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Correspondence 0001398344-24-023488 from RBB FUND, INC. (CIK 0000831114)

RBB FUND, INC. (CIK 0000831114)
Date: Dec. 20, 2024 · CIK: 0000831114 · Accession: 0001398344-24-023488

AI Filing Summary & Sentiment

File numbers found in text: 811-05518

Date
December 20, 2024
Author
Not clearly detected
Form
CORRESP
Company
RBB FUND, INC. (CIK 0000831114)

Letter

VIA EDGAR TRANSMISSION Securities and Exchange Commission Re: The RBB Fund, Inc. (the “Company”) Registration Statement on Form N-1A (File Nos.: 033-20827 and 811-05518)

Dear Ms. Lithotomos:

The purpose of this letter is to respond to the oral comments you provided regarding the Company’s post-effective amendment (“PEA”) No. 334 to its registration statement on Form N-1A. PEA No. 334 was filed with the Securities and Exchange Commission (the “Commission”) pursuant to Rule 485(a)(1) under the Securities Act of 1933, as amended, on Form N-1A on November 1, 2024.

The Company will file a subsequent PEA under Rule 485(b) (“Amended Registration Statement”) to update any missing information, respond to Staff comments, and file updated exhibits.

For your convenience, each comment has been reproduced in bold typeface immediately followed by the Company’s response. Capitalized but undefined terms used herein have the meanings assigned to them in the Registration Statement. The Company confirms that, where applicable, the responses to the comments provided in one section of the Registration Statement will be similarly updated in other parallel sections of the Registration Statement, except as noted by the Company. The changes to the disclosures discussed below will be reflected in the next post-effective amendment to the Registration Statement.

1. Comment: As a global comment for all funds, please complete the Fee and Expense tables and provide them to the Commission at least five (5) business days prior to the effective date.

Response: Please see updated Fee and Expense tables below.

Motley Fool 100 Index ETF:

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fool 100 Fund (“Shares”). This table and the Example below do not include the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

Management Fees 0.50%

Distribution (12b-1) Fees 0.00%

Other Expenses 0.00%

Total Annual Fund Operating Expenses 0.50%

Example

This Example is intended to help you compare the cost of investing in the Fool 100 Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fool 100 Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment has a 5% return each year, and (2) the Fool 100 Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

1 Year 3 Years 5 Years 10 Years

$51 $160 $280 $628

Motley Fool Global Opportunities ETF:

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Global Opportunities Fund (“Shares”). This table and the Example below do not include the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

Management Fees 0.85%

Distribution (12b-1) Fees 0.00%

Other Expenses 0.00%

Total Annual Fund Operating Expenses 0.85%

Example

This Example is intended to help you compare the cost of investing in the Global Opportunities Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Global Opportunities Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment has a 5% return each year, and (2) the Global Opportunities Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

1 Year 3 Years 5 Years 10 Years

$87 $271 $471 $1,049

Motley Fool Mid-Cap Growth ETF:

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Mid-Cap Growth Fund (“Shares”). This table and the Example below do not include the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

Management Fees 0.85%

Distribution (12b-1) Fees 0.00%

Other Expenses 0.00%

Total Annual Fund Operating Expenses 0.85%

Example

This Example is intended to help you compare the cost of investing in the Mid-Cap Growth Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Mid-Cap Growth Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment has a 5% return each year, and (2) the Mid-Cap Growth Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

1 Year 3 Years 5 Years 10 Years

$87 $271 $471 $1,049

Motley Fool Small-Cap Growth ETF:

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Small-Cap Growth Fund (“Shares”). This table and the Example below do not include the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

Management Fees 0.85%

Distribution (12b-1) Fees 0.00%

Other Expenses 0.00%

Total Annual Fund Operating Expenses 0.85%

Example

This Example is intended to help you compare the cost of investing in the Small-Cap Growth Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Small-Cap Growth Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment has a 5% return each year, and (2) the Small-Cap Growth Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

1 Year 3 Years 5 Years 10 Years

$87 $271 $471 $1,049

Motley Fool Next Index ETF:

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Next Fund (“Shares”). This table and the Example below do not include the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

Management Fees 0.50%

Distribution (12b-1) Fees 0.00%

Other Expenses 0.00%

Total Annual Fund Operating Expenses 0.50%

Example

This Example is intended to help you compare the cost of investing in the Next Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Next Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment has a 5% return each year, and (2) the Next Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

1 Year 3 Years 5 Years 10 Years

$51 $160 $280 $628

Motley Fool Capital Efficiency 100 Index ETF:

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Capital Efficiency Fund (“Shares”). This table and the Example below do not include the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

Management Fees 0.50%

Distribution (12b-1) Fees 0.00%

Other Expenses 0.00%

Total Annual Fund Operating Expenses 0.50%

Example

This Example is intended to help you compare the cost of investing in the Capital Efficiency Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Capital Efficiency Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment has a 5% return each year, and (2) the Capital Efficiency Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

1 Year 3 Years 5 Years 10 Years

$51 $160 $280 $628

SGI Enhanced Global Income ETF:

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund (“Shares”). This table and the Example below do not include the brokerage commissions that investors may pay on their purchases and sales of Shares.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

Management Fees 0.98%

Distribution (12b-1) Fees 0.00%

Other Expenses 0.00%

Acquired Fund Fees and Expenses(1) 0.01%

Total Annual Fund Operating Expenses 0.99%

(1) Acquired Fund Fees and Expenses are indirect fees and expenses that the Fund incurs from investing in the shares of other mutual funds, including money market funds and exchange traded funds. Please note that the amount of Total Annual Fund Operating Expenses shown in the above table will differ from the “Financial Highlights” section of the Prospectus, which reflects the operating expenses of the Fund and does not include indirect expenses such as Acquired Fund Fees and Expenses.

Example

This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment has a 5% return each year, and (2) the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

1 Year 3 Years

$101 $315

SGI Enhanced Core ETF:

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund (“Shares”). This table and the Example below do not include the brokerage commissions that investors may pay on their purchases and sales of Shares.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

Management Fees 0.98%

Distribution (12b-1) Fees 0.00%

Other Expenses 0.00%

Acquired Fund Fees and Expenses(1) 0.07%

Total Annual Fund Operating Expenses 1.05%

(1) Acquired Fund Fees and Expenses are indirect fees and expenses that the Fund incurs from investing in the shares of other mutual funds, including money market funds and exchange traded funds. Please note that the amount of Total Annual Fund Operating Expenses shown in the above table will differ from the “Financial Highlights” section of the Prospectus, which reflects the operating expenses of the Fund and does not include indirect expenses such as Acquired Fund Fees and Expenses.

Example

This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment has a 5% return each year, and (2) the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

1 Year 3 Years

$107 $334

SGI Enhanced Nasdaq-100 ETF:

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund (“Shares”). This table and the Example below do not include the brokerage commissions that investors may pay on their purchases and sales of Shares.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

Management Fees 0.98%

Distribution (12b-1) Fees 0.00%

Other Expenses 0.00%

Total Annual Fund Operating Expenses 0.98%

Example

This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment has a 5% return each year, and (2) the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

1 Year 3 Years

$100 $312

Campbell Systematic Macro Fund:

Expenses and Fees

This table describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund (the "Shares"). You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below. You may qualify for sales charge discounts if you invest at least $25,000 in Class A Shares of the Fund. More information about these discounts is available from your financial professional, in the section of this Prospectus entitled “Shareholder Information – Sales Charges” and in the section of the Fund’s Statement of Additional Information (“SAI”) entitled “Purchase and Redemption Information – Reducing or Eliminating the Front End Sales Charge.” Financial Intermediaries may impose different sales charge waivers for Class A Shares, and these variations are described in the section of this Prospectus entitled “Shareholder – Information – Sales Charges”.

SHAREHOLDER FEES (fees paid directly from your investment) Class A Class I Class C

Maximum Sales Charge (Load) Imposed on Purchases

(as a percentage of offering price)

3.50% None None

Maximum Deferred Sales Charge (Load) (as a percentage of original purchase price)(1) 1.00% None 1.00%

ANNUAL FUND OPERATING EXPENSES (expenses that you pay each year as a percentage of the value of your investment)

Management Fees 1.64 % 1.64 % 1.64 %

Distribution and/or Service (12b-1) Fees(2) 0.25 % None 1.00 %

Other Expenses 0.20 % 0.20 % 0.20 %

Total Annual Fund Operating Expenses 2.09 % 1.84 % 2.84 %

Fee Waivers and/or Expense Reimbursements(3) -0.09 % -0.09 % -0.09 %

Total Annual Fund Operating Expenses After Fee Waiver 2.00 % 1.75 % 2.75 %

(1) A contingent deferred sales charge (“CDSC”) of 1.00% is assessed on certain redemptions of Class A Shares made within twelve months after a purchase of Class A Shares where no initial sales charge was paid at the time of p

Show Raw Text
CORRESP
1
filename1.htm

Faegre Drinker Biddle & Reath LLP

320 South Canal Street, Suite 3300

Chicago, IL 60606

(312) 569-1000 (Phone)

(312) 569-3000 (Facsimile)

www.faegredrinker.com

December 20, 2024

VIA EDGAR TRANSMISSION

Ms. Valerie Lithotomos

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    The RBB Fund, Inc. (the “Company”)

    Registration Statement on Form N-1A

    (File Nos.: 033-20827 and 811-05518)

Dear Ms. Lithotomos:

The purpose of this letter is
to respond to the oral comments you provided regarding the Company’s post-effective amendment (“PEA”) No. 334 to its
registration statement on Form N-1A. PEA No. 334 was filed with the Securities and Exchange Commission (the “Commission”)
pursuant to Rule 485(a)(1) under the Securities Act of 1933, as amended, on Form N-1A on November 1, 2024.

The Company will file a subsequent
PEA under Rule 485(b) (“Amended Registration Statement”) to update any missing information, respond to Staff comments, and
file updated exhibits.

For your convenience, each comment
has been reproduced in bold typeface immediately followed by the Company’s response. Capitalized but undefined terms used herein
have the meanings assigned to them in the Registration Statement. The Company confirms that, where applicable, the responses to the comments
provided in one section of the Registration Statement will be similarly updated in other parallel sections of the Registration Statement,
except as noted by the Company. The changes to the disclosures discussed below will be reflected in the next post-effective amendment
to the Registration Statement.

    1.
    Comment: As a global comment for all funds, please complete the Fee and Expense tables and provide them to the Commission at least five (5) business days prior to the effective date.

Response: Please see updated Fee
and Expense tables below.

Motley Fool 100 Index ETF:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Fool 100 Fund (“Shares”). This table and the Example below do not include
the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

  Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

  Management Fees
  	0.50%

  Distribution (12b-1) Fees
  	0.00%

  Other Expenses
  	0.00%

  Total Annual Fund Operating Expenses
  0.50%

Example

This Example is intended to help you compare the cost
of investing in the Fool 100 Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fool 100
Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that:
(1) your investment has a 5% return each year, and (2) the Fool 100 Fund’s operating expenses remain the same. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years
    5 Years
    10 Years

    $51
    $160
    $280
    $628

Motley Fool Global Opportunities ETF:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Global Opportunities Fund (“Shares”). This table and the Example below
do not include the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

  Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

  Management Fees
  0.85%

  Distribution (12b-1) Fees
  	0.00%

  Other Expenses
  	0.00%

  Total Annual Fund Operating Expenses
  0.85%

Example

This Example is intended to help you compare the cost
of investing in the Global Opportunities Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in
the Global Opportunities Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The
Example also assumes that: (1) your investment has a 5% return each year, and (2) the Global Opportunities Fund’s operating expenses
remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years
    5 Years
    10 Years

    $87
    $271
    $471
    $1,049

Motley Fool Mid-Cap Growth ETF:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Mid-Cap Growth Fund (“Shares”). This table and the Example below do not
include the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

  Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

  Management Fees
  0.85%

  Distribution (12b-1) Fees
  	0.00%

  Other Expenses
  	0.00%

  Total Annual Fund Operating Expenses
  0.85%

Example

This Example is intended to help you compare the cost
of investing in the Mid-Cap Growth Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the
Mid-Cap Growth Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example
also assumes that: (1) your investment has a 5% return each year, and (2) the Mid-Cap Growth Fund’s operating expenses remain the
same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years
    5 Years
    10 Years

    $87
    $271
    $471
    $1,049

Motley Fool Small-Cap Growth ETF:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Small-Cap Growth Fund (“Shares”). This table and the Example below do
not include the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

  Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

  Management Fees
  0.85%

  Distribution (12b-1) Fees
  	0.00%

  Other Expenses
  	0.00%

  Total Annual Fund Operating Expenses
  0.85%

Example

This Example is intended to help you compare the cost
of investing in the Small-Cap Growth Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the
Small-Cap Growth Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example
also assumes that: (1) your investment has a 5% return each year, and (2) the Small-Cap Growth Fund’s operating expenses remain
the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years
    5 Years
    10 Years

    $87
    $271
    $471
    $1,049

Motley Fool Next Index ETF:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Next Fund (“Shares”). This table and the Example below do not include
the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

  Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

  Management Fees
  	0.50%

  Distribution (12b-1) Fees
  	0.00%

  Other Expenses
  	0.00%

  Total Annual Fund Operating Expenses
  	0.50%

Example

This Example is intended to help you compare the cost
of investing in the Next Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Next Fund
for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that:
(1) your investment has a 5% return each year, and (2) the Next Fund’s operating expenses remain the same. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years
    5 Years
    10 Years

    $51
    $160
    $280
    $628

Motley Fool Capital Efficiency 100 Index ETF:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Capital Efficiency Fund (“Shares”). This table and the Example below do
not include the brokerage commissions that investors may pay on their purchases and sales of Fund Shares.

  Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

  Management Fees
  	0.50%

  Distribution (12b-1) Fees
  	0.00%

  Other Expenses
  	0.00%

  Total Annual Fund Operating Expenses
  	0.50%

Example

This Example is intended to help you compare the cost
of investing in the Capital Efficiency Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in
the Capital Efficiency Fund for the time periods indicated and then hold or redeem all of your Shares at the end of those periods. The
Example also assumes that: (1) your investment has a 5% return each year, and (2) the Capital Efficiency Fund’s operating expenses
remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

    1 Year
    3 Years
    5 Years
    10 Years

    $51
    $160
    $280
    $628

SGI Enhanced Global Income ETF:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Fund (“Shares”). This table and the Example below do not include the brokerage
commissions that investors may pay on their purchases and sales of Shares.

    Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

    Management Fees
    0.98%

    Distribution (12b-1) Fees
    0.00%

    Other Expenses
    0.00%

    Acquired Fund Fees and Expenses(1)
    0.01%

    Total Annual Fund Operating Expenses
    0.99%

(1) Acquired Fund Fees and Expenses are indirect fees and expenses that the Fund incurs from investing in
the shares of other mutual funds, including money market funds and exchange traded funds. Please note that the amount of Total Annual
Fund Operating Expenses shown in the above table will differ from the “Financial Highlights” section of the Prospectus, which
reflects the operating expenses of the Fund and does not include indirect expenses such as Acquired Fund Fees and Expenses.

Example

This Example is intended to help you compare the cost
of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the time
periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment
has a 5% return each year, and (2) the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower,
based on these assumptions your costs would be:

    1 Year
    3 Years

    $101
    $315

SGI Enhanced Core ETF:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Fund (“Shares”). This table and the Example below do not include the brokerage
commissions that investors may pay on their purchases and sales of Shares.

    Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

    Management Fees
    0.98%

    Distribution (12b-1) Fees
    0.00%

    Other Expenses
    0.00%

    Acquired Fund Fees and Expenses(1)
    0.07%

    Total Annual Fund Operating Expenses
    1.05%

(1) Acquired Fund Fees and Expenses are indirect fees and expenses that the Fund incurs from investing in
the shares of other mutual funds, including money market funds and exchange traded funds. Please note that the amount of Total Annual
Fund Operating Expenses shown in the above table will differ from the “Financial Highlights” section of the Prospectus, which
reflects the operating expenses of the Fund and does not include indirect expenses such as Acquired Fund Fees and Expenses.

Example

This Example is intended to help you compare the cost
of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the time
periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment
has a 5% return each year, and (2) the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower,
based on these assumptions your costs would be:

    1 Year
    3 Years

    $107
    $334

SGI Enhanced Nasdaq-100 ETF:

Fees and Expenses

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Fund (“Shares”). This table and the Example below do not include the brokerage
commissions that investors may pay on their purchases and sales of Shares.

    Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment):

    Management Fees
    0.98%

    Distribution (12b-1) Fees
    0.00%

    Other Expenses
    0.00%

    Total Annual Fund Operating Expenses
    0.98%

Example

This Example is intended to help you compare the cost
of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the time
periods indicated and then hold or redeem all of your Shares at the end of those periods. The Example also assumes that: (1) your investment
has a 5% return each year, and (2) the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower,
based on these assumptions your costs would be:

    1 Year
    3 Years

    $100
    $312

Campbell Systematic Macro Fund:

Expenses and Fees

This table describes the fees and expenses that you
may pay if you buy, hold and sell shares of the Fund (the "Shares"). You may pay other fees, such as brokerage commissions and
other fees to financial intermediaries, which are not reflected in the tables and examples below. You may qualify for sales charge discounts
if you invest at least $25,000 in Class A Shares of the Fund. More information about these discounts is available from your financial
professional, in the section of this Prospectus entitled “Shareholder Information – Sales Charges” and in the section
of the Fund’s Statement of Additional Information (“SAI”) entitled “Purchase and Redemption Information –
Reducing or Eliminating the Front End Sales Charge.” Financial Intermediaries may impose different sales charge waivers for Class
A Shares, and these variations are described in the section of this Prospectus entitled “Shareholder – Information –
Sales Charges”.

    SHAREHOLDER FEES (fees paid directly from your investment)
    Class A
    Class I
    Class C

    Maximum Sales Charge (Load) Imposed on Purchases

    (as a percentage of offering price)

    3.50%
    None
    None

    Maximum Deferred Sales Charge (Load) (as a percentage of original purchase price)(1)
    1.00%
    None
    1.00%

    ANNUAL FUND OPERATING EXPENSES (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
    	1.64	%
    	1.64	%
    	1.64	%

    Distribution and/or Service (12b-1) Fees(2)
    	0.25	%
    None
    	1.00	%

    Other Expenses
    	0.20	%
    	0.20	%
    	0.20	%

    Total Annual Fund Operating Expenses
    	2.09	%
    	1.84	%
    	2.84	%

    Fee Waivers and/or Expense Reimbursements(3)
    	-0.09	%
    	-0.09	%
    	-0.09	%

    Total Annual Fund Operating Expenses After Fee Waiver
    	2.00	%
    	1.75	%
    	2.75	%

 (1) A contingent deferred sales charge (“CDSC”) of 1.00%
is assessed on certain redemptions of Class A Shares made within twelve months after a purchase of Class A Shares where no initial sales
charge was paid at the time of p