Cavalier Investments, LLC (“Adaptive Investments” or the “Adviser”) is a Massachusetts Limited Liability Company formed in 2015. The principal owner of the Adviser is Greg Rutherford. As of December 31, 2023, Adaptive Investments had total regulatory assets under management of $290,127,850 of which, $286,821,071 are discretionary. Fund Management Services Adaptive Investments provides discretionary investment advisory services through Exchange-Traded mutual funds (“ETF’s" or “Funds”) focused on capital appreciation, income, downside protection and real return. For certain Funds, sub-advisors assist Adaptive Investments in rendering investment management services pursuant to an investment sub-advisory agreement with Adaptive Investments. The sub- advisors employ their discretionary investment management services according to the investment objective, policies and restrictions established in the prospectus and statement of additional information of the respective Fund sub-advised. For the name of the sub-advisor for each sub-advised Fund, please see the respective prospectus. On at least a quarterly basis, Adaptive Investments performs a review of each sub-advisor and their performance as it relates to the Fund sub-advised and ensures that the Fund is being managed according to the Fund’s investment guidelines. Portfolio Management Services Adaptive Investments provides portfolio management services to financial intermediaries by providing asset-allocated model portfolios. Each model portfolio is designed to meet a particular investment goal. Asset class investments are used to construct the portfolios using institutional mutual funds and ETF’s. In selecting these assets, Adaptive Investments gives due consideration to past performance, transaction fees, expense ratios, intrinsic costs, consistency, and management style. Adaptive Investments creates and maintains

model portfolios that range from conservative to aggressive and are designed to meet the varying needs of the investor. The investment advisor representative, together with his/her client, selects the Adaptive Investments model portfolio to invest in based on the client’s specific investment objective, risk tolerance and time horizon. Investments are considered to be long-term in nature, and investors should expect to remain fully invested in their selected asset-allocated model portfolio(s) at all times. Adaptive Investments performs periodic rebalancing designed to keep portfolios consistent with desired asset allocation. Adaptive Investments offers model portfolio allocations to various advisory platforms. Adaptive Investments acts as a model portfolio advisor that offers its model strategies to independent investment advisors or third-party platforms or other platforms who employ the models in the management of their clients’ investments. Adaptive Investments develops and manages its investment strategies and provides current asset allocations and changes to the independent investment advisor or third-party platforms as the model changes. The investment advisor or third party-party platform is then responsible implementing the Adaptive model recommendations. Adaptive Investments’ discretionary authority is limited as described in Item 16. ERISA Section 3(38) Adaptive Investments also offer ERISA section 3(38) services and will work with business Clients to develop, design and implement a retirement savings plan investment lineup for its employees. As part its role, Adaptive Investments will be responsible for selecting, managing, monitoring and benchmarking the investment offerings of the retirement plan. In some plans, but not in participant directed plans, a retirement plan may also have discretionary authority to direct the investment of funds in accordance with the ERISA section 3(38).