Background and Ownership Structure Innealta is a Texas limited liability company, formed on November 2, 2017, for the purpose of providing discretionary investment advisory services to U.S. open-end management investment companies registered under the Investment Company Act of 1940, as amended, and to separately managed accounts whose investors include large institutions and high net worth individuals, including but not limited to, state and local pensions, corporate pensions, endowments and foundations, regional banks, and family offices. Innealta’s principal office and place of business is located in Austin, Texas. Innealta filed its initial registration as an investment adviser with the SEC on January 10, 2018 and was granted effective registration by the SEC on February 13, 2018, under the Investment Advisers Act of 1940, as amended (the “Advisers Act”).1 Pursuant to an agreement and strategic reorganization of the Innealta Capital division (the “Innealta Division”) of AFAM Capital, Inc. (“AFAM”), Innealta acquired substantially all the assets of the Innealta Division, on April 1, 2018. As a result of such reorganization and pursuant to an affirmative proxy vote by the shareholders, on March 27, 2018, Innealta became the investment adviser to two diversified series of a U.S. open-end management investment company registered under the Investment Company Act of 1940, as amended (the “1940 Act”), previously advised by AFAM’s Innealta Division. The two primary principal indirect owners of Innealta are Dr. Vito A. Sciaraffia, through Riomaggiore Investments, LLC as its sole member, and Dr. Gonzalo E. Maturana, through Alsacia Investments, LLC, as its sole member. Dr. Sciaraffia has a seventy-four percent (84%) indirect ownership, Dr. Maturana has a ten percent (11%) indirect ownership, and certain employees of Innealta collectively have a sixteen percent (5%) ownership of Innealta. Innealta is managed and controlled under the direction of its Board of Managers, which is comprised of Dr. Vito A. Sciaraffia and Dr. Gonzalo E. Maturana (collectively, the “Board of Managers”). Innealta’s officers and senior management team is comprised of Dr. Vito A. Sciaraffia, as Chief Investment Officer, Dr. Gonzalo E. Maturana, as Head of Strategy, and Ms. Carla A. Fava Quiroga, Chief Operating Officer and Chief Compliance Officer (collectively, the “Senior Management Team”). Advisory Services Innealta’s portfolio management and investment advisory services are offered (directly or indirectly through a sub-advisory arrangement with the client's primary investment adviser) to individuals, high net worth individuals, banking or thrift institutions, registered investment companies, pooled investment vehicles, single-investor funds, discretionary and non-discretionary advisory programs, commingled investment vehicles, charitable and endowment organizations, pension and profit sharing plans, foundations, corporations and other businesses, government agencies, government chartered corporations, quasi-governmental agencies, state or municipal government entities and other investment advisers. Innealta currently provides discretionary portfolio management and investment advisory services to: (i) investment companies registered under the 1940 Act (the “Funds”); (ii) separately managed accounts (the “Separate Accounts”); (iii) separately-managed account wrap programs (“Wrap Fee Programs”) offered by unaffiliated investment advisers or broker-dealers (“Sponsors”); and (iv) other proprietary accounts. The 1 Registration of an investment adviser does not imply any level of skill or training. Funds, Separate Accounts and Wrap Fee Programs are each, a “Client” and collectively, the “Clients”2. The types of Clients to which Innealta provides investment management services are more fully disclosed in Innealta’s Form ADV Part 1 and summarized in Item 7 – Types of Clients of this Brochure. Innealta offers several investment strategies to Clients and in doing so may invest in a wide range of securities and other financial instruments, including: equity securities of domestic and foreign issuers (both publicly and privately traded); corporate debt securities of domestic and foreign issuers (both publicly and privately traded); derivative securities, including, but not limited to, futures, options, swaps, and forward contracts; warrants; commercial paper; foreign currency contracts; registered investment company securities, including exchange-traded funds (“ETFs”); and U.S. government securities. As financial markets and products evolve, Innealta may invest in other instruments or securities, whether currently existing or developed in the future, when consistent with the Client’s investment guidelines, objectives, and policies. Generally, Innealta invests for long‐term growth of capital and income. Within that framework, a Client’s objectives and unique circumstances may dictate that short‐term positions be taken. See Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss of this Brochure for more information on Innealta’s investment strategies philosophy, context and process, including portfolio construction. Innealta’s investment advisory (or sub-advisory) services consist of managing a Client’s portfolio of investments, pursuant to an investment management agreement or other similar governing agreement (the “Management Agreement”), by providing origination, acquisition, asset management, and other administrative services to each respective Client in accordance with each Client’s respective Management Agreement, prospectus and statement of additional information (e.g., registration statement), private placement memorandum, offering memorandum, offering circular, limited partnership agreement, or other similar disclosure and governing documents (collectively, the “governing documents”). Innealta’s investment advisory services consist of, but are not limited to, managing each Client’s portfolio of investments, including sourcing, selecting, and determining investments in each Client’s portfolio, monitoring investments by each Client and executing transactions on behalf of each Client, including investing and re-investing the assets of each Client’s portfolio in accordance with the investment objectives, policies and guidelines set forth in each respective Client’s governing documents. Accordingly, Innealta’s investment advisory services to the Funds is not tailored to the individualized needs or objectives of any particular Fund shareholder. An investment in a Fund by a shareholder does not, in and of itself, create an advisory relationship between the shareholder and Innealta. Shareholders are not permitted to impose restrictions or limitations on the management of any Fund. Except for certain Wrap Fee Programs discussed below, when Innealta serves as investment adviser, it enters into a written Management Agreement with each of its advisory Clients, as described herein above. Such Management Agreements include provisions related to each Client’s management fees, investment strategy, investment guidelines, termination rights, proxy voting and sub-adviser, if applicable. Innealta’s standard Management Agreement contract generally permits either party to terminate the contract at the end of any calendar quarter following thirty (30) days’ written notice or at any time following sixty (60) days written notice for the Funds and other pooled investment vehicles. Upon termination, Clients are billed only for the pro-rata portion of the management period. Clients do not pay a termination fee. 2 As an SEC-registered investment adviser, Innealta owes a fiduciary duty to all of its Clients. An investment in a Fund by an investor or shareholder does not, in and of itself, create an advisory relationship between the investor or shareholder and Recurrent. Investors or shareholders are not permitted to impose restrictions or limitations on the management of any Fund. In 2006, the decision by the Court of Appeals for the D.C. Circuit in Goldstein v. SEC, 451 F.3d 873 (D.C. Cir. June 23, 2006), with respect to funds, clarified that the “client” of an investment adviser to a fund is the fund itself and not an investor in the fund. When Innealta serve as a sub-adviser, Innealta enters into a sub-advisory agreement with an unaffiliated investment adviser. These sub-advisory agreements typically include information related to Innealta’s sub- advisory fee, investment strategy, investment guidelines, termination rights and proxy voting. The unaffiliated investment adviser enters into an investment management agreement with the end client. Tailored Advice and Client-Imposed Restrictions As stated herein above, Innealta’s investment advisory (or sub-advisory) services consist of managing a Client’s portfolio of investments, pursuant to the agreed upon terms of a Management Agreement.

Each Management Agreement is separately negotiated and designed to suit the needs of each particular Client and their respective investment objectives, policies, and guidelines as set forth in each respective Client’s governing documents. Innealta works with Clients to formulate appropriate and agreed-upon investment guidelines. Innealta offers several investment strategies to Clients and Clients may select a particular investment strategy that meets their investment goals and objectives, or a Client may tailor a particular investment strategy to meet their investment goals and objectives. Accordingly, Innealta can tailor its investment advisory services to the individual needs of each respective Client and is subject to applicable investment objectives, policies, and guidelines set forth in the governing documents for each respective Client. Such Management Agreements may impose restrictions on Innealta’s ability to invest in certain securities or types of securities. Additional portfolio restrictions may also include exposure limits, concentration limits, industry and sector limits, geographical limits, and liquidity limits. Additionally, Innealta works with Clients to determine the feasibility of monitoring proposed restrictions and limitations. Clients who restrict their investment portfolios may experience potentially worse performance results than Clients with unrestricted portfolios even for Clients with similar objectives. Innealta reserves the right to reject or terminate any Client that seeks restrictions which Innealta is unable to implement, or which may fundamentally alter the investment objective of the strategy selected by the Client. Investors who participate in pooled investment vehicles, such as Funds, generally may not tailor investment guidelines. Prospective clients and prospective client investors must consider whether a particular Innealta advisory relationship is appropriate for their own circumstances based on all relevant factors including, but not limited to, the prospective client’s own investment objectives, liquidity requirements, tax situation, and risk tolerance. Prospective clients are strongly encouraged to undertake appropriate due diligence including, but not limited to, a review of governing documents relating to the proposed investment program for the prospective client and to investigate additional details about Innealta’s investment strategies, methods of analysis, and related risks, before making an investment decision or committing to a service provided by Innealta. See Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss of this Brochure for a more detailed discussion on investment strategies and the risks involved with such strategies. ALL DISCUSSION OF A FUND IN THIS BROCHURE, INCLUDING BUT NOT LIMITED TO ITS INVESTMENTS, THE STRATEGIES USED IN MANAGING A FUNDS, AND CONFLICTS OF INTEREST FACED BY INNEALTA IN CONNECTION WITH THE MANAGEMENT OF A FUNDS ARE QUALIFIED IN THEIR ENTIRETY BY REFERENCE TO THE RESPECTIVE FUND’S GOVERNING DOCUMENTS. Wrap Fee Programs Innealta offers certain of its investment strategies to Clients invested in three different types of Wrap Fee Programs:
• “Single Contract Programs” in which Innealta enters into a contract with a Sponsor to provide discretionary advisory services to the Sponsor’s Clients;
• “Dual Contract Programs” where Innealta enters into a contract directly with the Client to provide discretionary advisory services and the Client enters into a separate contract with the Sponsor, custodian and other service providers; and
• “Model Programs” where Innealta provides a model portfolio to the Sponsor or overlay manager who typically retains the ultimate authority to execute investment transactions. In most Model Programs, Innealta treats the Sponsor or overlay manager as its Client. As of December 31, 2023, Innealta provided model portfolios to Sponsors or overlay managers with respect to approximately $211,101,504 in assets under advisement. As discussed below, Innealta generally does not have investment discretion or trading authority for these assets. As such, these assets are generally not included in Innealta’s assets under management provided below. In Single and Dual Contract Programs, Sponsors introduce Clients to Innealta and generally provide Clients a package of services which may include any or all of the following: discretionary investment management, trade execution, account custody, performance monitoring and manager evaluation. Sponsors receive a (“Wrap Fee”) from Clients for providing this package of services and Innealta receives a portion of the Wrap Fee from the Sponsor for its investment management services. Sponsors typically: (i) assist Clients in defining their investment objectives based on information provided by the Clients; (ii) determine whether the given Wrap Fee arrangement is suitable for each Client; (iii) aid in the selection and monitoring of investment advisers (whether Innealta or another adviser) to manage accounts (or a portion of account assets); and (iv) periodically contact Clients to ascertain whether there have been any changes in Clients’ financial circumstances or objectives that warrant changes in the arrangement or the manner in which Clients’ assets are managed. Innealta generally receives Client information through Sponsors and relies on Sponsors to forward current and accurate Client information on a timely basis to assist in Innealta’s day-to-day management of Clients’ accounts. Single and Dual Contract Program Clients may also contact Innealta directly concerning their accounts. Under the typical Model Program, Innealta provides Sponsors or overlay managers with initial model portfolios at the inception of the arrangement and then provides updates of the model portfolio on a regular basis as part of Innealta’s trade rotation procedures or at such other intervals agreed to by Innealta and the Sponsor. See Item 12 – Brokerage Practices for more information on trade rotation. Investors in Model Programs do not have direct access to Innealta. In these programs, Sponsors or overlay managers have investment discretion to accept, reject or modify Innealta’s trade recommendations and apply them to their clients’ accounts. As a result, Innealta generally does not consider these assets as discretionary assets. In certain cases, Innealta may enter Model Programs and retain investment discretion; however, Innealta may not have the responsibility to place orders for the execution of trades for Clients. In these instances, the Sponsors (or the broker-dealer affiliated with the Sponsors) are solely responsible to execute transactions for such trades and are solely responsible for providing best execution for such trades. Clients investing in Wrap Fee Programs generally may invest in Innealta strategies with lower account minimums than other account types; however, Wrap Fee Programs may not be suitable for any given Client. Suitability depends on a number of factors, including the applicable Wrap Fee, account size, anticipated account trading activity, the Client’s financial needs, circumstances and objectives, and the value of the various services provided. Clients should consult with their Sponsor to determine whether investing through a Wrap Fee Program is suitable for their circumstances. Innealta’s suitability responsibility is limited to ensuring that investments chosen for an account are appropriate in light of the investment strategy selected by a Client or the Sponsor. Smaller Wrap Fee Program accounts may not receive or be able to fully implement all of Innealta’s investment recommendations for a particular strategy depending on the price of securities and the size of the account. Innealta may also be restricted from investing in certain securities due to operational constraints or limitations set by the Sponsor. Clients investing in Wrap Fee Programs should receive a brochure from the Sponsor detailing all aspects of the Wrap Fee Program prior to selecting Innealta as an investment manager. Clients should review program documentation carefully and discuss with their financial adviser whether these programs, and Innealta’s strategies, are appropriate for their investment needs and circumstances. Regulatory Assets Under Management As of December 31, 2023, Innealta managed $305,046,819 of advisory assets, of which all were on a discretionary basis, and none were on a non-discretionary basis. The SEC has adopted a uniform method for advisers to calculate assets under management for regulatory purposes which it refers to as an adviser’s “regulatory assets under management.” Regulatory assets under management are generally an adviser’s gross assets, i.e., assets under management without deduction for outstanding indebtedness or other accrued but unpaid liabilities. Innealta reports its regulatory assets under management in Item 5 of Part 1 of Form ADV which you can find at www.adviserinfo.sec.gov.