Correspondence 0001580642-23-004873 from Northern Lights Fund Trust IV (CIK 0001644419)
Northern Lights Fund Trust IV (CIK 0001644419)
Date: Sept. 12, 2023 · CIK: 0001644419 · Accession: 0001580642-23-004873
AI Filing Summary & Sentiment
File numbers found in text: 333-204808, 811-23066
Letter
VIA EDGAR TRANSMISSION Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549-0506 Re: Northern Lights Fund Trust IV, File Nos. 333-204808 and 811-23066 (“Registrant”)
Dear Ms. Hahn:
On June 23, 2023, the Registrant, on behalf of its proposed series, Brookstone Dividend Stock ETF, Brookstone Growth Stock ETF, Brookstone Value Stock ETF, Brookstone Intermediate Bond ETF, Brookstone Ultra-Short Bond ETF, Brookstone Active ETF, Brookstone Opportunities ETF and Brookstone Yield ETF (each a “Fund” and collectively, the “Funds”), filed an amendment to its registration statement under the Securities Act of 1933 on Form N-1A. In a telephone conversation on August 25, 2023, you provided comments to the amendment. Below, please find those comments and the Registrant’s responses, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Please note that added language is in italics and deleted language appears struck through.
All Funds
Prospectus
Comment 1: Please supplementally provide a completed fee table and expense example for each Fund. Additionally, please confirm, supplementally, that each fee table excludes fees charged for the purchase and redemption of creation units.
Response: The Registrant has amended its disclosures to include the following fee tables and expense examples:
Brookstone Dividend Stock ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Management Fees 0.65%
Distribution and Service (12b-1) Fees 0.00%
Other Expenses(1) 0.67%
Total Annual Fund Operating Expenses 1.32%
Zeynep.Kart@ThompsonHine.com Direct: 614.469.3215
Jaea Hahn
September 12, 2023
Page 2
Fee Waiver and/or Expense Reimbursement(2) (0.37)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement 0.95%
(1) Estimated for the current fiscal year.
(2) The Fund’s adviser has contractually agreed to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to ensure that total annual fund operating expenses after fee waiver and/or reimbursement (exclusive of any front-end or contingent deferred loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend expense on securities sold short), acquired fund fees and expenses, fees and expenses associated with investments in other collective investment vehicles or derivative instruments (including for example option and swap fees and expenses), or extraordinary expenses such as litigation) will not exceed 0.95% of the Fund’s net assets. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years (within the three years from the date the fees have been waived or reimbursed) if such recoupment can be achieved within the lesser of the foregoing expense limits or those in place at the time of recapture after the recoupment has been taken into account. This agreement may be terminated by the Trust’s Board of Trustees only on 60 days’ written notice to the Fund’s adviser.
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 redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year 3 Years
$97 $382
Brookstone Growth Stock ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Management Fees 0.65%
Distribution and Service (12b-1) Fees 0.00%
Other Expenses(1) 0.67%
Total Annual Fund Operating Expenses 1.32%
Fee Waiver and/or Expense Reimbursement(2) (0.37)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement 0.95%
(1) Estimated for the current fiscal year.
(2) The Fund’s adviser has contractually agreed to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to ensure that total annual fund operating expenses after fee waiver and/or reimbursement (exclusive of any front-end or contingent deferred loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend expense on securities sold short), acquired fund fees and expenses, fees and expenses associated with investments in other collective investment vehicles or derivative instruments (including for example option and swap fees and expenses), or extraordinary expenses such as litigation) will not exceed 0.95% of the Fund’s net assets. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years (within the three years from the date the fees have been waived or reimbursed) if such recoupment can be achieved within the lesser of the foregoing expense limits or those in place at the time of recapture after the recoupment has been taken into account. This agreement may be terminated by the Trust’s Board of Trustees only on 60 days’ written notice to the Fund’s adviser.
Jaea Hahn
September 12, 2023
Page 3
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 redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year 3 Years
$97 $382
Brookstone Value Stock ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Management Fees 0.65%
Distribution and Service (12b-1) Fees 0.00%
Other Expenses(1) 0.67%
Total Annual Fund Operating Expenses 1.32%
Fee Waiver and/or Expense Reimbursement(3) (0.37)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement 0.95%
(1) Estimated for the current fiscal year.
(2) The Fund’s adviser has contractually agreed to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to ensure that total annual fund operating expenses after fee waiver and/or reimbursement (exclusive of any front-end or contingent deferred loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend expense on securities sold short), acquired fund fees and expenses, fees and expenses associated with investments in other collective investment vehicles or derivative instruments (including for example option and swap fees and expenses), or extraordinary expenses such as litigation) will not exceed 0.95% of the Fund’s net assets. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years (within the three years from the date the fees have been waived or reimbursed) if such recoupment can be achieved within the lesser of the foregoing expense limits or those in place at the time of recapture after the recoupment is taken into account. This agreement may be terminated by the Trust’s Board of Trustees only on 60 days’ written notice to the Fund’s adviser.
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 redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year 3 Years
$97 $382
Jaea Hahn
September 12, 2023
Page 4
Brookstone Intermediate Bond ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Management Fees 0.65%
Distribution and Service (12b-1) Fees 0.00%
Other Expenses(1) 0.73%
Acquired Fund Fees and Expenses(2) 0.14%
Total Annual Fund Operating Expenses 1.52%
Fee Waiver and/or Expense Reimbursement(2) (0.43)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement 1.09%
(1) Estimated for the current fiscal year.
(2) Acquired Fund Fees and Expenses are the indirect costs of investing in other investment companies. The operating expenses in this fee table will not correlate to the expense ratio in the Fund’s financial highlights because the financial statements include only the direct operating expenses incurred by the Fund. The Acquired Fund Fees and Expenses are based on estimated amounts for the current fiscal year.
(3) The Fund’s adviser has contractually agreed to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to ensure that total annual fund operating expenses after fee waiver and/or reimbursement (exclusive of any front-end or contingent deferred loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend expense on securities sold short), acquired fund fees and expenses, fees and expenses associated with investments in other collective investment vehicles or derivative instruments (including for example option and swap fees and expenses), or extraordinary expenses such as litigation) will not exceed 0.95% of the Fund’s net assets. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years (within the three years from the date the fees have been waived or reimbursed) if such recoupment can be achieved within the lesser of the foregoing expense limits or those in place at the time of recapture after the recoupment is taken into account. This agreement may be terminated by the Trust’s Board of Trustees only on 60 days’ written notice to the Fund’s adviser.
Example: This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year 3 Years
$111 $438
Brookstone Ultra Short Bond ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Management Fees 0.65%
Distribution and Service (12b-1) Fees 0.00%
Other Expenses(1) 0.73%
Acquired Fund Fees and Expenses(2) 0.14%
Jaea Hahn
September 12, 2023
Page 5
Total Annual Fund Operating Expenses 1.52%
Fee Waiver and/or Expense Reimbursement(2) (0.43)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement 1.09%
(1) Estimated for the current fiscal year.
(2) Acquired Fund Fees and Expenses are the indirect costs of investing in other investment companies. The operating expenses in this fee table will not correlate to the expense ratio in the Fund’s financial highlights because the financial statements include only the direct operating expenses incurred by the Fund. The Acquired Fund Fees and Expenses are based on estimated amounts for the current fiscal year.
(3) The Fund’s adviser has contractually agreed to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to ensure that total annual fund operating expenses after fee waiver and/or reimbursement (exclusive of any front-end or contingent deferred loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend expense on securities sold short), acquired fund fees and expenses, fees and expenses associated with investments in other collective investment vehicles or derivative instruments (including for example option and swap fees and expenses), or extraordinary expenses such as litigation) will not exceed 0.95% of the Fund’s net assets. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years (within the three years from the date the fees have been waived or reimbursed) if such recoupment can be achieved within the lesser of the foregoing expense limits or those in place at the time of recapture after the recoupment is taken into account. This agreement may be terminated by the Trust’s Board of Trustees only on 60 days’ written notice to the Fund’s adviser.
Example: This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year 3 Years
$111 $438
Brookstone Active ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Management Fees 0.65%
Distribution and Service (12b-1) Fees 0.00%
Other Expenses(1) 0.67%
Acquired Fund Fees and Expenses(2) 0.20%
Total Annual Fund Operating Expenses 1.52%
Fee Waiver and/or Expense Reimbursement(2) (0.37)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement 1.15%
(1) Estimated for the current fiscal year.
(2) Acquired Fund Fees and Expenses are the indirect costs of investing in other investment companies. The operating expenses in this fee table will not correlate to the expense ratio in the Fund’s financial highlights because the financial statements include only the direct operating expenses incurred by the Fund. The Acquired Fund Fees and Expenses are based on estimated amounts for the current fiscal year.
(3) The Fund’s adviser has contractually agreed to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to ensure that total annual fund operating expenses after fee waiver and/or reimbursement
Jaea Hahn
September 12, 2023
Page 6
(exclusive of any front-end or contingent deferred loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend expense on securities sold short), acquired fund fees and expenses, fees and expenses associated with investments in other collective investment vehicles or derivative instruments (including for example option and swap fees and expenses), or extraordinary expenses such as litigation) will not exceed 0.95% of the Fund’s net assets. These fee waivers and expense reimbursements are subject to po
Show Raw Text
CORRESP
1
filename1.htm
September 12, 2023
VIA EDGAR TRANSMISSION
Jaea Hahn
Senior Counsel
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549-0506
Re: Northern Lights Fund Trust IV, File Nos. 333-204808 and 811-23066 (“Registrant”)
Dear Ms. Hahn:
On June 23, 2023, the Registrant, on behalf of its
proposed series, Brookstone Dividend Stock ETF, Brookstone Growth Stock ETF, Brookstone Value Stock ETF, Brookstone Intermediate Bond
ETF, Brookstone Ultra-Short Bond ETF, Brookstone Active ETF, Brookstone Opportunities ETF and Brookstone Yield ETF (each a “Fund”
and collectively, the “Funds”), filed an amendment to its registration statement under the Securities Act of 1933 on Form
N-1A. In a telephone conversation on August 25, 2023, you provided comments to the amendment. Below, please find those comments and the
Registrant’s responses, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Please note that added language
is in italics and deleted language appears struck through.
All Funds
Prospectus
Comment 1: Please supplementally provide a
completed fee table and expense example for each Fund. Additionally, please confirm, supplementally, that each fee table excludes fees
charged for the purchase and redemption of creation units.
Response: The Registrant has amended its disclosures
to include the following fee tables and expense examples:
Brookstone Dividend Stock ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your
investment)
Management Fees
0.65%
Distribution and Service (12b-1) Fees
0.00%
Other Expenses(1)
0.67%
Total Annual Fund Operating Expenses
1.32%
Zeynep.Kart@ThompsonHine.com
Direct: 614.469.3215
Jaea Hahn
September 12, 2023
Page 2
Fee Waiver and/or Expense Reimbursement(2)
(0.37)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement
0.95%
(1) Estimated for the current fiscal year.
(2) The Fund’s adviser has contractually agreed
to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to
ensure that total annual fund operating expenses after fee waiver and/or reimbursement (exclusive of any front-end or contingent deferred
loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend expense on securities sold short), acquired
fund fees and expenses, fees and expenses associated with investments in other collective investment vehicles or derivative instruments
(including for example option and swap fees and expenses), or extraordinary expenses such as litigation) will not exceed 0.95% of the
Fund’s net assets. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years
(within the three years from the date the fees have been waived or reimbursed) if such recoupment can be achieved within the lesser of
the foregoing expense limits or those in place at the time of recapture after the recoupment has been taken into account. This
agreement may be terminated by the Trust’s Board of Trustees only on 60 days’ written notice to the Fund’s adviser.
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 redeem all of your shares at the end of those
periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the
same. Although your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year
3 Years
$97
$382
Brookstone Growth Stock ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your
investment)
Management Fees
0.65%
Distribution and Service (12b-1) Fees
0.00%
Other Expenses(1)
0.67%
Total Annual Fund Operating Expenses
1.32%
Fee Waiver and/or Expense Reimbursement(2)
(0.37)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement
0.95%
(1) Estimated for the current fiscal year.
(2) The Fund’s adviser has contractually agreed
to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to
ensure that total annual fund operating expenses after fee waiver and/or reimbursement (exclusive of any front-end or contingent deferred
loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend expense on securities sold short), acquired
fund fees and expenses, fees and expenses associated with investments in other collective investment vehicles or derivative instruments
(including for example option and swap fees and expenses), or extraordinary expenses such as litigation) will not exceed 0.95% of the
Fund’s net assets. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years
(within the three years from the date the fees have been waived or reimbursed) if such recoupment can be achieved within the lesser of
the foregoing expense limits or those in place at the time of recapture after the recoupment has been taken into account. This
agreement may be terminated by the Trust’s Board of Trustees only on 60 days’ written notice to the Fund’s adviser.
Jaea Hahn
September 12, 2023
Page 3
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 redeem all of your shares at the end of those
periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the
same. Although your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year
3 Years
$97
$382
Brookstone Value Stock ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your
investment)
Management Fees
0.65%
Distribution and Service (12b-1) Fees
0.00%
Other Expenses(1)
0.67%
Total Annual Fund Operating Expenses
1.32%
Fee Waiver and/or Expense Reimbursement(3)
(0.37)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement
0.95%
(1) Estimated for the current fiscal year.
(2) The Fund’s adviser has contractually agreed
to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to
ensure that total annual fund operating expenses after fee waiver and/or reimbursement (exclusive of any front-end or contingent deferred
loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend expense on securities sold short), acquired
fund fees and expenses, fees and expenses associated with investments in other collective investment vehicles or derivative instruments
(including for example option and swap fees and expenses), or extraordinary expenses such as litigation) will not exceed 0.95% of the
Fund’s net assets. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years
(within the three years from the date the fees have been waived or reimbursed) if such recoupment can be achieved within the lesser of
the foregoing expense limits or those in place at the time of recapture after the recoupment is taken into account. This agreement
may be terminated by the Trust’s Board of Trustees only on 60 days’ written notice to the Fund’s adviser.
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 redeem all of your shares at the end of those
periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the
same. Although your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year
3 Years
$97
$382
Jaea Hahn
September 12, 2023
Page 4
Brookstone Intermediate Bond ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your
investment)
Management Fees
0.65%
Distribution and Service (12b-1) Fees
0.00%
Other Expenses(1)
0.73%
Acquired Fund Fees and Expenses(2)
0.14%
Total Annual Fund Operating Expenses
1.52%
Fee Waiver and/or Expense Reimbursement(2)
(0.43)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement
1.09%
(1) Estimated for the current fiscal year.
(2) Acquired Fund Fees and Expenses
are the indirect costs of investing in other investment companies. The operating expenses in this fee table will not correlate to the
expense ratio in the Fund’s financial highlights because the financial statements include only the direct operating expenses incurred
by the Fund. The Acquired Fund Fees and Expenses are based on estimated amounts for the current fiscal year.
(3) The Fund’s adviser has contractually agreed
to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to
ensure that total annual fund operating expenses after fee waiver and/or reimbursement (exclusive of any front-end or contingent deferred
loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend expense on securities sold short), acquired
fund fees and expenses, fees and expenses associated with investments in other collective investment vehicles or derivative instruments
(including for example option and swap fees and expenses), or extraordinary expenses such as litigation) will not exceed 0.95% of the
Fund’s net assets. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years
(within the three years from the date the fees have been waived or reimbursed) if such recoupment can be achieved within the lesser of
the foregoing expense limits or those in place at the time of recapture after the recoupment is taken into account. This agreement
may be terminated by the Trust’s Board of Trustees only on 60 days’ written notice to the Fund’s adviser.
Example: This Example
is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes
that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The
Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although
your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year
3 Years
$111
$438
Brookstone Ultra Short Bond ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your
investment)
Management Fees
0.65%
Distribution and Service (12b-1) Fees
0.00%
Other Expenses(1)
0.73%
Acquired Fund Fees and Expenses(2)
0.14%
Jaea Hahn
September 12, 2023
Page 5
Total Annual Fund Operating Expenses
1.52%
Fee Waiver and/or Expense Reimbursement(2)
(0.43)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement
1.09%
(1) Estimated for the current fiscal year.
(2) Acquired Fund Fees and Expenses
are the indirect costs of investing in other investment companies. The operating expenses in this fee table will not correlate to the
expense ratio in the Fund’s financial highlights because the financial statements include only the direct operating expenses incurred
by the Fund. The Acquired Fund Fees and Expenses are based on estimated amounts for the current fiscal year.
(3) The Fund’s adviser has contractually agreed
to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to
ensure that total annual fund operating expenses after fee waiver and/or reimbursement (exclusive of any front-end or contingent deferred
loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend expense on securities sold short), acquired
fund fees and expenses, fees and expenses associated with investments in other collective investment vehicles or derivative instruments
(including for example option and swap fees and expenses), or extraordinary expenses such as litigation) will not exceed 0.95% of the
Fund’s net assets. These fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years
(within the three years from the date the fees have been waived or reimbursed) if such recoupment can be achieved within the lesser of
the foregoing expense limits or those in place at the time of recapture after the recoupment is taken into account. This agreement
may be terminated by the Trust’s Board of Trustees only on 60 days’ written notice to the Fund’s adviser.
Example: This Example
is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes
that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The
Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although
your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year
3 Years
$111
$438
Brookstone Active ETF
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your
investment)
Management Fees
0.65%
Distribution and Service (12b-1) Fees
0.00%
Other Expenses(1)
0.67%
Acquired Fund Fees and Expenses(2)
0.20%
Total Annual Fund Operating Expenses
1.52%
Fee Waiver and/or Expense Reimbursement(2)
(0.37)%
Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement
1.15%
(1) Estimated for the current fiscal year.
(2) Acquired Fund Fees and Expenses
are the indirect costs of investing in other investment companies. The operating expenses in this fee table will not correlate to the
expense ratio in the Fund’s financial highlights because the financial statements include only the direct operating expenses incurred
by the Fund. The Acquired Fund Fees and Expenses are based on estimated amounts for the current fiscal year.
(3) The Fund’s adviser has contractually agreed
to reduce its fees and/or absorb expenses of the Fund, for at least one year from the commencement of the Fund’s operations, to
ensure that total annual fund operating expenses after fee waiver and/or reimbursement
Jaea Hahn
September 12, 2023
Page 6
(exclusive
of any front-end or contingent deferred loads, taxes, brokerage fees and commissions, borrowing costs (such as interest and dividend
expense on securities sold short), acquired fund fees and expenses, fees and expenses associated with investments in other collective
investment vehicles or derivative instruments (including for example option and swap fees and expenses), or extraordinary expenses such
as litigation) will not exceed 0.95% of the Fund’s net assets. These fee waivers and expense reimbursements are subject to po