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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

 

FORM N-CSR

 

CERTIFIED SHAREHOLDER REPORT OF REGISTERED

MANAGEMENT INVESTMENT COMPANIES

 

Investment Company Act file number: 811-23439
Exact name of registrant as specified in charter: ETF Opportunities Trust
Address of principal executive offices:

8730 Stony Point Parkway

Suite 205

Richmond, VA 23235

Name and address of agent for service

The Corporation Trust Co.

Corporation Trust Center

1209 Orange St.,

Wilmington, DE 19801

 

With Copy to:

 

Practus, LLP

11300 Tomahawk Creek Parkway

Suite 310

Leawood, KS 66211 

Registrant's telephone number, including area code: (804) 267-7400
Date of fiscal year end: July 31
Date of reporting period: July 31, 2025
   
  American Conservative Values ETF
   

 

 

 

 

 

ITEM 1.(a).  Reports to Stockholders.

 

 

American Conservative Values ETF Tailored Shareholder Report

American Conservative Values ETF Tailored Shareholder Report

annual Shareholder Report July 31, 2025

American Conservative Values ETF

Ticker: ACVF (Listed on the NYSE Arca, Inc.)

This annual shareholder report contains important information about the American Conservative Values ETF for the period of August 1, 2024 to July 31, 2025. You can find additional information about the Fund at acvetfs.com/acv-fund-material/. You can also request this information by contacting us at (888) 909-6030.

What were the Fund costs for the past year?

(based on a hypothetical $10,000 investment)

Fund Name
Costs of a $10,000 investment
Costs paid as a percentage of a $10,000 investment
American Conservative Values ETF
$81
0.75%

 

How did the Fund perform?

The American Conservative Values ETF (the "Fund") returned 14.82% for the period of August 1, 2024 to July 31, 2025 vs 16.33% for the S&P 500® Index and 16.54% for the Russell 1000® Total Return Index. The Fund invests substantially all of its assets in a portfolio of large-cap US equities and performance was affected by the boycotting of securities which in aggregate represent an active share (30%) of the S&P 500® benchmark. During the reporting period, the S&P 500®’s positive return masked a period of significant market volatility. Due to uncertainty around Trump’s tariffs, budget impact and Fed policy, the S&P 500® Index reached its maximum drawdown of -18.8% on April 8th, before rallying 27.7%, reaching an all-time high on July 27th. The equity market continues to be significantly influenced by the performance of the Magnificent Seven.

What affected the Fund’s performance?

The performance of our boycotts compared to what companies we overweight or replaced them with in the portfolio will always be the most significant driver of our relative returns to benchmarks. To minimize the resulting active risk, we remained broadly diversified and attempted to control multiple risk factors such as size, sector, and style. In aggregate, ACVF’s 39 boycotts, which represented approximately 30% of the S&P 500®, detracted 4.21% from performance, while what we did own contributed 3.62% to the one-year return.

Cumulative Performance

(based on a hypothetical $10,000 investment)

Date
American Conservative Values ETF - $19,776
S&P 500® Index - $20,080
10/28/2020*
10000
10000
7/31/2021
13102
13112
7/31/2022
12554
12504
7/31/2023
14243
14131
7/31/2024
17224
17261
7/31/2025
19776
20080
line
* Inception

Annual Performance

One Year
Average Annual
Total Return
Since Inception
American Conservative Values ETF
14.82%
15.42%
S&P 500® Index
16.33%
15.78%

 

The S&P 500® Index is a broad-based unmanaged index of 500 stocks, which is widely recognized as representative of the equity market in general.

Visit acvetfs.com/fund/acv-etf-fund-data/ for more recent performance information.

The Fund's past performance is not a good predictor of how the Fund will perform in the future. The graph and table do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or redemption of Fund shares.

American Conservative Values ETF Tailored Shareholder Report

American Conservative Values ETF Tailored Shareholder Report

American Conservative Values ETF Tailored Shareholder Report

Sector Breakdown

Sector
%
COMMUNICATION SERVICES
0.0472
CONSUMER DISCRETIONARY
0.0971
CONSMER STAPLES
0.0655
ENERGY
0.0315
FINANCIALS
0.1304
HEALTH CARE
0.0906
INDUSTRIALS
0.1169
INFORMATION TECHNOLOGY - HARDWARE
0.1837
INFORMATION TECHNOLOGY -SOFTWARE & SERVICES
0.1754
MATERIALS
0.0226
REAL ESTATE
0.0163
UTILITIES
0.021
bar
Top Ten Holdings
Nvidia Corp.
8.33%
Microsoft Corp.
6.71%
Broadcom, Inc.
2.81%
Berkshire Hathaway Class B
1.80%
Mastercard, Inc. Class A
1.78%
Walmart, Inc.
1.77%
Cisco Systems, Inc.
1.76%
Home Depot, Inc.
1.53%
Oracle Corp.
1.53%
The Procter & Gamble Co
1.33%

Key Fund Statistics

(as of July 31, 2025)

 

 

Fund Net Assets
$131,159,676
Number of Holdings
372
Total Advisory Fee
$865,874
Portfolio Turnover Rate
6.37%

 

 

For additional information about the Fund, including its summary prospectus, prospectus, financial information, holdings and proxy information, visit acvetfs.com/acv-fund-material/.

What did the Fund invest in?

(% of Net Assets as of July 31, 2025)

American Conservative Values ETF Tailored Shareholder Report

 

 

 

 

ITEM 1.(b). Not applicable.

 

ITEM 2. CODE OF ETHICS.

 

(a) The registrant, as of the end of the period covered by this report, has adopted a code of ethics that applies to the registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party.

 

(c) There have been no amendments, during the period covered by this report, to a provision of the code of ethics that applies to the registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party, and that relates to any element of the code of ethics description.

 

(d) The registrant has not granted any waivers, including an implicit waiver, from a provision of the code of ethics that applies to the registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party, that relates to one or more of the items set forth in paragraph (b) of this item’s instructions.

 

(e) Not applicable.

 

(f) The code of ethics is attached hereto as exhibit 19(a)(1).

 

ITEM 3. AUDIT COMMITTEE FINANCIAL EXPERT.

 

(a)(1) The registrant does not have an audit committee financial expert serving on its audit committee.

 

(a)(2) Not applicable.

 

(a)(3) At this time, the registrant believes that the collective experience provided by the members of the audit committee together offer the registrant adequate oversight for the registrant’s level of financial complexity.

 

ITEM 4. PRINCIPAL ACCOUNTANT FEES AND SERVICES.

 

(a) Audit Fees. The aggregate fees billed for each of the last two fiscal years for professional services rendered by the principal accountant for the audit of the registrant’s annual financial statements or services that are normally provided by the accountant in connection with statutory and regulatory filings or engagements for those fiscal years are $15,400 for 2025 and $15,400 for 2024.

 

(b) Audit-Related Fees. The aggregate fees billed in each of the last two fiscal years for assurance and related services by the principal accountant that are reasonably related to the performance of the audit of the registrant’s financial statements and are not reported under paragraph (a) of this Item are $0 for 2025 and $0 for 2024.

 

(c) Tax Fees. The aggregate fees billed in each of the last two fiscal years for professional services rendered by the principal accountant for tax compliance, tax advice, and tax planning are $3,300 for 2025 and $3,300 for 2024. The nature of the services comprising these fees include preparation of excise filings and income tax returns and assistance with calculation of required income, capital gain and excise distributions.

 

(d) All Other Fees. The aggregate fees billed in each of the last two fiscal years for products and services provided by the principal accountant, other than the services reported in paragraphs (a) through (c) of this Item are and $0 for 2025 and $0 for 2024.

 

 

 

 

(e)(1) Disclose the audit committee’s pre-approval policies and procedures described in paragraph (c)(7) of Rule 2-01 of Regulation S-X.

 

Pursuant to its charter, the registrant’s Audit Committee must pre-approve all audit and non-audit services to be provided to the registrant.  The Audit Committee also pre-approves any non-audit services provided by the registrant’s principal accountant to the adviser or any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the registrant, if the engagement relates directly to the operations and financial reporting of the registrant.

 

(e)(2) The percentage of services described in each of paragraphs (b) through (d) of this Item that were approved by the audit committee pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X are as follows:

 

(b) NA

 

(c) 0%

 

(d) NA

 

(f) The percentage of hours expended on the principal accountant’s engagement to audit the registrant’s financial statements for the most recent fiscal year that were attributed to work performed by persons other than the principal accountant’s full-time, permanent employees was zero percent (0%).

 

(g) The aggregate non-audit fees billed by the registrant’s accountant for services rendered to the registrant, and rendered to the registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the registrant for each of the last two fiscal years of the registrant was $0 for 2025 and $0 for 2024.

 

(h) Not applicable.

 

(i) Not applicable.

 

(j) Not applicable.

 

ITEM 5. AUDIT COMMITTEE OF LISTED REGISTRANTS.

 

(a) The registrant has an audit committee which was established by the Board of Trustees of the registrant in accordance with Section 3(a)(58)(A) of the Securities Exchange Act of 1934, as amended. Each of the registrant’s Trustees serves as a member of its Audit Committee.

 

(b) Not applicable.

 

ITEM 6. INVESTMENTS.

 

(a) The Registrant’s Schedule of Investments is included as part of the Financial Statements and Financial Highlights filed under Item 7 of this Form.

 

(b) Not applicable.

 

 

 

 

ITEM 7. FINANCIAL STATEMENTS AND FINANCIAL HIGHLIGHTS FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES.

FINANCIAL STATEMENTS
AND OTHER INFORMATION

Year Ended July 31, 2025

American Conservative Values ETF

1

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Schedule of InvestmentsJuly 31, 2025

See Notes to Financial Statements

 

 

Shares

 

Value

99.82%

COMMON STOCKS

 

 

 

 

 

 

 

 

 

 

 

 

4.72%

COMMUNICATION SERVICES

 

 

 

 

 

 

AT&T, Inc.

 

34,091

 

$934,434

 

 

Charter Communications, Inc.(A)

 

2,165

 

583,164

 

 

Electronic Arts, Inc.

 

2,154

 

328,463

 

 

Fox Corp. Class A

 

3,745

 

208,821

 

 

Fox Corp. Class B

 

3,533

 

180,678

 

 

The Interpublic Grou

 

7,915

 

194,709

 

 

Live Nation Entertainment(A)

 

993

 

146,666

 

 

News Corp. Class A

 

5,400

 

158,328

 

 

News Corp. Class B

 

4,937

 

164,995

 

 

Newsmax, Inc.(A)

 

17,055

 

226,661

 

 

Omnicom Group, Inc.

 

3,664

 

263,991

 

 

Pinterest, Inc.(A)

 

4,056

 

156,562

 

 

Spotify Technology SA ADR(A)

 

1,311

 

821,394

 

 

Take-Two Interactive(A)

 

1,484

 

330,531

 

 

T-Mobile US, Inc.

 

5,490

 

1,308,871

 

 

Trump Media & Technology Group Corp.(A)

10,196

 

179,348

 

 

 

 

 

 

6,187,616

 

 

 

 

 

 

 

 

9.71%

CONSUMER DISCRETIONARY

 

 

 

 

 

 

Advance Auto Parts

 

222

 

11,782

 

 

Airbnb, Inc.(A)

 

3,557

 

470,982

 

 

Aptiv plc ADR(A)

 

883

 

60,609

 

 

Autozone, Inc.(A)

 

111

 

418,290

 

 

Bath & Body Works, Inc.

 

977

 

28,294

 

 

Best Buy Co., Inc.

 

773

 

50,291

 

 

Booking Holdings, Inc.

 

237

 

1,304,462

 

 

Borg-Warner, Inc.

 

989

 

36,395

 

 

Darden Restaurants, Inc.

 

445

 

89,743

 

 

Domino’s Pizza, Inc.

 

111

 

51,416

 

 

DoorDash, Inc.(A)

 

2,302

 

576,076

 

 

DR Horton, Inc.

 

884

 

126,271

 

 

eBay, Inc.

 

1,856

 

170,288

 

 

Etsy, Inc.(A)

 

1,327

 

77,324

 

 

Expedia Group, Inc.

 

2,330

 

419,913

 

 

Ford Motor Co.

 

13,741

 

152,113

 

 

Garmin Ltd. ADR

 

2,757

 

603,121

 

 

Genuine Parts Co.

 

555

 

71,528

 

 

Hasbro, Inc.

 

224

 

16,836

 

2

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Schedule of Investments - continuedJuly 31, 2025

See Notes to Financial Statements

 

 

Shares

 

Value

 

Hilton Worldwide Holdings, Inc.

 

883

 

$236,715

 

 

Home Depot, Inc.

 

5,463

 

2,007,707

 

 

Kohl’s Corp.

 

4,095

 

44,390

 

 

Las Vegas Sands Corp.

 

1,325

 

69,430

 

 

Lennar Corp.

 

660

 

74,039

 

 

Lithia Motors, Inc.

 

455

 

131,040

 

 

LKQ Corp.

 

660

 

19,450

 

 

Marriott International Class A

 

2,127

 

561,166

 

 

McDonald’s Corp.

 

4,272

 

1,281,899

 

 

MGM Resorts International(A)

 

2,760

 

100,602

 

 

O’Reilly Automotive, Inc.(A)

 

7,243

 

712,132

 

 

Phinia, Inc.

 

207

 

10,495

 

 

Polo Ralph Lauren Corp.

 

110

 

32,862

 

 

Pool Corp.

 

111

 

34,204

 

 

Pulte Group, Inc.

 

334

 

37,715

 

 

PVH Corp.

 

221

 

16,226

 

 

Ross Stores, Inc.

 

2,752

 

375,758

 

 

Royal Caribbean Cruises ADR

 

553

 

175,782

 

 

Skechers U.S.A., Inc.(A)

 

2,406

 

152,180

 

 

Smith & Wesson Brands, Inc.

 

11,512

 

91,520

 

 

Sturm Ruger & Co., Inc.

 

3,461

 

118,228

 

 

Tapestry, Inc.

 

664

 

71,732

 

 

TJX Companies, Inc.

 

9,174

 

1,142,438

 

 

Tractor Supply Co.

 

4,313

 

245,625

 

 

Ulta Beauty, Inc.(A)

 

111

 

57,166

 

 

Under Armour, Inc. Class A(A)

 

7,937

 

52,702

 

 

Under Armour, Inc. Class C(A)

 

9,022

 

56,839

 

 

Wynn Resorts Ltd.

 

329

 

35,871

 

 

Yum! Brands, Inc.

 

342

 

49,299

 

 

 

 

 

 

12,730,946

 

6.55%

CONSUMER STAPLES

 

 

 

 

 

 

Altria Group, Inc.

 

5,251

 

325,247

 

 

Archer-Daniels-Midland Co.

 

1,727

 

93,569

 

 

Brown-Forman Corp. Class B

 

671

 

19,358

 

 

Church & Dwight Co.

 

553

 

51,855

 

 

The Clorox Co

 

104

 

13,058

 

 

Colgate-Palmolive Co.

 

2,916

 

244,507

 

 

Constellation Brands, Inc.

 

879

 

146,828

 

 

Dollar General Corp.

 

1,008

 

105,739

 

 

Dollar Tree, Inc.(A)

 

548

 

62,225

 

 

Estee Lauder Cos. Class A

 

553

 

51,617

 

 

General Mills, Inc.

 

1,326

 

64,948

 

3

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Schedule of Investments - continuedJuly 31, 2025

See Notes to Financial Statements

 

 

Shares

 

Value

 

The Hershey Compan

 

334

 

$62,167

 

 

Kimberly-Clark Corp.

 

772

 

96,207

 

 

The Kraft Heinz Co

 

2,097

 

57,584

 

 

Kroger Co.

 

772

 

54,117

 

 

McCormick & Co., Inc.(B)

 

442

 

31,218

 

 

Mondelez International Inc. Class A

 

12,458

 

805,908

 

 

Monster Beverage Corp.(A)

 

4,188

 

246,045

 

 

PepsiCo, Inc.

 

6,907

 

952,613

 

 

Philip Morris International, Inc.

 

5,878

 

964,286

 

 

The Procter & Gamble Co

 

11,592

 

1,744,248

 

 

Sysco Corp.

 

531

 

42,268

 

 

Walgreens Boots Alliance, Inc.

 

2,868

 

33,384

 

 

Walmart, Inc.

 

23,690

 

2,321,146

 

 

 

 

 

 

8,590,142

 

 

 

 

 

 

 

 

3.15%

ENERGY

 

 

 

 

 

 

Baker Hughes Co.

 

2,313

 

104,201

 

 

Chevron Corp.

 

6,144

 

931,676

 

 

ConocoPhillips

 

2,428

 

231,486

 

 

EOG Resources, Inc.

 

1,213

 

145,584

 

 

Exxon Mobil Corp.

 

15,238

 

1,701,170

 

 

Halliburton Co.

 

2,201

 

49,302

 

 

Kinder Morgan, Inc.

 

5,070

 

142,264

 

 

Marathon Petroleum Corp.

 

2,237

 

380,715

 

 

Occidental Petroleum Corp.

 

2,209

 

97,064

 

 

Oneok, Inc.

 

989

 

81,207

 

 

Schlumberger Ltd. ADR

 

4,185

 

141,453

 

 

Williams Cos., Inc.

 

2,092

 

125,415

 

 

 

 

 

 

4,131,537

 

 

 

 

 

 

 

 

13.04%

FINANCIALS

 

 

 

 

 

 

Aflac, Inc.

 

662

 

65,776

 

 

American International Group

 

777

 

60,319

 

 

Ameriprise Financial, Inc.

 

446

 

231,113

 

 

Aon plc ADR

 

553

 

196,708

 

 

Arthur J Gallagher & Co.

 

223

 

64,057

 

 

Bank Of New York Mellon

 

1,078

 

109,363

 

 

Berkshire Hathaway Class B(A)

 

4,990

 

2,354,681

 

 

Blackstone, Inc.

 

2,906

 

502,622

 

 

Capital One Financial

 

3,642

 

783,030

 

 

CBOE Global Markets, Inc.

 

1,191

 

287,079

 

 

The Charles Schwab Corp

 

3,041

 

297,197

 

4

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Schedule of Investments - continuedJuly 31, 2025

See Notes to Financial Statements

 

 

Shares

 

Value

 

Chubb Ltd. ADR

 

1,674

 

$445,351

 

 

Cincinnati Financial Corp.

 

445

 

65,642

 

 

Citigroup, Inc.

 

8,246

 

772,650

 

 

Citizens Financial Group

 

1,872

 

89,332

 

 

CME Group, Inc.

 

2,479

 

689,856

 

 

Coinbase Global, Inc.(A)

 

486

 

183,591

 

 

Fidelity National Information
Services, Inc.

1,871

 

148,576

 

 

Fifth Third Bancorp

 

3,087

 

128,327

 

 

Fiserv, Inc.(A)

 

4,699

 

652,879

 

 

Franklin Resources, Inc.

 

658

 

15,792

 

 

Global Payments, Inc.

 

1,973

 

157,741

 

 

Hartford Financial Services Group, Inc.

774

 

96,278

 

 

Huntington Bancshares

 

3,419

 

56,174

 

 

Intercontinental Exchange

 

3,107

 

574,267

 

 

Invesco Ltd. ADR

 

336

 

7,059

 

 

Keycorp

 

2,316

 

41,503

 

 

KKR & Co., Inc.

 

1,842

 

270,000

 

 

Loews Corp.

 

543

 

49,163

 

 

MarketAxess Holdings, Inc.

 

111

 

22,810

 

 

Marsh & McLennan Cos, Inc.

 

1,449

 

288,641

 

 

Mastercard, Inc. Class A

 

4,124

 

2,336,122

 

 

MetLife, Inc.

 

3,908

 

296,813

 

 

Moody’s Corporation

 

1,111

 

572,976

 

 

Morgan Stanley

 

3,122

 

444,760

 

 

MSCI, Inc.

 

113

 

63,434

 

 

Northern Trust Corp.

 

881

 

114,530

 

 

The PNC Financial Services Group, Inc

 

2,019

 

384,155

 

 

Principal Financial Group, Inc.

 

443

 

34,479

 

 

Prudential Financial, Inc.

 

446

 

46,197

 

 

Raymond James Financial

 

663

 

110,807

 

 

Regions Financial Corp.

 

3,966

 

100,459

 

 

Rocket Cos, Inc.

 

8,135

 

120,154

 

 

S&P 500 Global, Inc.

 

1,546

 

852,001

 

 

State Street Corp.

 

1,323

 

147,845

 

 

Synchrony Financial

 

223

 

15,536

 

 

T Rowe Price Group, Inc.

 

774

 

78,522

 

 

The Travelers Companies, Inc

 

229

 

59,595

 

 

Truist Financial Corp.

 

5,288

 

231,138

 

 

US Bancorp

 

6,453

 

290,127

 

 

Wells Fargo & Co.

 

12,249

 

987,637

 

 

Willis Towers Watson plc ADR

 

334

 

105,480

 

 

 

 

 

 

17,100,344

 

5

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Schedule of Investments - continuedJuly 31, 2025

See Notes to Financial Statements

 

 

Shares

 

Value

9.06%

HEALTH CARE

 

 

 

 

 

 

Abbott Laboratories

 

5,564

 

$702,121

 

 

Abbvie, Inc.

 

5,698

 

1,077,036

 

 

Agilent Technologies, Inc.

 

553

 

63,490

 

 

Amgen, Inc.

 

1,562

 

460,946

 

 

Becton Dickinson & Co.

 

774

 

137,966

 

 

Biogen, Inc.(A)

 

131

 

16,768

 

 

Boston Scientific Corp.(A)

 

4,131

 

433,425

 

 

Bristol-Myers Squibb Co.

 

7,591

 

328,766

 

 

Cardinal Health, Inc.

 

657

 

101,980

 

 

Cencora, Inc.

 

663

 

189,671

 

 

Centene Corp.(A)

 

1,210

 

31,545

 

 

The Cigna Grou

 

2,211

 

591,177

 

 

Cooper Cos., Inc.(A)

 

444

 

31,386

 

 

CVS Health Corp.

 

3,861

 

239,768

 

 

Danaher Corp.

 

2,560

 

504,730

 

 

Dexcom, Inc.(A)

 

888

 

71,724

 

 

Edwards Lifescience Corp.(A)

 

1,547

 

122,693

 

 

Elevance Health, Inc.

 

1,039

 

294,120

 

 

Eli Lilly & Co.

 

2,316

 

1,714,002

 

 

Embecta Corp.

 

127

 

1,290

 

 

Fortrea Holdings, Inc.(A)

 

222

 

1,274

 

 

GE Healthcare Technologies

 

1,006

 

71,748

 

 

Gilead Sciences, Inc.

 

1,224

 

137,443

 

 

Grail, Inc.(A)

 

79

 

2,702

 

 

HCA Healthcare, Inc.

 

328

 

116,109

 

 

Hologic, Inc.(A)

 

331

 

22,117

 

 

Humana, Inc.

 

769

 

192,150

 

 

Idexx Laboratories, Inc.(A)

 

113

 

60,377

 

 

Illumina, Inc.(A)

 

442

 

45,398

 

 

Incyte Corp.(A)

 

336

 

25,163

 

 

Intuitive Surgical, Inc.(A)

 

1,468

 

706,240

 

 

Iqvia Holdings, Inc.(A)

 

441

 

81,964

 

 

Labcorp Holdings, Inc.

 

222

 

57,738

 

 

McKesson Corp.

 

560

 

388,382

 

 

Medtronic plc ADR

 

4,109

 

370,796

 

 

Merck & Company, Inc.

 

8,372

 

654,021

 

 

Mettler-Toledo International, Inc.(A)

 

1

 

1,234

 

 

Regeneron Pharmaceuticals, Inc.

 

336

 

183,274

 

 

ResMed, Inc.

 

223

 

60,643

 

 

Solventum Corp.(A)

 

217

 

15,485

 

 

Stryker Corp.

 

1,005

 

394,694

 

6

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Schedule of Investments - continuedJuly 31, 2025

See Notes to Financial Statements

 

 

Shares

 

Value

 

Thermo Fisher Scientific, Inc.

 

1,220

 

$570,569

 

 

Veeva Systems, Inc. Class A(A)

 

214

 

60,819

 

 

Vertex Pharmaceuticals(A)

 

789

 

360,470

 

 

Zimmer Biomet Holdings

 

341

 

31,253

 

 

Zoetis, Inc.

 

1,095

 

159,640

 

 

 

 

 

 

11,886,307

 

 

 

 

 

 

 

 

11.69%

INDUSTRIALS

 

 

 

 

 

 

3M Co.

 

871

 

129,971

 

 

Amentum Holdings, Inc.(A)

 

348

 

8,689

 

 

American Airlines Group(A)

 

5,730

 

65,837

 

 

Ametek, Inc.

 

439

 

81,149

 

 

Automatic Data Processing, Inc.

 

1,566

 

484,677

 

 

The Boeing Co(A)

 

1,546

 

342,965

 

 

Broadridge Financial Solutions, Inc.

 

333

 

82,421

 

 

Builders FirstSource, Inc.(A)

 

1,004

 

127,639

 

 

Canadian Pacific Kansas City
Southern ADR

2,214

 

162,840

 

 

Carrier Global Corp.

 

1,213

 

83,236

 

 

Caterpillar, Inc.

 

1,673

 

732,807

 

 

CH Robinson Worldwide, Inc.

 

336

 

38,748

 

 

Cintas Corp.

 

2,237

 

497,844

 

 

Copart, Inc.(A)

 

15,799

 

716,169

 

 

CSX Corp.

 

6,608

 

234,848

 

 

Cummins, Inc.

 

553

 

203,294

 

 

Deere & Co.

 

1,266

 

663,852

 

 

Eaton Corp. plc

 

2,104

 

809,451

 

 

Emerson Electric Co.

 

2,008

 

292,184

 

 

Equifax, Inc.

 

332

 

79,756

 

 

Expeditors International of
Washington, Inc.

444

 

51,611

 

 

Fastenal Co.

 

3,312

 

152,783

 

 

FedEx Corp.

 

663

 

148,174

 

 

Fortive Corporation

 

776

 

37,194

 

 

GE Vernova LLC

 

782

 

516,347

 

 

General Dynamics Corp.

 

325

 

101,273

 

 

General Electric Co.

 

3,129

 

848,209

 

 

Grainger WW, Inc.

 

112

 

116,428

 

 

Honeywell International

 

2,557

 

568,549

 

 

Illinois Tool Works, Inc.

 

663

 

169,708

 

 

Ingersoll Rand, Inc.

 

884

 

74,813

 

 

Jacobs Solutions, Inc.

 

329

 

46,675

 

7

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Schedule of Investments - continuedJuly 31, 2025

See Notes to Financial Statements

 

 

Shares

 

Value

 

JB Hunt Transport Services, Inc.

 

111

 

$15,990

 

 

Johnson Controls International ADR

 

2,908

 

305,340

 

 

L3Harris Technologies, Inc.

 

664

 

182,480

 

 

Lockheed Martin Corp.

 

778

 

327,522

 

 

Norfolk Southern Corp.

 

235

 

65,330

 

 

Northrop Grumman Corp.

 

443

 

255,438

 

 

Old Dominion Freight

 

446

 

66,566

 

 

Otis Worldwide Corp.

 

658

 

56,384

 

 

PACCAR, Inc.

 

1,521

 

150,214

 

 

Parker-Hannifin Corp.

 

333

 

243,723

 

 

Paychex, Inc.

 

1,104

 

159,340

 

 

Paycom Software, Inc.

 

111

 

25,701

 

 

Quanta Services, Inc.

 

111

 

45,080

 

 

RB Global, Inc. ADR

 

2,280

 

246,833

 

 

Republic Services, Inc.

 

2,228

 

513,888

 

 

Rockwell Automation, Inc.

 

111

 

39,040

 

 

RTX Corp.

 

4,467

 

703,865

 

 

Southwest Airlines Co.

 

2,206

 

68,232

 

 

Trane Technologies plc ADR

 

550

 

240,944

 

 

Transdigm Group, Inc.

 

111

 

178,539

 

 

Uber Technologies, Inc.(A)

 

9,022

 

791,680

 

 

Union Pacific Corp.

 

2,003

 

444,606

 

 

United Airlines Holdings(A)

 

2,196

 

193,929

 

 

UPS, Inc. Class B

 

1,974

 

170,080

 

 

Veralto Corp.

 

854

 

89,525

 

 

Verisk Analytics, Inc.

 

1,414

 

394,096

 

 

Wabtec Corp.

 

439

 

84,310

 

 

Waste Management, Inc.

 

2,485

 

569,463

 

 

Xylem, Inc.

 

223

 

32,250

 

 

 

 

 

 

15,330,529

 

 

 

 

 

 

 

 

18.37%

INFORMATION TECHNOLOGY - HARDWARE

 

 

 

 

 

Advanced Micro Devices(A)

 

5,020

 

885,076

 

 

Amphenol Corp. Class A

 

3,566

 

379,815

 

 

Analog Devices, Inc.

 

2,645

 

594,146

 

 

Broadcom, Inc.

 

12,553

 

3,686,816

 

 

Cisco Systems, Inc.

 

33,972

 

2,312,814

 

 

Corning, Inc.

 

2,098

 

132,678

 

 

HP, Inc.

 

5,164

 

128,067

 

 

Intel Corp.

 

16,249

 

321,730

 

 

Jabil, Inc.

 

1,573

 

351,046

 

 

Keysight Technologies, Inc.(A)

 

442

 

72,448

 

8

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Schedule of Investments - continuedJuly 31, 2025

See Notes to Financial Statements

 

 

Shares

 

Value

 

Lam Research Corp.

 

6,658

 

$631,445

 

 

Microchip Technology, Inc.

 

1,104

 

74,619

 

 

Micron Technology, Inc.

 

4,004

 

436,997

 

 

Motorola Solutions, Inc.

 

2,108

 

925,370

 

 

Nvidia Corp.

 

61,433

 

10,927,088

 

 

NXP Semiconductors NV ADR

 

971

 

207,571

 

 

Qualcomm, Inc.

 

4,112

 

603,477

 

 

Ralliant Corp.(A)

 

258

 

11,796

 

 

Roper Technologies, Inc.

 

1,014

 

558,106

 

 

TE Connectivity plc ADR

 

1,106

 

227,560

 

 

Texas Instruments, Inc.

 

3,444

 

623,571

 

 

 

 

 

 

24,092,236

 

17.54%

INFORMATION TECHNOLOGY - SOFTWARE & SERVICES

 

 

 

 

 

Accenture plc Class A ADR

 

3,007

 

803,170

 

 

Adobe, Inc.(A)

 

2,330

 

833,418

 

 

Applied Materials, Inc.

 

3,586

 

645,695

 

 

Arista Networks, Inc.(A)

 

8,925

 

1,099,738

 

 

Autodesk, Inc.(A)

 

1,224

 

371,007

 

 

Cadence Design Systems(A)

 

1,896

 

691,225

 

 

CDW Corp.

 

334

 

58,243

 

 

Cognizant Tech Solutions

 

3,914

 

280,869

 

 

CrowdStrike Holdings, Inc.(A)

 

580

 

263,651

 

 

F5, Inc.(A)

 

1,100

 

344,762

 

 

Fair Isaac Corp.(A)

 

207

 

297,401

 

 

Fortinet, Inc.(A)

 

2,195

 

219,280

 

 

Gartner Group, Inc.(A)

 

440

 

149,006

 

 

Hewlett-Packard Enterprise

 

13,270

 

274,556

 

 

Intuit, Inc.

 

1,644

 

1,290,754

 

 

KLA Corp.

 

590

 

518,628

 

 

Manhattan Associates, Inc.(A)

 

678

 

148,929

 

 

Microsoft Corp.

 

16,504

 

8,804,884

 

 

Oracle Corp.

 

7,890

 

2,002,245

 

 

Palo Alto Networks, Inc.(A)

 

3,049

 

529,306

 

 

Seagate Technology Holdings plc ADR

 

545

 

85,570

 

 

ServiceNow, Inc.(A)

 

1,143

 

1,077,986

 

 

Synopsys, Inc.(A)

 

1,344

 

851,384

 

 

Tyler Technologies, Inc.(A)

 

106

 

61,963

 

 

Verisign, Inc.

 

3,216

 

864,686

 

 

Workday, Inc. Class A(A)

 

968

 

222,040

 

 

Zebra Technologies Corp.(A)

 

657

 

222,736

 

 

 

 

 

 

23,013,132

 

 

 

 

 

 

 

 

9

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Schedule of Investments - continuedJuly 31, 2025

See Notes to Financial Statements

 

 

Shares

 

Value

2.26%

MATERIALS

 

 

 

 

 

 

Air Products and Chemicals, Inc.

 

666

 

$191,728

 

 

Albemarle Corp.

 

111

 

7,531

 

 

Amcor plc ADR

 

4,962

 

46,395

 

 

Ball Corporation

 

1,104

 

63,215

 

 

Celanese Corp. Class A

 

112

 

5,850

 

 

Corteva, Inc.

 

2,208

 

159,263

 

 

Dow, Inc.

 

879

 

20,472

 

 

Dupont de Nemours, Inc.

 

754

 

54,213

 

 

Ecolab, Inc.

 

776

 

203,126

 

 

FMC Corp.

 

112

 

4,372

 

 

Freeport-McMoran, Inc.

 

5,293

 

212,990

 

 

International Flavors & Fragrance, Inc.

221

 

15,698

 

 

International Paper Co.

 

1,545

 

72,213

 

 

Linde plc ADR

 

2,350

 

1,081,611

 

 

LyondellBasell Industries NV ADR

 

659

 

38,176

 

 

The Mosaic Co

 

881

 

31,725

 

 

Newmont Goldcorp Corp.

 

2,094

 

130,037

 

 

Nucor Corp.

 

768

 

109,878

 

 

Olin Corp.

 

6,652

 

125,989

 

 

Packaging Corp. of America

 

223

 

43,206

 

 

PPG Industries, Inc.

 

663

 

69,946

 

 

The Sherwin-Williams Co

 

664

 

219,704

 

 

Smurfit Kappa Group plc ADR

 

553

 

24,542

 

 

Sylvamo Corp.

 

119

 

5,482

 

 

Vulcan Materials Co.

 

111

 

30,488

 

 

 

 

 

 

2,967,850

 

 

 

 

 

 

 

 

1.63%

REAL ESTATE

 

 

 

 

 

 

Alexandria Real Estate Equities, Inc. REIT

223

 

17,044

 

 

American Tower Corporate REIT

 

1,229

 

256,111

 

 

AvalonBay Communities, Inc. REIT

 

334

 

62,218

 

 

CBRE Group, Inc.(A)

 

1,323

 

206,044

 

 

Crown Castle, Inc. REIT

 

1,216

 

127,789

 

 

Digital Realty Trust, Inc. REIT

 

773

 

136,388

 

 

Equinix, Inc.

 

335

 

263,032

 

 

Equity Residential REIT

 

994

 

62,821

 

 

Extra Space Storage, Inc. REIT

 

112

 

15,048

 

 

Host Hotels & Resorts, Inc. REIT

 

1,316

 

20,688

 

 

Mid-America Apartment
Communities REIT

112

 

15,952

 

 

Millrose Properties, Inc. REIT

 

324

 

9,717

 

 

Prologis, Inc.

 

3,589

 

383,233

 

 

Public Storage REIT

 

552

 

150,111

 

10

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Schedule of Investments - continuedJuly 31, 2025

See Notes to Financial Statements

 

 

Shares

 

Value

 

Realty Income Corp. REIT

 

539

 

$30,254

 

 

SBA Communications Corp.

 

103

 

23,146

 

 

Simon Property Group, Inc. REIT

 

549

 

89,921

 

 

Ventas, Inc. REIT

 

657

 

44,137

 

 

Welltower, Inc. REIT

 

1,104

 

182,237

 

 

Weyerhaeuser Co. REIT

 

1,761

 

44,113

 

 

 

 

 

 

2,140,004

 

 

 

 

 

 

 

 

2.10%

UTILITIES

 

 

 

 

 

 

AES Corp.

 

657

 

8,640

 

 

Ameren Corp.

 

99

 

10,012

 

 

American Electric Power, Inc.

 

450

 

50,913

 

 

American Water Works Co.

 

223

 

31,274

 

 

CenterPoint Energy, Inc.

 

1,102

 

42,780

 

 

Consolidated Edison, Inc.

 

109

 

11,282

 

 

Constellation Energy Corp.

 

443

 

154,093

 

 

Dominion Energy, Inc.

 

641

 

37,466

 

 

DTE Energy Co.

 

446

 

61,731

 

 

Duke Energy Corp.

 

1,418

 

172,486

 

 

Edison International

 

873

 

45,501

 

 

Eversource Energy

 

883

 

58,366

 

 

Exelon Corp.

 

1,080

 

48,535

 

 

FirstEnergy Corp.

 

1,436

 

61,332

 

 

NextEra Energy, Inc.

 

8,685

 

617,156

 

 

Public Service Enterprise Group, Inc.

 

1,213

 

108,915

 

 

Sempra Energy

 

470

 

38,390

 

 

The Southern Compan

 

10,793

 

1,019,723

 

 

WEC Energy Group

 

666

 

72,647

 

 

Xcel Energy, Inc.

 

1,324

 

97,235

 

 

 

 

 

 

2,748,477

 

 

 

 

 

 

 

 

99.82%

TOTAL COMMON STOCKS

 

 

 

 

 

(Cost: $100,431,145)

 

 

 

130,919,120 

 

 

 

 

 

 

 

 

99.82%

TOTAL INVESTMENTS

 

 

 

 

 

(Cost: $100,431,145)

 

 

130,919,120 

 

0.18%

Other assets, net of liabilities

 

 

 

240,556

 

100.00%

NET ASSETS

 

 

 

$131,159,676

 

(A)Non-income producing

(B)Non-voting shares

ADR - Security represented is held by the custodian in the form of American Depositary Receipts.

REIT- Real Estate Investment Trust

11

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Statement of Assets and LiabilitiesJuly 31, 2025

See Notes to Financial Statements

ASSETS

Investments at value (cost of $100,431,145) (Note 1)

$130,919,120

Cash

245,309

Dividends receivable

78,430

TOTAL ASSETS

131,242,859

 

LIABILITIES

Accrued advisory fees

83,183

TOTAL LIABILITIES

83,183

NET ASSETS

$131,159,676

 

Net Assets Consist of:

Paid-in capital

$103,369,975

Distributable earnings (accumulated deficit)

27,789,701

Net Assets

$131,159,676

 

NET ASSET VALUE PER SHARE

Net Assets

$131,159,676

Shares Outstanding (unlimited number of shares of beneficial interest authorized without par value)

2,750,000

Net Asset Value and Offering Price Per Share

$47.69

12

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Statement of OperationsYear Ended July 31, 2025

See Notes to Financial Statements

INVESTMENT INCOME

Dividend income (net of foreign tax withheld of $1,457)

$1,604,777

Total investment income

1,604,777

 

 

EXPENSES

 

Investment advisory fees (Note 2)

865,874

Total expenses

865,874

Net investment income (loss)

738,903

 

 

REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS

 

Net realized gain (loss) on investments(1)

2,806,226

Net change in unrealized appreciation (depreciation) of investments

12,356,955

 

Net realized and unrealized gain (loss) on investments

15,163,181

 

INCREASE (DECREASE) IN NET ASSETS FROM OPERATIONS

$15,902,084

(1)Includes reazlied gains (losses) as a result of in-kind transactions (Note 3).

13

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Statements of Changes in Net Assets

See Notes to Financial Statements

Year Ended
July 31, 2025

Year Ended
July 31, 2024

INCREASE (DECREASE) IN NET ASSETS FROM

 

OPERATIONS

Net investment income (loss)

$738,903

$583,679

Net realized gain (loss) on investments

2,806,226

2,403,253

Net change in unrealized appreciation (depreciation) of investments

12,356,955

 

12,047,457

Increase (decrease) in net assets from operations

15,902,084

 

15,034,389

 

DISTRIBUTIONS TO SHAREHOLDERS

Distributions to shareholders

(751,218

)

(565,179

)

Decrease in net assets from distributions

(751,218

)

(565,179

)

 

 

CAPITAL STOCK TRANSACTIONS (NOTE 5)

 

Proceeds from shares issued

23,473,329

38,258,227

Shares redeemed

(6,757,242

)

(10,035,347

)

Increase (decrease) in net assets from capital
stock transactions

16,716,087

 

28,222,880

 

NET ASSETS

Increase (decrease) during year

31,866,953

42,692,090

Beginning of year

99,292,723

 

56,600,633

End of year

$131,159,676

 

$99,292,723

15

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Selected Per Share Data Throughout Each Period

14

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Financial Highlights

 

Years Ended July 31,

Period Ended
July 31, 2021*

 

2025

 

2024

 

2023

 

2022

 

 

Net asset value, beginning of period

$41.81

 

$34.83

 

$30.99

 

$32.55

 

$25.00

Investment activities

Net investment income (loss)(1)

0.28

0.29

0.29

0.25

0.19

Net realized and unrealized gain (loss) on investments

5.89

 

6.97

 

3.83

 

(1.58

 )

7.53

Total from investment activities

6.17

 

7.26

 

4.12

 

(1.33

)

7.72

Distributions

 

 

Net investment income

(0.29

)

(0.28

)

(0.28

)

(0.21

)

(0.17

)

Net realized gain

 

 

 

(0.02

)

Total distributions

(0.22

)

(0.28

)

(0.28

)

(0.23

)

(0.17

)

Net asset value, end of period

$47.69

 

$41.81

 

$34.83

 

$30.99

 

$32.55

 

 

 

Total Return(2)

14.82

%

20.93

%

13.45

%

(4.06

%)

30.96

%

Ratios/Supplemental Data

 

Ratios to average net assets(3)

 

Expenses

0.75

%

0.75

%

0.75

%

0.75

%

0.75

%

Net investment income (loss)

0.64

%

0.77

%

0.94

%

0.77

%

0.82

%

Portfolio turnover rate(4)

6.37

%

12.98

%

9.27

%

3.70

%

6.04

%

Net assets, end of period (000’s)

$131,160

$99,293

$56,601

$32,537

$13,965

(1)Per share amounts caluculated using the average shares outstanding during the period.

(2)Total return is for the period indicated and has not been annualized for periods less than one year.

(3)Ratios to average net assets have been annualized for periods less than a year.

(4)Portfolio turnover rate is for the period indicated, excludes the effect of securities received or
delivered from processing in-kind creations or redemptions, and has not been annualized for
periods less than
one year.

*The Fund commenced operations on October 28, 2020.

16

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Notes to Financial StatementsJuly 31, 2025

NOTE 1 – ORGANIZATION AND SIGNIFICANT ACCOUNTING POLICIES

The American Conservative Values ETF (the “Fund”) is a diversified series of ETF Opportunities Trust, a Delaware statutory trust (the “Trust”) which was organized on March 18, 2019 and is registered under the Investment Company Act of 1940, as amended (the “1940 Act”) as an open-end management investment company. The offering of the Fund’s shares is registered under the Securities Act of 1933, as amended. The Fund commenced operations on October 28, 2020.

The Fund’s objective is to seek to achieve long-term capital appreciation with capital preservation as a secondary objective.

The Fund is deemed to be an individual reporting segment and is not part of a consolidated reporting entity. The objective and strategy of the Fund is used by Ridgeline Research LLC (the “Advisor”) to make investment decisions, and the results of the Fund’s operations, as shown in its Statement of Operations and Financial Highlights, is the information utilized for the day-to-day management of the Fund. Due to the significance of oversight and its role in the Fund’s management, the Advisor’s portfolio manager is deemed to be the Chief Operating Decision Maker.

The following is a summary of significant accounting policies consistently followed by the Fund. The policies are in conformity with accounting principles generally accepted in the United States of America (“GAAP”). The Fund follows the investment company accounting and reporting guidance of the Financial Accounting Standards Board (“FASB”) Accounting Standards Codification Topic 946 “Financial Services – Investment Companies”.

Security Valuation

The Fund records its investments at fair value. Generally, the Fund’s domestic securities are valued each day at the last quoted sales price on each security’s primary exchange. Securities traded or dealt in upon one or more securities exchanges for which market quotations are readily available and not subject to restrictions against resale are valued at the last quoted sales price on the primary exchange or, in the absence of a sale on the primary exchange, at the mean between the current bid and ask prices on such exchange. Securities primarily traded in the NASDAQ National Market System for which market quotations are readily available shall be valued using the NASDAQ Official Closing Price. If market quotations are not readily available, securities are valued at their fair market value as determined in good faith under procedures set by the Trust’s Board of Trustees (the “Board”). Although the Board is ultimately responsible

17

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Notes to Financial Statements - continuedJuly 31, 2025

for fair value determinations under Rule 2a-5 of the 1940 Act, the Board has delegated day-to-day responsibility for oversight of the valuation of the Fund’s assets to the Advisor as the Valuation Designee pursuant to the Fund’s policies and procedures. Securities that are not traded or dealt in any securities exchange (whether domestic or foreign) and for which over-the-counter market quotations are readily available generally are valued at the last sale price or, in the absence of a sale, at the mean between the current bid and ask price on such over-the- counter market.

The Fund has a policy that contemplates the use of fair value pricing to determine the net asset value (“NAV”) per share of the Fund when market prices are unavailable as well as under special circumstances, such as: (i) if the primary market for a portfolio security suspends or limits trading or price movements of the security; and (ii) when an event occurs after the close of the exchange on which a portfolio security is principally traded, but prior to the time as of which the Fund’s NAV is calculated, that is likely to have changed the value of the security. Since most of the Fund’s investments are traded on U.S. securities exchanges, it is anticipated that the use of fair value pricing will be limited.

When the Fund uses fair value pricing to determine the NAV per share of the Fund, securities will not be priced on the basis of quotations from the primary market in which they are traded, but rather may be priced by another method that the Valuation Designee believes accurately reflects fair value. Any method used will be approved by the Board and results will be monitored to evaluate accuracy. The Fund’s policy is intended to result in a calculation of the Fund’s NAV that fairly reflects security values as of the time of pricing.

The Fund has adopted fair valuation accounting standards that establish an authoritative definition of fair value and set out a hierarchy for measuring fair value. These standards require additional disclosures about the various inputs used to develop the measurements of fair value. These inputs are summarized in the three broad levels listed below.

Various inputs are used in determining the value of the Fund’s investments. GAAP established a three-tier hierarchy of inputs to establish a classification of fair value measurements for disclosure purposes. Level 1 includes quoted prices in active markets for identical securities. Level 2 includes other significant observable market-based inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.). Level 3 includes significant unobservable inputs (including the Fund’s own assumptions in determining fair value of investments).

18

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Notes to Financial Statements - continuedJuly 31, 2025

The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities.

The following is a summary of the level of inputs used to value the Fund’s investments as of July 31, 2025:

Level 1
Quoted Prices

Level 2
Other Significant Observable Inputs

Level 3
Significant Unobservable Inputs

Total

Common Stocks

$130,919,120

$

$

$130,919,120

 

$130,919,120

$

$

$130,919,120

Refer to the Fund’s Schedule of Investments for a listing of the securities by type and sector. The Fund held no Level 3 securities at any time during the year ended July 31, 2025.

Security Transactions and Income

Security transactions are accounted for on the trade date. The cost of securities sold is determined generally on specific identification basis to calculate realized gains and losses from security transactions for book and tax purposes. Dividends are recorded on the ex-dividend date. Interest income is recorded on an accrual basis. Withholding taxes on foreign dividends have been provided for in accordance with the Fund’s understanding of the applicable country’s tax rules and rates.

Accounting Estimates

In preparing financial statements in conformity with GAAP, management makes estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures of contingent assets and liabilities at the date of the financial statements, as well as the reported amounts of investment income and expenses during the reporting period. Actual results could differ from those estimates.

Federal Income Taxes

The Fund has complied and intends to continue to comply with the requirements of the Internal Revenue Code applicable to regulated investment companies and to distribute all of its taxable income to its shareholders. The Fund also

19

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Notes to Financial Statements - continuedJuly 31, 2025

intends to distribute sufficient net investment income and net capital gains, if any, so that it will not be subject to excise tax on undistributed income and gains. Therefore, no federal income tax or excise provision is required.

Management has concluded that no liability for unrecognized tax benefits should be recorded related to uncertain tax positions taken in the Fund’s tax returns. The Fund has no examinations in progress and management is not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly change in the next twelve months. Interest and penalties, if any, associated with any federal or state income tax obligations are recorded as income tax expense as incurred.

Reclassification of Capital Accounts

GAAP requires that certain components of net assets relating to permanent differences be reclassified between financial and tax reporting. For the year ended July 31, 2025, such reclassifications were attributable primarily to the tax treatment of redemptions in-kind.

Distributable earnings

$(3,280,998

)

Paid-in capital

3,280,998

Dividends and Distributions

Dividends from net investment income, if any, are declared and paid quarterly by the Fund. The Fund distributes its net realized capital gains, if any, to shareholders annually. The Fund may also pay a special distribution at the end of a calendar year to comply with federal tax requirements. All distributions are recorded on the ex-dividend date.

Creation Units

The Fund issues and redeems shares to certain institutional investors (typically market makers or other broker-dealers) only in large blocks of at least 25,000 shares known as “Creation Units.” Purchasers of Creation Units (“Authorized Participants”) will be required to pay Citibank, N.A. (the “Custodian”) a fixed transaction fee (“Creation Transaction Fee”) in connection with creation orders that is intended to offset the transfer and other transaction costs associated with the issuance of Creation Units. The standard Creation Transaction Fee will be the same regardless of the number of Creation Units purchased by an investor on the applicable Business Day. The Creation Transaction Fee charged by the Custodian for each creation order is $1,500. Authorized Participants wishing to

20

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Notes to Financial Statements - continuedJuly 31, 2025

redeem shares will be required to pay to the Custodian a fixed transaction fee (“Redemption Transaction Fee”) to offset the transfer and other transaction costs associated with the redemption of Creation Units. The standard Redemption Transaction Fee will be the same regardless of the number of Creation Units redeemed by an investor on the applicable Business Day. The Redemption Transaction Fee charged by the Custodian for each redemption order is $1,500.

Except when aggregated in Creation Units, shares are not redeemable securities. Shares of the Fund may only be purchased or redeemed by Authorized Participants. An Authorized Participant is either (i) a broker-dealer or other participant in the clearing process through the Continuous Net Settlement System of the National Securities Clearing Corporation or (ii) a Depository Trust Company (“DTC”) participant and, in each case, must have executed an agreement with the Fund’s principal underwriter (the “Distributor”) with respect to creations and redemptions of Creation Units (“Participation Agreement”). Most retail investors will not qualify as Authorized Participants or have the resources to buy and sell whole Creation Units. Therefore, they will be unable to purchase or redeem the shares directly from the Fund. Rather, most retail investors will purchase shares in the secondary market with the assistance of a broker and will be subject to customary brokerage commissions or fees. The following table discloses the Creation Unit breakdown based on the NAV as of July 31, 2025:

Creation
Unit Shares

 

Creation Transaction Fee

 

Value

American Conservative Values ETF

25,000

$1,500

$1,192,250

To the extent contemplated by a participant agreement, in the event an Authorized Participant has submitted a redemption request in proper form but is unable to transfer all or part of the shares comprising a Creation Unit to be redeemed to the Distributor, on behalf of the Fund, by the time as set forth in a participant agreement, the Distributor may nonetheless accept the redemption request in reliance on the undertaking by the Authorized Participant to deliver the missing shares as soon as possible, which undertaking shall be secured by the Authorized Participant’s delivery and maintenance of collateral equal to a percentage of the value of the missing shares as specified in the participant agreement. A participant agreement may permit the Fund to use such collateral to purchase the missing shares, and could subject an Authorized Participant to liability for any shortfall between the cost of the Fund acquiring such shares and the value of the collateral. Amounts are disclosed as Segregated Cash Balance from Authorized Participants for Deposit Securities and Collateral Payable upon Return of Deposit Securities on the Statement of Assets and Liabilities, when applicable.

21

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Notes to Financial Statements - continuedJuly 31, 2025

Officers and Trustees Indemnification

Under the Trust’s organizational documents, its officers and trustees are indemnified against certain liabilities arising out of the performance of their duties to the Fund. In addition, in the normal course of business, the Fund enters into contracts with its vendors and others that provide for general indemnifications. The Fund’s maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Fund. However, based on experience, the Fund expects that risk of loss to be remote.

NOTE 2 – INVESTMENT ADVISORY AND DISTRIBUTION AGREEMENTS AND OTHER TRANSACTIONS WITH AFFILIATES

The Advisor currently provides investment advisory services pursuant to an investment advisory agreement (the “Advisory Agreement”). Under the terms of the Advisory Agreement, the Advisor manages the investment portfolio of the Fund, subject to the policies adopted by the Trust’s Board of Trustees. Under the Advisory Agreement, the Advisor, at its own expense and without reimbursement from the Trust, furnishes office space and all necessary office facilities, equipment and executive personnel necessary for managing the assets of the Fund. Under the Advisory Agreement, the Advisor assumes and pays all ordinary expenses of the Fund, except the fee paid to the Advisor pursuant to the Investment Advisory Agreement, distribution fees or expenses under a 12b-1 plan (if any), interest expenses, taxes, acquired fund fees and expenses, brokerage commissions and any other portfolio transaction related expenses and fees arising out of transactions effected on behalf of the Fund, credit facility fees and expenses, including interest expenses, and litigation and indemnification expenses and other extraordinary expenses not incurred in the ordinary course of the Fund’s business.

For its services with respect to the Fund, the Advisor is entitled to receive an annual advisory fee, calculated daily and payable monthly as a percentage of the Fund’s average daily net assets, at the rate of 0.75%.

The Advisor has retained Vident Asset Management (the “Sub-Advisor”), to serve as sub-advisor for the Fund. The Sub-Advisor is responsible for trading portfolio securities on behalf of the Fund, including selecting broker-dealers to execute purchase and sale transactions as instructed by the Advisor, subject to the supervision of the Advisor and the Board.

For the services it provides to the Fund, the Sub-Advisor is compensated by the Advisor from the advisory fees paid by the Fund to the Advisor. Fees to the Sub-Advisor are calculated daily and paid monthly, based on the daily net assets

22

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Notes to Financial Statements - continuedJuly 31, 2025

of the Fund at the following rate: 0.05% on the first $250 million in net assets; 0.04% on the next $250 million in net assets; and 0.03% on any net assets in excess of $500 million (subject to a minimum of $30,000 per year).

Fund Administrator

Commonwealth Fund Services, Inc. (“CFS”) acts as the Fund’s administrator. As administrator, CFS supervises all aspects of the operations of the Fund except those performed by the Advisor and the Sub-Advisor. For its services, fees to CFS are computed daily and paid monthly based on the average daily net assets of the Fund. The Advisor pays these fees.

Custodian

Citibank, N.A. serves as the Fund’s Custodian pursuant to a Global Custodial and Agency Services Agreement. For its services, Citibank, N.A. is entitled to a fee. The Advisor pays these fees monthly.

Fund Accountant and Transfer Agent

Citi Fund Services, Ohio, Inc. serves as the Fund’s Fund Accountant and Transfer Agent pursuant to a Services Agreement. For its services, Citi Fund Services, Ohio, Inc. is entitled to a fee. The Advisor pays these fees monthly.

Distributor

Foreside Fund Services, LLC serves as the Fund’s principal underwriter pursuant to an ETF Distribution Agreement. For its services, Foreside Fund Services, LLC is entitled to a fee. The Advisor pays these fees monthly.

Trustees and Officers

Each Trustee who is not an “interested person” of the Trust receives compensation for their services to the Funds. Each Trustee receives an annual retainer fee, paid quarterly. Trustees are reimbursed for any out-of-pocket expenses incurred in connection with attendance at meetings. The Advisor pays these costs.

Certain officers of the Trust are also officers and/or directors of CFS. Additionally, Practus, LLP serves as legal counsel to the Trust. John H. Lively, Secretary of the Trust, is Managing Partner of Practus, LLP. J. Stephen King, Jr., Assistant Secretary of the Trust, is a partner of Practus, LLP. Tom Carter, Vice President

23

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Notes to Financial Statements - continuedJuly 31, 2025

of the Trust, is President of the Advisor. Neither the officers and/or directors of CFS, Mr. Lively, Mr. King, or Mr. Carter receive any special compensation from the Trust or the Fund for serving as officers of the Trust.

The Fund’s Chief Compliance Officer and Assistant Chief Compliance Officer are not compensated directly by the Fund for its service. However, the Assistant Chief Compliance Officer is the Managing Member of Watermark Solutions, LLC (“Watermark”), which provides certain compliance services to the Fund, including the provision of the Chief Compliance Officer and the Assistant Chief Compliance Officer. The Chief Compliance Officer is the Managing Member of Fit Compliance, LLC, which has been retained by Watermark to provide the Chief Compliance Officer’s services.

NOTE 3 – INVESTMENTS

The costs of purchases and proceeds from the sales of securities other than in-kind transactions for the year ended July 31, 2025, were as follows:

Purchases

Sales

$7,349,246

$7,386,524

The costs of purchases and proceeds from the sales of in-kind transactions associated with creations and redemptions for the year ended July 31, 2025, were as follows:

Purchases

Sales

Realized Gain

$23,364,423

$6,550,908

$3,280,650

NOTE 4 – DISTRIBUTIONS TO SHAREHOLDERS AND TAX COMPONENTS OF CAPITAL

Distributions are determined on a tax basis and may differ from net investment income and realized capital gains for financial reporting purposes. Differences may be permanent or temporary. Permanent differences are reclassified among capital accounts in the financial statements to reflect their tax character. Temporary differences arise when certain items of income, expense, gain or loss are recognized in different periods for financial statement and tax purposes; these differences will reverse at some time in the future. Differences in classification may also result from the treatment of short-term gains as ordinary income for tax purposes.

24

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Notes to Financial Statements - continuedJuly 31, 2025

The tax character of distributions during the years ended July 31, 2025 and 2024 were as follows:

Year Ended
July 31, 2025

Year Ended
July 31, 2024

Distributions paid from: 

Ordinary income

$751,218

$565,179

 

$751,218

$565,179

As of July 31, 2025, the components of distributable earnings (accumulated deficits) on a tax basis were as follows:

Accumulated undistributed net investment income (loss)

$27,043

Other losses

(2,724,636

)

Net unrealized appreciation (depreciation) on investments

30,487,294

 

$27,789,701

As of July 31, 2025, the Fund had a capital loss carryforward of $2,724,636, of which $851,226 is considered short term and $1,873,410 is considered long term. These losses may be carried forward indefinitely.

Cost of securities for Federal Income tax purpose and the related tax-based net unrealized appreciation (depreciation) consists of:

Cost

Gross Unrealized Appreciation

Gross Unrealized Depreciation

Total Unrealized Appreciation (Depreciation)

$100,431,826

$34,736,323

$(4,249,029)

$30,487,294

The difference between book basis and tax basis accumulated appreciation (depreciation) is attributable primarily to the deferral of wash sale losses.

NOTE 5 – TRANSACTIONS IN SHARES OF BENEFICIAL INTEREST

Shares of the Fund are listed for trading on the NYSE Arca, Inc. (the “Exchange”), and trade at market prices rather than at NAV. Shares of the Fund may trade at a price that is greater than, at, or less than NAV. The Fund will issue and redeem shares at NAV only in large blocks of 25,000 shares (each block of shares is called a “Creation Unit”). Creation Units are issued and redeemed for cash and/or in-kind for securities. Individual shares may only be purchased and sold in secondary market transactions through brokers. Except when aggregated in Creation Units, the shares are not redeemable securities of the Fund.

All orders to create Creation Units must be placed with the Fund’s distributor or transfer agent either (1) through the Continuous Net Settlement System of the NSCC (“Clearing Process”), a clearing agency that is registered with the U.S.

25

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Notes to Financial Statements - continuedJuly 31, 2025

Securities and Exchange Commission (“SEC”), by a “Participating Party,” i.e., a broker-dealer or other participant in the Clearing Process; or (2) outside the Clearing Process by a DTC Participant. In each case, the Participating Party or the DTC Participant must have executed an agreement with the Distributor with respect to creations and redemptions of Creation Units (“Participation Agreement”); such parties are collectively referred to as “APs” or “Authorized Participants.” Investors should contact the Distributor for the names of Authorized Participants. All Fund shares, whether created through or outside the Clearing Process, will be entered on the records of DTC for the account of a DTC Participant.

Shares of beneficial interest transactions for the Fund were:

Year Ended July 31, 2025

Year Ended July 31, 2024

Shares sold

525,000

1,025,000

Shares redeemed

(150,000

)

(275,000

)

Net increase (decrease)

375,000

750,000

NOTE 6 – RISKS OF INVESTING IN THE FUND

It is important that you closely review and understand the risks of investing in the Fund. The Fund’s NAV and investment return will fluctuate based upon changes in the value of its portfolio securities. You could lose money on your investment in the Fund, and the Fund could underperform other investments. There is no guarantee that the Fund will meet its investment objective. An investment in the Fund is not a deposit of a bank and is not insured or guaranteed by the FDIC or any other government agency. A complete description of the principal risks is included in the Fund’s prospectus under the heading “Principal Risks.”

NOTE 7 – SUBSEQUENT EVENTS

Subsequent to the date of the financial statements, the Fund has made the following distributions to the shareholders of record:

Record Date

Ex-Dividend Date

Character

Amount

September 24, 2025

September 24, 2025

Net investment income

$195,839

Management has evaluated all transactions and events subsequent to the date of the Statement of Assets and Liabilities through the date on which these financial statements were issued and, except as noted above, has noted no additional items require disclosure.

26

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Report of Independent Registered Public Accounting Firm

See Notes to Financial Statements

To the Shareholders of American Conservative Values ETF and
Board of Trustees of ETF
Opportunities Trust

Opinion on the Financial Statements

We have audited the accompanying statement of assets and liabilities, including the schedule of investments, of American Conservative Values ETF (the “Fund”), a series of ETF Opportunities Trust, as of July 31, 2025, the related statement of operations for the year then ended, the statements of changes in net assets for each of the two years in the period then ended, the financial highlights for the years ended July 31, 2025, 2024, 2023, and 2022 and for the period from October 28, 2020 (commencement of operations) through July 31, 2021, and the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Fund as of July 31, 2025, the results of its operations for the year then ended, the changes in net assets for each of the two years in the period then ended, and the financial highlights for the years ended July 31, 2025, 2024, 2023, and 2022 and for the period October 28, 2020 (commencement of operations) through July 31, 2021, in conformity with accounting principles generally accepted in the United States of America.

Basis for Opinion

These financial statements are the responsibility of the Fund’s management. Our responsibility is to express an opinion on the Fund’s financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to the Fund in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement whether due to error or fraud.

Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our procedures included confirmation of securities owned as of July 31, 2025, by correspondence with the custodian. Our audits

27

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Report of Independent Registered Public Accounting Firm - continued

See Notes to Financial Statements

also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

We have served as the Fund’s auditor since 2020.

COHEN & COMPANY, LTD.
Cleveland, Ohio
September
29, 2025

28

FINANCIAL STATEMENTS | July 31, 2025

American Conservative Values ETF

Supplemental Information (unaudited)

Changes in and disagreements with accountants for open-end management investment companies.

Not applicable.

Proxy disclosures for open-end management investment companies.

The Trustees of the Trust authorized a Special Meeting of Shareholders that was held on August 15, 2024 (the “Special Meeting”). The Special Meeting was called for the purpose of electing Trustees to the Trust. Because the Special Meeting involved a matter that affected the Trust as a whole, the proposal was put forth for consideration by shareholders of each series of the Trust, including the Fund. A quorum of shareholders was not achieved and the Special Meeting was adjourned without action.

Remuneration paid to Directors, Officers, and others of open-end management investment companies.

Ridgeline Research, LLC (the “Advisor”) has agreed in the Investment Advisory Agreement to cover all operating expenses of the Funds, subject to certain exclusions as provided for therein, the Advisor pays the compensation to each Independent Trustee and the Chief Compliance Officer for services to the Fund from the Advisor’s management fees.

Statement Regarding Basis for Approval of Investment Advisory Contract.

Not applicable.

 

 

 

ITEM 8. CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES.

 

Not applicable.

 

ITEM 9. PROXY DISCLOSURES FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES.

 

Reference Item 7 which includes proxy disclosures for open-end management investment companies in the Supplemental Information.

 

ITEM 10. REMUNERATION PAID TO DIRECTORS, OFFICERS, AND OTHERS OF OPEN-END MANAGEMENT INVESTMENT COMPANIES.

 

Reference Item 7 which includes remuneration paid to the Trustees and Officers in the Supplemental Information.

 

ITEM 11. STATEMENT REGARDING BASIS FOR APPROVAL OF INVESTMENT ADVISORY CONTRACT.

 

Not applicable.

 

ITEM 12. DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

 

Not applicable because it is not a closed-end management investment company.

 

ITEM 13. PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

 

Not applicable because it is not a closed-end management investment company.

 

ITEM 14. PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS.

 

Not applicable because it is not a closed-end management investment company.

 

ITEM 15. SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS.

 

There have been no material changes to the procedures by which shareholders may recommend nominees to the registrant's board of trustees.

 

ITEM 16. CONTROLS AND PROCEDURES.

 

(a) The registrant's principal executive and principal financial officers, or persons performing similar functions, have concluded that the registrant's disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940, as amended (the "1940 Act") (17 CFR 270.30a-3(c))) are effective, as of a date within 90 days of the filing date of the report that includes the disclosure required by this paragraph, based on their evaluation of these controls and procedures required by Rule 30a-3(b) under the 1940 Act (17 CFR 270.30a-3(b)) and Rules 13a-15(b) or 15d-15(b) under the Securities Exchange Act of 1934, as amended (17 CFR 240.13a-15(b) or 240.15d- 15(b)).

 

(b) There were no changes in the registrant's internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act (17 CFR 270.30a-3(d)) that occurred during the period covered by this report that have materially affected, or are reasonably likely to materially affect, the registrant's internal control over financial reporting.

 

ITEM 17. DISCLOSURE OF SECURITIES LENDING ACTIVITIES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

 

Not applicable because it is not a closed-end management investment company.

 

 

 

 

ITEM 18. RECOVERY OF ERRONEOUSLY AWARDED COMPENSATION.

 

Not applicable.

 

ITEM 19. EXHIBITS.

 

(a)(1) Code of Ethics in response to Item 2 of this Form N-CSR is attached hereto.

 

(a)(2) Any policy required by the listing standards adopted pursuant to Rule 10D-1 under the Exchange Act of 1934 - Not applicable.

 

(a)(3) Certifications pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto.

 

(a)(3)(1) Any written solicitation to purchase securities under Rule 23c-1 under the Investment Company Act of 1940 – Not applicable.

 

(a)(3)(2) Change in the registrant’s independent public accountant – Not applicable.

 

(b) Certifications pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 are attached hereto.

 

 

 

 

SIGNATURES

 

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

 

Registrant:   ETF Opportunities Trust

 

By (Signature and Title)*: /s/ Karen Shupe
 

Karen Shupe

Principal Executive Officer

Date:  October 3, 2025  

 

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

 

By (Signature and Title)*: /s/ Karen Shupe
 

Karen Shupe

Principal Executive Officer

Date: October 3, 2025  
   
By (Signature and Title)*: /s/ Ann MacDonald
 

Ann MacDonald

Principal Financial Officer

Date: October 3, 2025  

 

* Print the name and title of each signing officer under his or her signature.

 

 

 

 

ETF Opportunities Trust N-CSR

 

Exhibit 99.COE

 

ETF OPPORTUNITIES TRUST

CODE OF ETHICS FOR SENIOR OFFICERS

 

Preamble

 

Section 406 of the Sarbanes-Oxley Act of 2002 directs that rules be adopted disclosing whether a company has a code of ethics for senior financial officers.  The U.S. Securities and Exchange Commission (the "SEC") has adopted rules requiring annual disclosure of an investment company's code of ethics applicable to the company's principal executive as well as principal financial officers, if such a code has been adopted. In response, ETF Opportunities Trust (the "Company") has adopted this Code of Ethics (the "Code").

 

Statement of Policy

 

It is the obligation of the senior officers of the Company to provide full, fair, timely and comprehensible disclosure--financial and otherwise--to Company shareholders, regulatory authorities and the general public. In fulfilling that obligation, senior officers must act ethically, honestly and diligently. This Code is intended to enunciate guidelines to be followed by persons who serve the Company in senior officer positions. No Code of Ethics can address every situation that a senior officer might face; however, as a guiding principle, senior officers should strive to implement the spirit as well as the letter of applicable laws, rules and regulations, and to provide the type of clear and complete disclosure and information Company shareholders have a right to expect.

 

The purpose of this Code of Ethics is to promote high standards of ethical conduct by Covered Persons (as defined below) in their capacities as officers of the Company, to instruct them as to what is considered to be inappropriate and unacceptable conduct or activities for officers and to prohibit such conduct or activities. This Code supplements other policies that the Company and its adviser has adopted or may adopt in the future with which Company officers are also required to comply (e.g., code of ethics relating to personal trading and conduct).

 

Covered Persons

 

This Code of Ethics applies to those persons appointed by the Company's Board of Trustees as Chief Executive Officer, President, Chief Financial Officer and Chief Accounting Officer, or persons performing similar functions.

 

Promotion of Honest and Ethical Conduct

 

In serving as an officer of the Company, each Covered Person must maintain high standards of honesty and ethical conduct and must encourage his colleagues who provide services to the Company, whether directly or indirectly, to do the same.

 

Each Covered Person understands that as an officer of the Company, he has a duty to act in the best interests of the Company and its shareholders. The interests of the Covered Person's personal interests should not be allowed to compromise the Covered Person from fulfilling his duties as an officer of the Company.

 

If a Covered Person believes that his personal interests are likely to materially compromise his objectivity or his ability to perform the duties of his role as an officer of the Company, he should consult with the Company's chief legal officer or outside counsel. Under appropriate circumstances, a Covered Person should also consider whether to present the matter to the Trustees of the Company or a committee thereof.

 

No Covered Person shall suggest that any person providing, or soliciting to be retained to provide, services to a Company give a gift or an economic benefit of any kind to him in connection with the person's retention or the provision of services.

 

Promotion of Full, Fair, Accurate, Timely and Understandable Disclosure

 

 

 

 

No Covered Person shall create or further the creation of false or misleading information in any SEC filing or report to Company shareholders. No Covered Person shall conceal or fail to disclose information within the Covered Person's possession legally required to be disclosed or necessary to make the disclosure made not misleading. If a Covered Person shall become aware that information filed with the SEC or made available to the public contains any false or misleading information or omits to disclose necessary information, he shall promptly report it to Company counsel, who shall advise such Covered Person whether corrective action is necessary or appropriate.

 

Each Covered Person, consistent with his responsibilities, shall exercise appropriate supervision over, and shall assist, Company service providers in developing financial information and other disclosure that complies with relevant law and presents information in a clear, comprehensible and complete manner. Each Covered Person shall use his best efforts within his area of expertise to assure that Company reports reveal, rather than conceal, the Company's financial condition.

 

Each Covered Person shall seek to obtain additional resources if he believes that available resources are inadequate to enable the Company to provide full, fair and accurate financial information and other disclosure to regulators and Company shareholders.

 

Each Covered Person shall inquire of other Company officers and service providers, as appropriate, to assure that information provided is accurate and complete and presented in an understandable format using comprehensible language.

 

Each Covered Person shall diligently perform his services to the Company, so that information can be gathered and assessed early enough to facilitate timely filings and issuance of reports and required certifications.

 

Promotion of Compliance with Applicable Government Laws, Rules and Regulations

 

Each Covered Person shall become and remain knowledgeable concerning the laws and regulations relating to the Company and its operations and shall act with competence and due care in serving as an officer of the Company. Each Covered Person with specific responsibility for financial statement disclosure will become and remain knowledgeable concerning relevant auditing standards, generally accepted accounting principles, FASB pronouncements and other accounting and tax literature and developments.

 

Each Covered Person shall devote sufficient time to fulfilling his responsibilities to the Company.

 

Each Covered Person shall cooperate with the Company's independent auditors, regulatory agencies and internal auditors in their review or inspection of the Company and its operations.

 

No Covered Person shall knowingly violate any law or regulation relating to the Company or their operations or seek to illegally circumvent any such law or regulation.

 

No Covered Person shall engage in any conduct involving dishonesty, fraud, deceit or misrepresentation involving the Company or their operations.

Promoting Prompt Internal Reporting of Violations

 

Each Covered Person shall promptly report his own violations of this Code and violations by other Covered Persons of which he is aware to the Chairman of the Company's Audit Committee.

 

Any requests for a waiver from or an amendment to this Code shall be made to the Chairman of the Company's Audit Committee. All waivers and amendments shall be disclosed as required by law.

 

 

 

 

Sanctions

 

Failure to comply with this Code will subject the violator to appropriate sanctions, which will vary based on the nature and severity of the violation.  Such sanctions may include censure, suspension or termination of position as an officer of the Company. Sanctions shall be imposed by the Company's Audit Committee, subject to review by the entire Board of Trustees of the Company.


Each Covered Person shall be required to certify annually whether he has complied with this Code.

 

No Rights Created

 

This Code of Ethics is a statement of certain fundamental principles, policies and procedures that govern the Company's senior officers in the conduct of the Company's business. It is not intended to and does not create any rights in any employee, investor, supplier, competitor, shareholder or any other person or entity.

 

Recordkeeping

 

The Company will maintain and preserve for a period of not less than six (6) years from the date such action is taken, the first two (2) years in an easily accessible place, a copy of the information or materials supplied to the Board (1) that provided the basis for any amendment or waiver to this Code and (2) relating to any violation of the Code and sanctions imposed for such violation, together with a written record of the approval or action taken by the Board.

 

Amendments

 

The Trustees will make and approve such changes to this Code of Ethics as they deem necessary or appropriate to effectuate the purposes of this Code.

 

Dated:  October 7, 2021

                   

 

 

 

ETF Opportunities Trust N-CSR

 

Exhibit 99.CERT

 

PRINCIPAL EXECUTIVE OFFICER CERTIFICATION

 

I, Karen Shupe, Principal Executive Officer of ETF Opportunities Trust, certify that:

 

1. I have reviewed this report on Form N-CSR of the American Conservative Values ETF;

 

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

 

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

 

4. The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

 

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

 

(b) Designed such internal control over financial reporting, or caused such internal control over financial  reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial  statements for external purposes in accordance with generally accepted accounting principles;

 

(c) Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

 

(d) Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and

 

 5. The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of trustees (or persons performing the equivalent functions):

 

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and

 

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting.

 

Date:   October 3, 2025

 

/s/ Karen Shupe

Principal Executive Officer

 

 

 

                               

PRINCIPAL FINANCIAL OFFICER CERTIFICATION

 

I, Ann MacDonald, Principal Financial Officer of ETF Opportunities Trust, certify that:

 

1. I have reviewed this report on Form N-CSR of the American Conservative Values ETF;

 

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

 

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

 

4. The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

 

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

 

(b) Designed such internal control over financial reporting, or caused such internal control over financial  reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial  statements for external purposes in accordance with generally accepted accounting principles;

 

(c) Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

 

(d) Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and

 

 5. The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of trustees (or persons performing the equivalent functions):

 

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and

 

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting.

 

Date: October 3, 2025

 

/s/ Ann MacDonald

Principal Financial Officer

 

 

 

 

ETF Opportunities Trust N-CSR

 

Exhibit 99.906 CERT

 

SECTION 906 CERTIFICATION

 

Pursuant to 18 U.S.C. ss.1350, the undersigned officer of ETF Opportunities Trust (the "Company"), hereby certifies that the Company's Report on Form N-CSR for the period ended July 31, 2025  (the "Report") fully complies with the  requirements  of Section 13(a) or 15(d), as applicable, of the Securities and Exchange Act of 1934 and that the information contained in the Report fairly presents,  in all material respects,  the financial  condition and results of operations of the Company.

 

Dated: October 3, 2025  
     
Name: /s/ Karen Shupe  
  Karen Shupe  
Title: Treasurer and Principal Executive Officer  

 

A signed original of this written statement required by Section 906 has been provided to the Fund and will be retained by the Fund and furnished to the U.S. Securities and Exchange Commission or its staff upon request. This certification is being furnished to the Commission pursuant to 18 U.S.C. Section 1350 and is not being filed as part of the Report.

 

 

 

 

 SECTION 906 CERTIFICATION

 

Pursuant to 18 U.S.C. ss.1350, the undersigned officer of ETF Opportunities Trust (the "Company"), hereby certifies that the Company's Report on Form N-CSR for the period ended July 31, 2025 (the "Report") fully complies with the requirements  of Section 13(a) or 15(d), as applicable, of the Securities and Exchange Act of 1934 and that the information contained in the Report fairly presents,  in all material respects,  the financial  condition and results of operations of the Company.

 

Dated: October 3, 2025  
     
Name: /s/ Ann MacDonald  
  Ann MacDonald  
Title: Assistant Treasurer and Principal Financial Officer  

 

A signed original of this written statement required by Section 906 has been provided to the Fund and will be retained by the Fund and furnished to the U.S. Securities and Exchange Commission or its staff upon request. This certification is being furnished to the Commission pursuant to 18 U.S.C. Section 1350 and is not being filed as part of the Report.