequality and protective characteristics, these may be outweighed by large uncertainties or major exposures to adverse conditions.
BB - An obligation rated ‘BB’ is less vulnerable to nonpayment than other speculative issues. However, it faces major ongoing
uncertainties or exposure to adverse business, financial, or economic conditions which could lead to the obligor’s inadequate
capacity to meet its financial commitment on the obligation.
B - An obligation rated ‘B’ is more vulnerable to nonpayment than obligations rated ‘BB’, but the obligor currently has thecapacity to meet its financial commitment on the obligation. Adverse business, financial, or economic conditions will likely
impair the obligor’s capacity or willingness to meet its financial commitment on the obligation.
CCC - An obligation rated ‘CCC’ is currently vulnerable to nonpayment, and is dependent upon favorable business, financial,and economic conditions for the obligor to meet its financial commitment on the obligation. In the event of adverse business,financial, or economic conditions, the obligor is not likely to have the capacity to meet its financial commitment on the obligation.
CC - An obligation rated ‘CC’ is currently highly vulnerable to nonpayment. The ‘CC’ rating is used when a default has not yet
occurred, but Standard & Poor’s expects default to be a virtual certainty, regardless of the anticipated time to default.
C - An obligation rated ‘C’ is currently highly vulnerable to nonpayment, and the obligation is expected to have lower relative
seniority or lower ultimate recovery compared to obligations that are rated higher.
D - An obligation rated ‘D’ is in default or in breach of an imputed promise. For non-hybrid capital instruments, the ‘D’ rating
category is used when payments on an obligation are not made on the date due, unless Standard & Poor’s believes that suchpayments will be made within five business days in the absence of a stated grace period or within the earlier of the stated grace
period or 30 calendar days. The ‘D’ rating also will be used upon the filing of a bankruptcy petition or the taking of similaraction and where default on an obligation is a virtual certainty, for example due to automatic stay provisions. An obligation’s
rating is lowered to ‘D’ if it is subject to a distressed exchange offer.
Plus (+) or Minus (-) - The ratings from ‘AA’ to ‘CCC’ may be modified by the addition of a plus (+) or minus (-) sign to show
relative standing within the major rating categories.
NR - This indicates that no rating has been requested, that there is insufficient information on which to base a rating, or that
Standard & Poor’s does not rate a particular obligation as a matter of policy.

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Moody’s Investors Service, Inc. (“Moody’s”) Long-Term Corporate Bond Ratings:
The following descriptions of Moody’s long-term corporate bond ratings have been published by Moody’s Investors Service,
Inc. and Moody’s Analytics Inc.
Aaa - Obligations rated Aaa are judged to be of the highest quality, with minimal credit risk.
Aa - Obligations rated Aa are judged to be of high quality and are subject to very low credit risk.
A - Obligations rated A are considered upper-medium grade and are subject to low credit risk.
Baa - Obligations rated Baa are subject to moderate credit risk. They are considered medium-grade and as such may possesscertain speculative characteristics.
Ba - Obligations rated Ba are judged to have speculative elements and are subject to substantial credit risk.
B - Obligations rated B are considered speculative and are subject to high credit risk.
Caa - Obligations rated Caa are judged to be of poor standing and are subject to very high credit risk.
Ca - Obligations rated Ca are highly speculative and are likely in, or very near, default, with some prospect of recovery of
principal and interest.
C - Obligations rated C are the lowest rated class of bonds and are typically in default, with little prospect for recovery of
principal or interest.
Modifiers: Moody’s appends numerical modifiers 1, 2, and 3 to each generic rating classification from Aa through Caa.
The modifier 1 indicates that the obligation ranks in the higher end of its generic rating category; the modifier 2 indicates a
mid-range ranking; and the modifier 3 indicates a ranking in the lower end of that generic rating category.
Moody’s U.S. Municipal Long-Term Bond Ratings:
The following descriptions of Moody’s long-term municipal bond ratings have been published by Moody’s Investors Service,
Inc. and Moody’s Analytics Inc.
Aaa - Issuers or issues rated Aaa demonstrate the strongest creditworthiness relative to other U.S. municipal or tax-exempt
issuers or issues.
Aa - Issuers or issues rated Aa demonstrate very strong creditworthiness relative to other U.S. municipal or tax-exempt issuers
or issues.
A - Issuers or issues rated A present above-average creditworthiness relative to other U.S. municipal or tax-exempt issuers or
issues.
Baa - Issuers or issues rated Baa represent average creditworthiness relative to other U.S. municipal or tax- exempt issuers or
issues.
Ba - Issuers or issues rated Ba demonstrate below-average creditworthiness relative to other U.S. municipal or tax-exempt
issuers or issues.
B - Issuers or issues rated B demonstrate weak creditworthiness relative to other U.S. municipal or tax- exempt issuers or
issues.
Caa - Issuers or issues rated Caa demonstrate very weak creditworthiness relative to other U.S. municipal or tax-exempt
issuers or issues.

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Ca - Issuers or issues rated Ca demonstrate extremely weak creditworthiness relative to other U.S. municipal or tax-exempt
issuers or issues.
C - Issuers or issues rated C demonstrate the weakest creditworthiness relative to other U.S. municipal or tax-exempt issuers
or issues.
Modifiers: Moody’s appends numerical modifiers 1, 2, and 3 to each generic rating category from Aa through Caa. The
modifier 1 indicates that the issuer or obligation ranks in the higher end of its generic rating category; the modifier 2 indicatesa mid-range ranking; and the modifier 3 indicates a ranking in the lower end of that generic rating category.
Fitch Ratings Ltd. (“Fitch”) Corporate Bond Ratings:
The following descriptions of Fitch’s long-term corporate bond ratings have been published by Fitch, Inc. andFitch Ratings Ltd.
AAA - Highest credit quality. ‘AAA’ ratings denote the lowest expectation of credit risk. They are assigned only in cases of
exceptionally strong capacity for payment of financial commitments. This capacity is highly unlikely to be adversely affectedby foreseeable events.
AA - Very high credit quality. ‘AA’ ratings denote expectations of very low credit risk. They indicate very strong capacity for
payment of financial commitments. This capacity is not significantly vulnerable to foreseeable events.
A - High credit quality. ‘A’ ratings denote expectations of low credit risk. The capacity for payment of financial commitments
is considered strong. This capacity may, nevertheless, be more vulnerable to adverse business or economic conditions than isthe case for higher ratings.
BBB - Good credit quality. ‘BBB’ ratings indicate that expectations of credit risk are currently low. The capacity for paymentof financial commitments is considered adequate but adverse business or economic conditions are more likely to impair thiscapacity.
BB - Speculative. ‘BB’ ratings indicate an elevated vulnerability to credit risk, particularly in the event of adverse changes
in business or economic conditions over time; however, business or financial alternatives may be available to allow financial
commitments to be met.
B - Highly speculative. ‘B’ ratings indicate that material credit risk is present. For performing obligations, default risk iscommensurate with the issuer being rated with an Issuer Default Risk (“IDR”) in the ranges ‘BB’ to ‘C’. For issuers withan IDR below ‘B’, the overall credit risk of this obligation is moderated by the expected level of recoveries should a default
occur. For issuers with an IDR above ‘B’, the overall credit risk of this obligation is exacerbated by the expected low levelof recoveries should a default occur. For non-performing obligations, the obligation or issuer is in default, or has deferredpayment, but the rated obligation is expected to have extremely high recovery rates consistent with a Recovery Rating of ‘RR1’(outstanding recovery prospects given default).
CCC - Substantial credit risk. ‘CCC’ ratings indicate that substantial credit risk is present. For performing obligations,default risk is commensurate with an IDR in the ranges ‘B’ to ‘C’. For issuers with an IDR below ‘CCC’, the overall credit
risk of this obligation is moderated by the expected level of recoveries should a default occur. For issuers with an IDR above‘CCC’, the overall credit risk of this obligation is exacerbated by the expected low level of recoveries should a default occur.
For non-performing obligations, the obligation or issuer is in default, or has deferred payment, but the rated obligation is
expected to have a superior recovery rate consistent with a Recovery Rating of ‘RR2’ (superior recovery prospects given
default).
CC - Very high levels of credit risk. ‘CC’ ratings indicate very high levels of credit risk. For performing obligations, default
risk is commensurate with an IDR in the ranges ‘B’ to ‘C’. For issuers with an IDR below ‘CC’, the overall credit risk ofthis obligation is moderated by the expected level of recoveries should a default occur. For issuers with an IDR above ‘CC’,
the overall credit risk of this obligation is exacerbated by the expected low level of recoveries should a default occur. For
non-performing obligations, the obligation or issuer is in default, or has deferred payment, but the rated obligation is expected
to have a good recovery rate consistent with a Recovery Rating of ‘RR3’ (good recovery prospects given default).

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C - Exceptionally high levels of credit risk. ‘C’ indicates exceptionally high levels of credit risk. For performing obligations,default risk is commensurate with an IDR in the ranges ‘B’ to ‘C’. The overall credit risk of this obligation is exacerbatedby the expected low level of recoveries should a default occur. For non-performing obligations, the obligation or issuer is indefault, or has deferred payment, and the rated obligation is expected to have an average, below-average or poor recovery
rate consistent with a Recovery Rating of ‘RR4’ (average recovery prospects given default), ‘RR5’ (below average recovery
prospects given default) or ‘RR6’ (poor recovery prospects given default).
Defaulted obligations typically are not assigned ‘RD’ or ‘D’ ratings, but are instead rated in the ‘B’ to ‘C’ rating categories,
depending upon their recovery prospects and other relevant characteristics. This approach better aligns obligations that havecomparable overall expected loss but varying vulnerability to default and loss.
Plus (+) or Minus (-) The modifiers “+” or “-” may be appended to a rating to denote relative status within major rating
categories. Such suffixes are not added to the ‘AAA’ obligation rating category, or to corporate finance obligation ratings in
the categories below ‘B’.
The terms “investment grade” and “speculative grade” have established themselves over time as shorthand to describe
the categories ‘AAA’ to ‘BBB’ (investment grade) and ‘BB’ to ‘D’ (speculative grade). The terms “investment grade” and“speculative grade” are market conventions, and do not imply any recommendation or endorsement of a specific security
for investment purposes. “Investment grade” categories indicate relatively low to moderate credit risk, while ratings in the“speculative” categories either signal a higher level of credit risk or that a default has already occurred.
Fitch’s Municipal Bond Long-Term Ratings:
The following descriptions of Fitch’s long-term municipal bond ratings have been published by Fitch, Inc. andFitch Ratings Ltd.
AAA - Highest credit quality. ‘AAA’ ratings denote the lowest expectation of default risk. They are assigned only in cases of
exceptionally strong capacity for payment of financial commitments. This capacity is highly unlikely to be adversely affectedby foreseeable events.
AA - Very high credit quality. ‘AA’ ratings denote expectations of very low default risk. They indicate very strong capacity for
payment of financial commitments. This capacity is not significantly vulnerable to foreseeable events.
A - High credit quality. ‘A’ ratings denote expectations of low default risk. The capacity for payment of financial commitments
is considered strong. This capacity may, nevertheless, be more vulnerable to adverse business or economic conditions than isthe case for higher ratings.
BBB - Good credit quality. ‘BBB’ ratings indicate that expectations of credit risk are currently low. The capacity for paymentof financial commitments is considered adequate but adverse business or economic conditions are more likely to impair thiscapacity.
BB - Speculative. ‘BB’ ratings indicate an elevated vulnerability to default risk, particularly in the event of adverse changes inbusiness or economic conditions over time.
B - Highly speculative. ‘B’ ratings indicate that material default risk is present, but a limited margin of safety remains.
Financial commitments are currently being met; however, capacity for continued payment is vulnerable to deterioration in thebusiness and economic environment.
CCC - Substantial credit risk. ‘CCC’ ratings indicate that default is a real possibility.
CC - Very high levels of credit risk. ‘CC’ ratings indicate default of some kind appears probable.
C - Exceptionally high levels of credit risk. ‘C’ ratings indicate default appears imminent or inevitable.

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D - Default. ‘D’ ratings indicate a default. Default generally is defined as one of the following:•

failure to make payment of principal and/or interest under the contractual terms of the rated obligation;•

the bankruptcy filings, administration, receivership, liquidation or other winding-up or cessation of the businessof an issuer/obligor; or•the distressed exchange of an obligation, where creditors were offered securities with diminished structural or
economic terms compared with the existing obligation.

Structured Finance Defaults - “Imminent” default, categorized under ‘C’, typically refers to the occasion where a payment
default has been intimated by the issuer, and is all but inevitable. This may, for example, be where an issuer has missed ascheduled payment, but (as is typical) has a grace period during which it may cure the payment default. Another alternative
would be where an issuer has formally announced a distressed debt exchange, but the date of the exchange still lies several days
or weeks in the immediate future.
Additionally, in structured finance transactions, where analysis indicates that an instrument is irrevocably impaired such that
it is not expected to pay interest and/or principal in full in accordance with the terms of the obligation’s documentation during
the life of the transaction, but where no payment default in accordance with the terms of the documentation is imminent, theobligation will typically be rated in the ‘C’ category.
Structured Finance Writedowns - Where an instrument has experienced an involuntary and, in the agency’s opinion,
irreversible “writedown” of principal (i.e. other than through amortization, and resulting in a loss to the investor), a credit
rating of ‘D’ will be assigned to the instrument. Where the agency believes the “writedown” may prove to be temporary (andthe loss may be “written up” again in future if and when performance improves), then a credit rating of ‘C’ will typicallybe assigned. Should the “writedown” then later be reversed, the credit rating will be raised to an appropriate level for that
instrument. Should the “writedown” later be deemed as irreversible, the credit rating will be lowered to ‘D’.
Notes: In the case of structured and project finance, while the ratings do not address the loss severity given default of the rated
liability, loss severity assumptions on the underlying assets are nonetheless typically included as part of the analysis. Lossseverity assumptions are used to derive pool cash flows available to service the rated liability.
Plus (+) or Minus (-) - The modifiers “+” or “-”may be appended to a rating to denote relative status within major rating
categories. Such suffixes are not added to the ‘AAA’ Long-Term Rating category, or to Long-Term Rating categories below ‘B’.
Municipal Short-Term Bond Ratings
S&P’s Municipal Short-Term Bond Ratings:
The following descriptions of S&P’s short-term municipal ratings have been published by Standard & Poor’s Financial
Service LLC.
SP-1 - Strong capacity to pay principal and interest. An issue determined to possess a very strong capacity to pay debt service
is given a plus (+) designation.
SP-2 - Satisfactory capacity to pay principal and interest, with some vulnerability to adverse financial and economic changes
over the term of the notes.
SP-3 - Speculative capacity to pay principal and interest.
Moody’s Short-Term Ratings:
The following descriptions of Moody’s short-term municipal ratings have been published by Moody’s Investors Service, Inc.
and Moody’s Analytics Inc.
MIG 1 - This designation denotes superior credit quality. Excellent protection is afforded by established cash flows, highly
reliable liquidity support, or demonstrated broad-based access to the market for refinancing.

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MIG 2 - This designation denotes strong credit quality. Margins of protection are ample, although not as large as in thepreceding group.
MIG 3 - This designation denotes acceptable credit quality. Liquidity and cash-flow protection may be narrow, and market
access for refinancing is likely to be less well-established.
SG - This designation denotes speculative-grade credit quality. Debt instruments in this category may lack sufficient margins
of protection.
Fitch’s Short-Term Credit Ratings:
The following descriptions of Fitch’s short-term credit ratings have been published by Fitch, Inc. and Fitch Ratings Ltd.
F1 - Highest short-term credit quality. Indicates the strongest intrinsic capacity for timely payment of financial commitments;
may have an added “+” to denote any exceptionally strong credit feature.
F2 - Good short-term credit quality. Good intrinsic capacity for timely payment of financial commitments.
F3 - Fair short-term credit quality. The intrinsic capacity for timely payment of financial commitments is adequate.
B - Speculative short-term credit quality. Minimal capacity for timely payment of financial commitments, plus heightened
vulnerability to near term adverse changes in financial and economic conditions.
C - High short-term default risk. Default is a real possibility.
RD - Restricted default. Indicates an entity that has defaulted on one or more of its financial commitments, although it
continues to meet other financial obligations. Applicable to entity ratings only.
D - Default. Indicates a broad-based default event for an entity, or the default of a specific short-term obligation.
Short-Term Credit Ratings
S&P’s Short-Term Credit Ratings:
The following descriptions of S&P’s short-term credit ratings have been published by Standard & Poor’s Financial
Service LLC.
A-1 - A short-term obligation rated ‘A-1’ is rated in the highest category by Standard & Poor’s. The obligor’s capacity to meetits financial commitment on the obligation is strong. Within this category, certain obligations are designated with a plus sign(+). This indicates that the obligor’s capacity to meet its financial commitment on these obligations is extremely strong.
A-2 - A short-term obligation rated ‘A-2’ is somewhat more susceptible to the adverse effects of changes in circumstancesand economic conditions than obligations in higher rating categories. However, the obligor’s capacity to meet its financial
commitment on the obligation is satisfactory.
A-3 - A short-term obligation rated ‘A-3’ exhibits adequate protection parameters. However, adverse economic conditions orchanging circumstances are more likely to lead to a weakened capacity of the obligor to meet its financial commitment on the
obligation.
B - A short-term obligation rated ‘B’ is regarded as vulnerable and has significant speculative characteristics. The obligor
currently has the capacity to meet its financial commitments; however, it faces major ongoing uncertainties which could leadto the obligor’s inadequate capacity to meet its financial commitments.
C - A short-term obligation rated ‘C’ is currently vulnerable to nonpayment and is dependent upon favorable business, financial,and economic conditions for the obligor to meet its financial commitment on the obligation.

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D - A short-term obligation rated ‘D’ is in default or in breach of an imputed promise. For non-hybrid capital instruments, the‘D’ rating category is used when payments on an obligation are not made on the date due, unless Standard & Poor’s believes
that such payments will be made within any stated grace period. However, any stated grace period longer than five businessdays will be treated as five business days. The ‘D’ rating also will be used upon the filing of a bankruptcy petition or the taking
of a similar action and where default on an obligation is a virtual certainty, for example due to automatic stay provisions. An
obligation’s rating is lowered to ‘D’ if it is subject to a distressed exchange offer.
Dual Ratings - S&P assigns “dual” ratings to all debt issues that have a put option or demand feature. The first componentof the rating addresses the likelihood of repayment of principal and interest as due, and the second component of the rating
addresses only the demand feature. The first component of the rating can relate to either a short-term or long-term transaction
and accordingly use either short-term or long-term rating symbols. The second component of the rating relates to the put
option and is assigned a short-term rating symbol (for example, ‘AAA/A-1+’ or ‘A-1+/A-1’). With U.S. municipal short-term
demand debt, the U.S. municipal short-term note rating symbols are used for the first component of the rating (for example,‘SP-1+/A-1+’).
Moody’s Short-Term Ratings:
The following descriptions of Moody’s short-term credit ratings have been published by Moody’s Investors Service, Inc. andMoody’s Analytics Inc.
P-1 - Issuers (or supporting institutions) rated Prime-1 have a superior ability to repay short-term debt obligations.
P-2 - Issuers (or supporting institutions) rated Prime-2 have a strong ability to repay short-term debt obligations.
P-3 - Issuers (or supporting institutions) rated Prime-3 have an acceptable ability to repay short-term obligations.
NP - Issuers (or supporting institutions) rated Not Prime do not fall within any of the Prime rating categories.
Note: Canadian issuers rated P-1 or P-2 have their short-term ratings enhanced by the senior-most long-term rating of theissuer, its guarantor or support-provider.
Fitch’s Short-Term Ratings:
The following descriptions of Fitch’s short-term credit ratings have been published by Fitch, Inc. and Fitch Ratings Ltd.
F1 - Highest short-term credit quality. Indicates the strongest intrinsic capacity for timely payment of financial commitments;
may have an added “+” to denote any exceptionally strong credit feature.
F2 - Good short-term credit quality. Good intrinsic capacity for timely payment of financial commitments.
F3 - Fair short-term credit quality. The intrinsic capacity for timely payment of financial commitments is adequate.
B - Speculative short-term credit quality. Minimal capacity for timely payment of financial commitments, plus heightened
vulnerability to near term adverse changes in financial and economic conditions.
C - High short-term default risk. Default is a real possibility.
RD - Restricted default. Indicates an entity that has defaulted on one or more of its financial commitments, although it
continues to meet other financial obligations. Applicable to entity ratings only.
D - Default. Indicates a broad-based default event for an entity, or the default of a specific short-term obligation.
The modifiers “+” or “-” may be appended to a rating to denote relative status within major rating categories. Such suffixes are
not added to the ‘AAA’ Long-term rating category, to categories below ‘CCC’, or to Short-term ratings other than ‘F1’. (The+/- modifiers are only used to denote issues within the CCC category, whereas issuers are only rated CCC without the use ofmodifiers.)

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