A General Description of Advisory Firm and Identity of Owners Academy Asset Management (“AAM” or the “Firm”) is a New York-based investment management company that was organized as a Nevada limited liability company in late 2021. AAM has various certifications as both a disabled veteran and minority owned and operated firm. The Firm is owned by a disabled service veteran representing 100% of Firm ownership. Listed below is the Firm’s principal member (i.e., the individual controlling 25% or more of the Firm). Name Title Ronald Chance Mims CEO B. Types of Advisory Services Academy Asset Management provides investment management services with respect to client accounts.
• Separate Account Portfolio Management The Firm offers the following Investment Management Services: Separate Account Portfolio Management We provide investment management services of client funds in separate account portfolios both as an adviser and as a sub-adviser. We manage these advisory and sub-advisory accounts in a discretionary manner taking into account individual client needs, if any, set forth in the client’s investment management agreement or other written investment policy or guidelines provided by the client. Investment teams and individual portfolio managers often manage multiple accounts according to the same or a similar investment strategy. In this regard, we have been engaged by Tidal EFT Trust (“Tidal”) to provide certain sub-advisory services as specified in our sub- adviser management agreement with Tidal. Tailored Relationships Clients can impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. AAM will discuss with a client or a client’s representative any guideline or policy that may limit management of the funds in line with the strategy selected by the client. AAM may, in the future, provide discretionary investment adviser services to Collective Trust funds wherein the fund Trustee retains authority to accept or reject the advice or direction of the Firm. Types of Investments The Firm’s current investment strategies incorporate domestic, high-quality fixed income securities and will generally include the following securities either traded on an exchange or in the over-the-counter market:
• United

States government securities
• Investment grade corporate debt securities
• Agency debentures and discount notes
• Agency Mortgage-backed securities
• Asset-backed securities (ABS)
• Residential Mortgage-Backed Securities (RMBS)
• Commercial Mortgage-Backed Securities (CMBS)
• Commercial Paper
• Certificates of Deposit
• Money Market funds
• Municipals As noted above, AAM utilizes high quality securities in its investment strategies. However, because some types of investments may involve certain additional degrees of risk, they will only be implemented when consistent with the client’s stated investment objectives, tolerance for risk, liquidity, and suitability. Private Funds Though not currently contemplated, we may in the future provide investment management services to private investment funds. Each private investment fund is an investment pool with, among other things, its principal investment strategy described in a confidential private placement memorandum. We intend to manage the assets of these funds in a discretionary manner taking into account individual fund’s needs set forth in the confidential private placement memorandum and in the client’s investment management agreement or other written investment policy or guidelines provided by the client. Tailored Relationships Investors in a private investment fund generally do not have any right or opportunity to select or evaluate any fund strategy or investment. Accordingly, we generally do not permit investors in the funds to impose limitations on the investment activities described in the offering documents for the funds. Under certain circumstances, we will contract with a client to adhere to limited risk and/or operating guidelines imposed by the client. We negotiate such arrangements on a case-by-case basis. Types of Investments As set forth above, the types of investments undertaken by a private investment fund is ordinarily set forth in its confidential private placement memorandum, investment management agreement and any other investment guidance provided by the private fund to us. E. Amount of Managed Assets As of March 27, 2024, we actively managed clients' assets in the aggregate amount of $163.5 million on a discretionary basis.