A. Firm Description Formidable Asset Management, LLC, (“Formidable Asset Management,” “Formidable” or “the Firm”) is an investment management firm that is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser based in Cincinnati, Ohio. The Firm also operates under the tradename, Massey Romans Capital. The Firm’s registration as an investment adviser does not imply a certain level of skill or training. The Firm is organized as an Ohio limited liability company that was founded in 2013. Formidable Asset Management’s current business activities consist:
• Portfolio Management Services
• Financial Planning/Consulting Services
• Out-sourced CIO Consulting
• Pension Consulting Services
• Advisor to Exchange Traded Funds Principal Owner: William B. Brown is the principal owner. Mr. Brown also serves as an Investment Adviser Representative for the Firm. B. Types of Advisory Services PORTFOLIO MANAGEMENT SERVICES Formidable Asset Management offers personalized investment advisory services which are focused on capital appreciation. The Firm provides portfolio management services employing its investment strategies, either in isolation or in conjunction with asset allocation strategies. Exposure to these strategies is generally achieved through allocating client funds to Exchange Traded Funds managed by Formidable (described below). In addition to collecting a management fee for traditional portfolio management services, the Firm also collects a management fee as advisor to the Formidable ETFs. Traditional Portfolio Management Formidable Asset Management offers advisory and traditional portfolio management services through individuals associated with the Firm as investment advisor representatives (“IARs”). IARs may also be insurance licensed and offer insurance products and services. The Firm requires that a written Investment Advisory Agreement (“IA Agreement”) be signed by the client prior to the provision of services. The IA Agreement outlines the services rendered by Formidable Asset Management and the fees that the client will be charged. Clients shall open either a discretionary asset management account or a non-discretionary account with the custodian, through which Formidable Asset Management shall monitor the assets of the account, and purchase and/or sell securities within the account, according to the terms and conditions of the IA Agreement. Discretionary Portfolio Management: As a discretionary adviser, Formidable Asset Management will have the authority to supervise and direct the client’s portfolio without prior consultation with the client. By granting Formidable Asset Management full discretion and authority to manage the account, the client is authorizing the Firm to perform various functions, at the client’s expense, without further approval from the client. Such functions include the determination of securities to be purchased or sold and the amount of securities to be purchased or sold. Notwithstanding the foregoing, clients may impose certain reasonable written restrictions on Formidable Asset Management in regards to the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments. Each client should take note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Once the portfolio is constructed, Formidable Asset Management will provide continuous supervision and re-balancing of the portfolio as changes in market conditions and as client circumstances may require. Non-Discretionary Portfolio Management: Alternatively, Formidable Asset Management provides non-discretionary portfolio management services whereby the Firm will make specific investment recommendations to a client tailored to meet the needs and investment objectives of that specific client but shall not initiate any orders to purchase or sell any securities (or specific securities) without the client’s approval. This program offers clients the opportunity to maintain full investment authority and direct the individual investments made within their own accounts. As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of: 1)) Leaving the funds in your employer's (former employer's) plan; 2) moving the funds to a new employer's retirement plan; 3) cashing out and taking a taxable distribution from the plan; and/or 4) rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. Our recommendations may include any of them, depending on what we feel is in your best interest. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. As a fiduciary, we are required to document the reason(s) for why the recommendation we made is in your best interest. FINANCIAL PLANNING AND CONSULTING SERVICES Formidable Asset Management provides financial planning and consulting services for clients seeking financial advice involving the analysis of a particular investment, investment portfolio, or overall financial situation. The consulting services typically take the form of a financial plan. These consulting services may include, but are not necessarily limited to, a review of aspects of an individual’s current financial situation, with emphasis on portfolio analysis, estate planning, insurance planning, education planning and/or capital needs planning. Formidable Asset Management may also assist the client in coordinating the implementation of any recommendations made. The decision to implement any recommendation rests exclusively with the client, and the client has no obligation to implement any such recommendations through Formidable Asset Management or its affiliates. In preparing the financial plan for a client, Formidable Asset Management will gather information deemed relevant to the particular advisory services being provided through fact- finding reviews with the client and through documents provided by the client. The service includes an analysis of the client’s financial information, which may include items such as the client’s current assets, income, investments liabilities, short and long-term capital and liquidity needs, risk tolerance and short and long-term financial goals and objectives. RETIREMENT PLAN ADVISORY SERVICES Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. Formidable Asset Management will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will(i) make the decision to retain our firm;(ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, the Firm will be considered a fiduciary under ERISA. For example, the Firm will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan Fiduciaries by recommending a suite of investments as choices among which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain Formidable Asset Management to act as an investment manager within the meaning of ERISA § 3(38), the Firm will provide discretionary investment management services to the Plan. With respect to any account for which the Firm meets the definition of a fiduciary under Department of Labor rules, the Firm acknowledges that both Formidable Asset Management and its Related Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between Formidable Asset Management and Client. Fiduciary Consulting Services
• Investment Selection Services: the Firm may provide Plan Fiduciaries with recommendations of investment options consistent with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c).
• Non-Discretionary Investment Advice: the Firm may provide Plan Fiduciaries and Plan Participants general, non-discretionary investment advice regarding asset classes and investments.
• Investment Monitoring: the Firm may assist in monitoring the plan’s investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and Formidable Asset Management may make recommendations to maintain or remove and replace investment options. The details of this aspect of service will be enumerated in the engagement agreement between the parties. Fiduciary Management Services Discretionary Management Services: when retained as an investment manager within the meaning of ERISA § 3(38), the Firm may provide continuous and ongoing supervision over the designated retirement plan assets. The Firm will actively monitor the designated retirement plan assets and provide ongoing management of the assets. When applicable, Formidable Asset Management will have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with the Plan Fiduciaries. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets. Discretionary Investment Selection Services: the Firm will monitor the investment options of the Plan and add or remove investment options for the Plan without prior consultation with the Plan Fiduciaries. The Firm will have discretionary authority to make and implement all decisions regarding the investment options that are available to Plan Participants. Investment Management via Model Portfolios: Formidable Asset Management will provide discretionary management of Model Portfolios among which the participants may choose to invest as Plan options. Plan Participants will also have the option of investing only in options that do not include Model Portfolios (i.e., the Plan Participants may elect to invest in one or more of the mutual funds or exchange traded fund options made available in the Plan and choose not to invest in the Model Portfolios at all). Non-Fiduciary Services Participant Education: Formidable Asset Management will provide education services to Plan Participants about general investment principles and the investment alternatives available under the Plan. Education presentations will not take into account the individual circumstances of each Plan Participant and individual recommendations will not be provided unless a Plan Participant separately engages the Firm for such services. Plan Participants are responsible for implementing transactions in their own accounts. Participant Enrollment: Formidable Asset Management will assist with group enrollment meetings designed to increase retirement Plan participation among employees and investment and financial understanding by the employees. C. Tailored Relationships The investment advisory services offered by Formidable Asset Management are based on the individual needs of our clients and the suitability of products and services.

We make an assessment of our client’s goals, objectives, investment horizon, and risk tolerance. If clients wish to impose certain restrictions on investing in certain securities or types of securities, the Firm will address those restrictions with the clients to have a clear understanding of the client’s requirements. As the client’s financial situation, goals, objectives, or needs change, the client must notify Formidable Asset Management promptly. D. Wrap Fee Programs Wrap Fee Programs are arrangements between broker-dealers, investment advisers, banks and other financial institutions and affiliated and unaffiliated investment advisers through which the clients of such firms receive discretionary investment advisory, execution, clearing and custodial services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all-inclusive (or “wrap”) fee determined as a percentage of the assets held in the wrap account. Formidable Asset Management does not participate in and is not a sponsor of any wrap fee program(s). E. Assets under Management As of December 31, 2023, the Firm manages approximately $886,834,074in assets, of which $851,715,030 is managed on a discretionary basis, and $35,119,045 is managed on a non-discretionary basis. Formidable Exchange Trade Funds The Exchange Traded Funds are each a series of the ETF Opportunities Trust, an open-end management investment company organized as a Delaware statutory trust on March 18, 2019. The Board supervises the operations of the Funds according to applicable state and federal law, and the Board is responsible for the overall management of the Funds’ business affairs. Formidable ETF (ticker symbol: FORH)—Under normal market conditions, the Fund seeks to meet its investment objective by investing primarily in equity securities, including common stocks, preferred stocks, related depository receipts (i.e., American Depository Receipts or “ADRs,” European Depository Receipts or “EDRs,” and Global Depository Receipts or “GDRs”), and real estate investment trusts (“REITs”). The Fund invests predominantly in common stocks. The Fund’s investments are the responsibility of the Adviser and the Fund’s sub-adviser, Toroso Asset Management (the “Sub-Adviser”). Formidable working together with the Sub-Adviser, makes buy, hold and sell decisions with respect to Fund portfolio securities using an investment process that combines top-down and bottom-up research and analysis. The top-down portion of the investment process seeks to identify attractive investment themes and market inefficiencies. The bottom-up portion of the process is used to make buy and sell decisions for equity securities. Both quantitative and fundamental analysis are used by Formidable, along with valuation and technical considerations. Formidable’s internal research and analysis leverages insights from diverse sources, including external research, to develop and refine its general investment theme and identify and take advantage of trends that have ramifications for individual companies or entire industries. Formidable also evaluates market segments, products, services and business models positioned to benefit significantly from innovations in commerce relative to broad securities markets and seeks to identify the primary beneficiaries of new trends or developments in commerce to select investments for the Fund. In pursuing the Fund’s investment goal, Formidable may invest in companies in any economic sector or of any market capitalization and may invest in companies both inside and outside of the United States, including those in developing or emerging markets. The Fund is classified as “non-diversified” for purposes of the Investment Company Act of 1940, as amended (the “1940 Act”), which means it generally invests a greater portion of its assets in the securities of one or more issuers and invests overall in a smaller number of issuers than a diversified fund. Formidable may at times use derivatives for hedging purposes. The Fund’s derivative investments may include, among other instruments: (i) options; (ii) volatility linked ETFs; and (iii) volatility-linked exchange-traded notes (“ETNs”). These derivatives will be used to enhance Fund returns, produce income, and/or hedge risks associated with the Fund’s other portfolio investments. As a result of the Fund’s use of derivatives, the Fund may have economic leverage, which means the sum of the Fund’s investment exposures through its use of derivatives may significantly exceed the amount of assets invested in the Fund, although these exposures may vary over time. The Fund is an actively managed exchange-traded fund (ETF) that does not seek to replicate the performance of a specified index. Formidable Fortress ETF (ticker symbol: KONG)—Under normal market conditions, the Fund seeks to meet its investment objective by investing in large- and mid-cap equity securities, including common stocks, related depository receipts (i.e., American Depository Receipts or “ADRs,” European Depository Receipts or “EDRs,” and Global Depository Receipts or “GDRs”), real estate investment trusts (“REITs”), and other equity investments or ownership interests in business enterprises. The Fund invests predominantly in common stocks of large- and mid-cap companies (the “Investable Universe”). The Fund’s investments will be the responsibility of the Adviser and the Fund’s sub-adviser, Toroso Asset Management (the “Sub-Adviser”). As of March 1, 2021, the Fund considers large- and mid-capitalization companies to be those with a market capitalization over $10 billion. The exact size of the companies included will change with market conditions and the Fund will not automatically sell or cease to purchase a stock that it already owns due to changes in market conditions. Formidable, working together with the Sub-Adviser, makes buy, hold and sell decisions with respect to Fund portfolio securities using an investment process that is based on a combination of quantitative and fundamental analysis. The investment process seeks to identify stocks of large- and mid-cap companies which exhibit one or more of the following primary factors:
• Capital structure discipline: lower debt levels relative to the Investable Universe;
• Beta –lower historical price volatility relative to the Investable Universe;
• Dividends – history of returning capital to shareholders, ideally at an increasing level; and
• Quality–relative to the Investable Universe, companies with higher returns on equity (ROE), operating margins, and earnings growth. In pursuing the Fund’s investment goal, Formidable may invest in companies in any economic sector and may invest in companies both inside and outside of the United States, including those in developing or emerging markets. The Fund is classified as “non-diversified” for purposes of the 1940 Act, which means it generally invests a greater portion of its assets in the securities of one or more issuers and invests overall in a smaller number of issuers than a diversified fund. Notwithstanding, the Fund would generally expect to own the securities of approximately 30 companies although the Fund may at times own a much lesser number and at other times it could own a larger number. The Fund’s derivative investments may include, among other instruments: (i) options; (ii) volatility- linked ETFs; and (iii) volatility-linked exchange-traded notes (“ETNs”). These derivatives will be used to hedge risks associated with the Fund’s other portfolio investments. The Fund’s may also use derivatives to create income by writing covered call options. In writing covered call, the sell an option on a security that the Fund owns in exchange for a premium (i.e., income). The Fund will “cover” the position by either continuing to own the security on which the option was written or by otherwise segregating assets sufficient to satisfy applicable regulatory requirements pertaining to having sufficient assets to offset any liability created by the covered call that was written. As a result of the Fund’s use of derivatives, the Fund may have economic leverage, which means the sum of the Fund’s investment exposures through its use of derivatives may exceed the amount of assets invested in the Fund, although these exposures may vary over time. The Fund is an actively managed exchange-traded fund (ETF) that does not seek to replicate the performance of a specified index. Formidable Model Portfolio Service (Formidable Series)– Subscription Service The Firm provides model portfolios to other Registered Investment Advisers. This model portfolio service involves Formidable Asset Management creating, managing, and maintaining investment models and updating Subscribers as adjustments occur within the models. Initial and ongoing delivery of the Formidable Series models to subscribers occurs through direct communication with advisers or through delivery of the models to model manager platforms (“Third Party Platforms”). If Subscribers choose to follow the Formidable Series Models, they are responsible to trade client accounts to bring the portfolios in line with The Formidable Model Portfolios. Subscribers to the Models are responsible for handling all matters pertaining to their client accounts, including suitability, trading, reporting, and custody. The Formidable Series Models are not customized to any individual client of the subscriber and Formidable Asset Management has no advisory relationship with any “end- client” under this arrangement. Formidable Dividend and Income ETF (ticker symbol: FODI)- Under normal market conditions, the Fund seeks to meet its investment objective by investing at least 80% of its net assets (plus the amount of borrowings, if any, for investment purposes) in large- and mid- cap equity securities, including common stocks, related depository receipts (i.e., American Depository Receipts or “ADRs,” European Depository Receipts or “EDRs,” and Global Depository Receipts or “GDRs”), real estate investment trusts (“REITs”), and other equity investments or ownership interests in business enterprises. The Fund invests predominantly in common stocks of large- and mid-cap companies. The Fund’s investments will be the responsibility of the Adviser and the Fund’s sub-adviser, Toroso Investments, LLC (the “Sub- Adviser”). As of March 1, 2023, the Fund considers large- and mid-capitalization companies to be those with a market capitalization in excess of $10 billion. The exact size of the companies included will change with market conditions and the Fund will not automatically sell or cease to purchase a stock that it already owns due to changes in market conditions. The Adviser, working together with the Sub-Adviser, makes buy, hold and sell decisions with respect to Fund portfolio securities using an investment process that is based on a combination of fundamental analysis, valuation, and technical considerations. The Adviser’s investment process is designed to:
• Observe
• Portfolio positioning.
• Economic and market conditions.
• Investor sentiment.
• Trends.
• Orient
• How should we interact with the environment?
• Determine what is changing and at what rate.
• How does this relate to previous experiences?
• Decide
• Discuss stocks where our sell discipline leans toward a sell.
• Review potential portfolio additions.
• Evaluate relative risk/reward.
• Act
• Choose optimal approach.
• Enter/exit position. The investment process seeks to identify stocks of large- and mid-cap companies with an attractive combination of yield, growth, and valuation, although the primary emphasis is on yield.. The portfolio:
• Targets an equity yield 200 basis points greater than 10-year U.S. Treasury.
• Fundamental research process evaluates historical growth and estimates future earnings potentials.
• Target portfolio P/E ratio below S&P 500.
• The sum of these three factors (yield, growth, multiple expansion) is used to estimate total return potential. In pursuing the Fund’s investment goal, the Adviser may invest in companies in any economic sector and may invest in companies both inside and outside of the United States, including those in developing or emerging markets. The Fund is classified as “non-diversified” for purposes of the 1940 Act, which means it generally invests a greater portion of its assets in the securities of one or more issuers and invests overall in a smaller number of issuers than a diversified fund. The Adviser may at times use derivatives for hedging purposes. The Fund’s derivative investments may include, among other instruments: (i) options; (ii) volatility-linked ETFs; (iii) volatility-linked exchange-traded notes (“ETNs”); and (iv) and FLexible EXchange® Options (“FLEX Options”). These derivatives will be used to enhance Fund returns, produce income, and/or hedge risks associated with the Fund’s other portfolio investments. As a result of the Fund’s use of derivatives, the Fund may have economic leverage, which means the sum of the Fund’s investment exposures through its use of derivatives may significantly exceed the amount of assets invested in the Fund, although these exposures may vary over time. FLEX Options are customizable exchange-traded option contracts guaranteed for settlement by the Options Clearing Corporation (“OCC”). The Fund is an actively managed exchange-traded fund (ETF) that does not seek to replicate the performance of a specified index.