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HECO Strategy Shares EcoLogical Strategy ETF

36.6101
0.00 (0.00%)
Pre Market
Last Updated: 01:00:00
Delayed by 15 minutes
Name Symbol Market Type
Strategy Shares EcoLogical Strategy ETF AMEX:HECO AMEX Exchange Traded Fund
  Price Change % Change Price High Price Low Price Open Price Traded Last Trade
  0.00 0.00% 36.6101 0 01:00:00

Amendment to Annual Report for Registered Investment Companies (n-cen/a)

18/03/2020 2:07pm

Edgar (US Regulatory)


schemaVersion: X0201

The Securities and Exchange Commission has not necessarily reviewed the information in this filing and has not determined if it is accurate and complete.
The reader should not assume that the information is accurate and complete.

Form N-CEN/A Filer Information UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM N-CEN
ANNUAL REPORT FOR REGISTERED INVESTMENT COMPANIES
OMB APPROVAL


Form N-CEN/A

OMB Number: 3235-0729


Estimated average burden hours per response: 19.04

schemaVersion:

N-CEN/A:Series/Class (Contract) Information

Series ID Record:1
Series ID
S000031175
Series ID Record:2
Series ID
S000059719
Series ID Record:3
Series ID
S000031176

N-CEN/A:Part A: General Information

Item A.1. Reporting period covered.

a. Report for period ending:
2019-04-30
b. Does this report cover a period of less than 12 months?  Yes X No

N-CEN/A:Part B: Information About the Registrant


Item B.1. Background information.

a. Full name of Registrant
Strategy Shares
b. Investment Company Act file number ( e.g., 811-)
811-22497
c. CIK
0001506213
d. LEI
00000000000000000000

Item B.2. Address and telephone number of Registrant.

a. Street 1
36 North New York Avenue
Street 2
b. City
Huntington
c. State, if applicable
NEW YORK
d. Foreign country, if applicable
UNITED STATES OF AMERICA
e. Zip code and zip code extension, or foreign postal code
11743
f. Telephone number (including country code if foreign)
855-477-3837
g. Public Website, if any
http://strategysharesetfs.com/

Item B.3. Location of books and records.

Instruction. Provide the requested information for each person maintaining physical possession of each account, book, or other document required to be maintained by section 31(a) of the Act (15 U.S.C. 80a-30(a)) and the rules under that section.
Location books Record: 1
a. Name of person (e.g., a custodian of records)
Citibank, N.A.
b. Street 1
388 GREENWICH STREET
Street 2
c. City
New York
d. State, if applicable
NEW YORK
e. Foreign country, if applicable
UNITED STATES OF AMERICA
f. Zip code and zip code extension, or foreign postal code
10013
g. Telephone number (including country code if foreign)
8136041770
h. Briefly describe the books and records kept at this location:
CUSTODIAN

Item B.4. Initial of final filings.

Instruction. Respond "yes" to Item B.4.b only if the Registrant has filed an application to deregister or will file an application to deregister before its next required filing on this form.
a. Is this the first filing on this form by the Registrant? X Yes   No
b. Is this the last filing on this form by the Registrant?   Yes X No

Item B.5. Family of investment companies.

Instruction. "Family of investment companies" means, except for insurance company separate accounts, any two or more registered investment companies that (i) share the same investment adviser or principal underwriter; and (ii) hold themselves out to investors as related companies for purposes of investment and investor services.In responding to this item, all Registrants in the family of investment companies should report the name of the family of investment companies identically.
Insurance company separate accounts that may not hold themselves out to investors as related companies (products) for purposes of investment and investor services should consider themselves part of the same family if the operational or accounting or control systems under which these entities function are substantially similar.
a. Is the Registrant part of a family of investment companies? X Yes   No
i. Full name of family of investment companies
FundComplx

Item B.6. Organization.

Instruction. For Item B.6.a.i., the Registrant should include all Series that have been established by the Registrant and have shares outstanding (other than shares issued in connection with an initial investment to satisfy section 14(a) of the Act).
Indicate the classification of the Registrant by checking the applicable item below.
X a. Open-end management investment company registered under the Act on Form N-1A
  b. Closed-end management investment company registered under the Act on Form N-2
  c. Separate account offering variable annuity contracts which is registered under the Act as a management investment company on Form N-3
  d. Separate account offering variable annuity contracts which is registered under the Act as a unit investment trust on Form N-4
  e. Small business investment company registered under the Act on Form N-5
  f. Separate account offering variable insurance contracts which is registered under the Act as a unit investment trust on Form N-6
  g. Unit investment trust registered under the Act on Form N-8B-2
i. Total number of Series of the Registrant
3

Item B.7. Securities Act registration.

Is the Registrant the issuer of a class of securities registered under the Securities Act of 1933 ("Securities Act")? X Yes   No

Item B.8. Directors.

Provide the information requested below about each person serving as director of the Registrant (management investment companies only):
Director Record: 1
a. Full Name
Donald McIntosh
b. CRD number, if any
N/A
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))?   Yes X No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
N/A
Director Record: 2
a. Full Name
Stephen P. Lachenauer
b. CRD number, if any
N/A
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))?   Yes X No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
N/A
Director Record: 3
a. Full Name
Tobias Caldwell
b. CRD number, if any
N/A
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))?   Yes X No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
N/A

Item B.9. Chief compliance officer.

Provide the information requested below about each person serving as chief compliance officer of the Registrant for purposes of rule 38a-1 (17 CFR 270.38a- 1):
Chief compliance officer Record: 1
a. Full Name
Frederick J. Schmidt
b. CRD Number, if any
N/A
c. Street Address 1
36 N. New York Avenue
Street Address 2
d. City
Huntington
e. State, if applicable
NEW YORK
f. Foreign country, if applicable
UNITED STATES OF AMERICA
g. Zip code and zip code extension, or foreign postal code
11743
h. Telephone number (including country code if foreign)
XXXXXX
i. Has the chief compliance officer changed since the last filing?   Yes X No
If the chief compliance officer is compensated or employed by any person other than the Registrant, or an affiliated person of the Registrant, for providing chief compliance officer services, provide:
CCO employer Record: 1
i. Name of the person
N/A
ii. Person's IRS Employer Identification Number
N/A

Item B.10. Matters for security holder vote.

Instruction. Registrants registered on Forms N-3, N-4 or N-6, should respond "yes" to this Item only if security holder votes were solicited on contract-level matters.
Were any matters submitted by the Registrant for its security holders' vote during the reporting period?   Yes X No

Item B.11. Legal proceeding.

Instruction. For purposes of this Item, the following proceedings should be described: (1) any bankruptcy, receivership or similar proceeding with respect to the Registrant or any of its significant subsidiaries; (2) any proceeding to which any director, officer or other affiliated person of the Registrant is a party adverse to the Registrant or any of its subsidiaries; and (3) any proceeding involving the revocation or suspension of the right of the Registrant to sell securities.
a. Have there been any material legal proceedings, other than routine litigation incidental to the business, to which the Registrant or any of its subsidiaries was a party or of which any of their property was the subject during the reporting period?   Yes X No
b. Has any proceeding previously reported been terminated?   Yes X No

Item B.12. Fidelity bond and insurance (management investment companies only).

a. Were any claims with respect to the Registrant filed under a fidelity bond (including, but not limited to, the fidelity insuring agreement of the bond) during the reporting period?   Yes X No

Item B.13. Directors and officers/errors and omissions insurance (management investment companies only).

a. Are the Registrant's officers or directors covered in their capacities as officers or directors under any directors and officers/errors and omissions insurance policy owned by the Registrant or anyone else? X Yes   No
i. If yes, were any claims filed under the policy during the reporting period with respect to the Registrant?   Yes X No

Item B.14. Provision of financial support.

Instruction. For purposes of this Item, a provision of financial support includes any (1) capital contribution, (2) purchase of a security from a Money Market Fund in reliance on rule 17a-9 under the Act (17 CFR 270.17a-9), (3) purchase of any defaulted or devalued security at fair value reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio, (4) execution of letter of credit or letter of indemnity, (5) capital support agreement (whether or not the Registrant ultimately received support), (6) performance guarantee, or (7) other similar action reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio. Provision of financial support does not include any (1) routine waiver of fees or reimbursement of Registrant's expenses, (2) routine inter-fund lending, (3) routine inter-fund purchases of Registrant's shares, or (4) action that would qualify as financial support as defined above, that the board of directors has otherwise determined not to be reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio.
Did an affiliated person, promoter, or principal underwriter of the Registrant, or an affiliated person of such a person, provide any form of financial support to the Registrant during the reporting period?   Yes X No

Item B.15. Exemptive orders.

a. During the reporting period, did the Registrant rely on any orders from the Commission granting an exemption from one or more provisions of the Act, Securities Act or Exchange Act? X Yes   No
Release number Record: 1
i. If yes, provide below the release number for each order
IC-30061
Release number Record: 2
i. If yes, provide below the release number for each order
IC-30854

Item B.16. Principal underwriters.

a. Provide the information requested below about each principal underwriter:
Principal underwriter Record: 1
i. Full name
Foreside Fund Services, LLC
ii. SEC file number (e.g., 8-)
008-51293
iii. CRD number
000046106
iv. LEI, if any
N/A
v. State, if applicable
MAINE
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Is the principal underwriter an affiliated person of the Registrant, or its investment adviser(s) or depositor?   Yes X No
b. Have any principal underwriters been hired or terminated during the reporting period?   Yes X No

Item B.17. Independent public accountant.

Provide the following information about eachthe independent public accountant:
Public accountant Record: 1
a. Full Name
Cohen Fund Audit Services, Ltd.
b. PCAOB Number
925
c. LEI, if any
N/A
d. State, if applicable
OHIO
e. Foreign country, if applicable
UNITED STATES OF AMERICA
f. Has the independent public accountant changed since the last filing?  Yes X No

Item B.18. Report on internal control (management investment companies only).

Instruction. Small business investment companies are not required to respond to this item.
For the reporting period, did an independent public accountant's report on internal control note any material weaknesses?   Yes X No

Item B.19. Audit opinion.

For the reporting period, did an independent public accountant issue an opinion other than an unqualified opinion with respect to its audit of the Registrant's financial statements?   Yes X No

Item B.20. Change in valuation methods.

Instruction. Responses to this item need not include changes to valuation techniques used for individual securities (e.g., changing from market approach to income approach for a private equity security). In responding to Item B.20.c., provide the applicable "asset type" category specified in Item C.4.a. of Form N-PORT. In responding to Item B.20.d., provide a brief description of the type of investments involved. If the change in valuation methods applies only to certain sub-asset types included in the response to Item B.20.c., please provide the sub-asset types in the response to Item B.20.d. The responses to Item B.20.c. and Item B.20.d. should be identical only if the change in valuation methods applies to all assets within that category.
Have there been material changes in the method of valuation (e.g., change from use of bid price to mid price for fixed income securities or change in trigger threshold for use of fair value factors on international equity securities) of the Registrant's assets during the reporting period?   Yes X No

Item B.21. Change in accounting principles and practices.

Have there been any changes in accounting principles or practices, or any change in the method of applying any such accounting principles or practices, which will materially affect the financial statements filed or to be filed for the current year with the Commission and which has not been previously reported?   Yes X No

Item B.22. Net asset value error corrections (open-end management investment companies only).

a. During the reporting period, were any payments made to shareholders or shareholder accounts reprocessed as a result of an error in calculating the Registrant's net asset value (or net asset value per share)?   Yes X No

Item B.23. Rule 19a-1 notice (management investment companies only).

During the reporting period, did the Registrant pay any dividend or make any distribution in the nature of a dividend payment, required to be accompanied by a written statement pursuant to section 19(a) of the Act (15 U.S.C. 80a-19(a)) and rule 19a-1 thereunder (17 CFR 270.19a-1)? X Yes   No
Payment dividend series info Record: 1
a. If yes, and to the extent the response relates only to certain series of the Registrant, indicate the series involved:
i. Series name
Strategy Shares Nasdaq 7 HANDL(TM) ETF
ii. Series identification number
S000059719

N-CEN/A:Part C: Additional Questions for Management Investment Companies

General Instruction.

Management investment companies that offer multiple series must complete Part C as to each series separately, even if some information is the same for two or more series. To begin this section or add an additional series(s), click on the bar labeled "Add a New Series" below.
Management Investment Record: 1

Item C.1. Background information.

a. Full Name of the Fund

Strategy Shares Nasdaq 7 HANDL(TM) Index ETF

b. Series identication number, if any

S000059719

c. LEI

549300L5NDMV21TEOR35

d. Is this the first filing on this form by the Fund? X Yes   No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

1

b. How many new Classes of shares of the Fund were added during the reporting period?

0

c. How many Classes of shares of the Fund were terminated during the reporting period?

0

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
STRATEGY SHARES NASDAQ 7 HANDL(TM) INDEX ETF
ii. Class identification number, if any

C000195439

iii. Ticker symbol, if any

HNDL


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund
i. X Exchange-Traded Fund
ii.   Exchange-Traded Managed Fund
b. X Index Fund
i. Is the index whose performance the Fund tracks, constructed:
1. By an affiliated person of the fund?X Yes   No
2. Exclusively for the fund?X Yes   No
ii. Provide the annualized difference between the Fund's total return during the reporting period and the index's return during the reporting period (i.e., the Fund's total return less the index's return):
1. Before Fund fees and expenses:
2.37
2. After Fund fees and expenses (i.e., net asset value):
1.36
iii. Provide the annualized standard deviation of the daily difference between the Fund's total return and the index's return during the reporting period:
1. Before Fund fees and expenses:
0.002239961
2. After Fund fees and expenses (i.e., net asset value):
0.0022364374

c. X Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark
d.   Interval Fund
e.   Fund of Funds
f.   Master-Feeder Fund
g.   Money Market Fund
h.   Target Date Fund
i.   Underlying fund to a variable annuity or variable life insurance contract
  N/A

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))?   Yes X No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities?   Yes X No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions?   Yes X No
b. Did the Fund lend any of its securities during the reporting period?   Yes X No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund?   Yes   No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent?   Yes   No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period?   Yes   No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund?   Yes   No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund?   Yes   No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply):   i. Revenue sharing split
  ii. Non-revenue sharing split (other than administrative fee)
  iii. Administrative fee
  iv. Cash collateral reinvestment fee
  v. Indemnification fee
  vi. Other
X N/A
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A

g. Provide the net income from securities lending activities

N/A


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply)   a. Rule 10f-3 (17 CFR 270.10f-3)
X b. Rule 12d1-1 (17 CFR 270.12d1-1)
  c. Rule 15a-4 (17 CFR 270.15a-4)
  d. Rule 17a-6 (17 CFR 270.17a-6)
  e. Rule 17a-7 (17 CFR 270.17a-7)
  f. Rule 17a-8 (17 CFR 270.17a-8)
  g. Rule 17e-1 (17 CFR 270.17e-1)
X h. Rule 22d-1 (17 CFR 270.22d-1)
  i. Rule 23c-1 (17 CFR 270.23c-1)
X j. Rule 32a-4 (17 CFR 270.32a-4)
  N/A

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? X Yes   No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? X Yes   No
c. Are the fees waived subject to recoupment? X Yes   No
d. Were any expenses previously waived recouped during the period?   Yes X No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Rational Advisors, Inc.
ii. SEC file number ( e.g., 801- )

801-60176

iii.CRD number
000111452
iv. LEI, if any

00000000000000000000

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Was the investment adviser hired during the reporting period?   Yes X No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
ii. SEC file number ( e.g., 801- )

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Termination date

c. For each sub-adviser to the Fund, provide the information requested:
i. Full name
ii. SEC file number ( e.g., 801- ), if applicable

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)?   Yes   No
viii. Was the sub-adviser hired during the reporting period?   Yes   No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
ii. SEC file number ( e.g., 801- )

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Termination date


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Citi Fund Services Ohio, Inc.
ii.SEC file number ( e.g., 84- or 85- )

085-11408

iii. LEI, if any

549300OX9HIV34JOX333

iv. State, if applicable
OHIO
v. Foreign country, if applicable
UNITED STATES OF AMERICA
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)?   Yes X No
vii. Is the transfer agent a sub-transfer agent?   Yes X No
b. Has a transfer agent been hired or terminated during the reporting period?   Yes X No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Intercontinental Exchange, Inc.
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92

Description of other identifying number

iii. State, if applicable
GEORGIA
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)?   Yes X No
b. Was a pricing service hired or terminated during the reporting period?   Yes X No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
Citibank, N.A.
ii. LEI, if any

00000000000000000000

iii. State, if applicable
NEW YORK
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)?   Yes X No
vi. Is the custodian a sub-custodian?   Yes X No
vii. With respect to the custodian, check below to indicate the type of custody:   1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
  2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
  3.Self - rule 17f-2 (17 CFR 270.17f-2)
X 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
  5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
  6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
  7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
  8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
  9.Other

b. Has a custodian been hired or terminated during the reporting period?*   Yes X No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
i. Full name
ii. LEI, if any, or provide and describe other identifying number

Description of other identifying number

iii. State, if applicable
iv. Foreign country, if applicable
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)?   Yes   No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent?   Yes   No
b. Has a shareholder servicing agent been hired or terminated during the reporting period?   Yes X No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Citi Fund Services Ohio, Inc.
ii. LEI, if any, or other identifying number

549300OX9HIV34JOX333

Description of other identifying number

iii. State, if applicable
OHIO
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)?   Yes X No
vi. Is the administrator a sub-administrator?   Yes X No
b.Has a third-party administrator been hired or terminated during the reporting period?   Yes X No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
Alts Fund Distributors, LLC
b. SEC file number

008-67829

c. CRD number
000146547
d. LEI, if any

00000000000000000000

e. State, if applicable
NEW YORK
f. Foreign country, if applicable
UNITED STATES OF AMERICA
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
BTIG, LLC.
ii. SEC file number

008-65473

iii. CRD number
000122225
iv. LEI, if any

549300GTG9PL6WO3EC51

v. State, if applicable
CALIFORNIA
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

932.63

Brokers Record: 2
i. Full name of broker
ESPOSITO SECURITIES, LLC
ii. SEC file number

008-67596

iii. CRD number
000143710
iv. LEI, if any

5493005PRA6C64RLD847

v. State, if applicable
TEXAS
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

5,056.04

b. Aggregate brokerage commissions paid by Fund during the reporting period:

5,988.67


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
CITIGROUP GLOBAL MARKETS INC.
ii. SEC file number

008-08177

iii. CRD number
000007059
iv. LEI, if any

MBNUM2BPBDO7JBLYG310

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

817,672.19

Principal Transactions Record: 2
i. Full name of dealer
J.P. MORGAN SECURITIES LLC
ii. SEC file number

008-35008

iii. CRD number
000000079
iv. LEI, if any

ZBUT11V806EZRVTWT807

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,347,154.42

Principal Transactions Record: 3
i. Full name of dealer
MERRILL LYNCH PROFESSIONAL CLEARING CORP.
ii. SEC file number

008-07221

iii. CRD number
000007691
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

3,234,155.36

Principal Transactions Record: 4
i. Full name of dealer
CANTOR FITZGERALD & CO.
ii. SEC file number

008-00201

iii. CRD number
000000134
iv. LEI, if any

5493004J7H4GCPG6OB62

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

2,665,564.15

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

11,064,546.12


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)?   Yes X No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

8,437,773.56

b. Provide the money market fund's daily average net assets during the reporting period


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?  Yes X No

b. Did the Fund engage in interfund lending?   Yes X No

c.Did the Fund engage in interfund borrowing?   Yes X No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing?   Yes   No
Management Investment Record: 2

Item C.1. Background information.

a. Full Name of the Fund

Strategy Shares US Market Rotation Strategy ETF

b. Series identication number, if any

S000031175

c. LEI

00000000000000000000

d. Is this the first filing on this form by the Fund? X Yes   No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

1

b. How many new Classes of shares of the Fund were added during the reporting period?

0

c. How many Classes of shares of the Fund were terminated during the reporting period?

0

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
STRATEGY SHARES US MARKET ROTATION STRATEGY ETF 1
ii. Class identification number, if any

C000096746

iii. Ticker symbol, if any

HUSE


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund
i. X Exchange-Traded Fund
ii.   Exchange-Traded Managed Fund
b.   Index Fund

c.   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark
d.   Interval Fund
e.   Fund of Funds
f.   Master-Feeder Fund
g.   Money Market Fund
h.   Target Date Fund
i.   Underlying fund to a variable annuity or variable life insurance contract
  N/A

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))?   Yes X No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities?   Yes X No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions?   Yes X No
b. Did the Fund lend any of its securities during the reporting period?   Yes X No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund?   Yes   No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent?   Yes   No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period?   Yes   No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund?   Yes   No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund?   Yes   No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply):   i. Revenue sharing split
  ii. Non-revenue sharing split (other than administrative fee)
  iii. Administrative fee
  iv. Cash collateral reinvestment fee
  v. Indemnification fee
  vi. Other
X N/A
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A

g. Provide the net income from securities lending activities

N/A


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply)   a. Rule 10f-3 (17 CFR 270.10f-3)
X b. Rule 12d1-1 (17 CFR 270.12d1-1)
  c. Rule 15a-4 (17 CFR 270.15a-4)
  d. Rule 17a-6 (17 CFR 270.17a-6)
  e. Rule 17a-7 (17 CFR 270.17a-7)
  f. Rule 17a-8 (17 CFR 270.17a-8)
  g. Rule 17e-1 (17 CFR 270.17e-1)
X h. Rule 22d-1 (17 CFR 270.22d-1)
  i. Rule 23c-1 (17 CFR 270.23c-1)
X j. Rule 32a-4 (17 CFR 270.32a-4)
  N/A

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? X Yes   No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period?   Yes X No
c. Are the fees waived subject to recoupment?   Yes X No
d. Were any expenses previously waived recouped during the period? X Yes   No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Rational Advisors, Inc.
ii. SEC file number ( e.g., 801- )

801-60176

iii.CRD number
000111452
iv. LEI, if any

00000000000000000000

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Was the investment adviser hired during the reporting period?   Yes X No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
ii. SEC file number ( e.g., 801- )

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Termination date

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Tuttle Tactical Management, LLC
ii. SEC file number ( e.g., 801- ), if applicable

801-76982

iii. CRD number
000164937
iv. LEI, if any

00000000000000000000

v. State, if applicable
CONNECTICUT
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)?   Yes X No
viii. Was the sub-adviser hired during the reporting period?   Yes X No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
ii. SEC file number ( e.g., 801- )

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Termination date


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Citi Fund Services Ohio, Inc.
ii.SEC file number ( e.g., 84- or 85- )

085-11408

iii. LEI, if any

549300OX9HIV34JOX333

iv. State, if applicable
OHIO
v. Foreign country, if applicable
UNITED STATES OF AMERICA
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)?   Yes X No
vii. Is the transfer agent a sub-transfer agent?   Yes X No
b. Has a transfer agent been hired or terminated during the reporting period?   Yes X No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Intercontinental Exchange, Inc.
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92

Description of other identifying number

iii. State, if applicable
GEORGIA
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)?   Yes X No
b. Was a pricing service hired or terminated during the reporting period?   Yes X No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
Citibank, N.A.
ii. LEI, if any

00000000000000000000

iii. State, if applicable
NEW YORK
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)?   Yes X No
vi. Is the custodian a sub-custodian?   Yes X No
vii. With respect to the custodian, check below to indicate the type of custody:   1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
  2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
  3.Self - rule 17f-2 (17 CFR 270.17f-2)
X 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
  5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
  6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
  7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
  8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
  9.Other

b. Has a custodian been hired or terminated during the reporting period?*   Yes X No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
i. Full name
ii. LEI, if any, or provide and describe other identifying number

Description of other identifying number

iii. State, if applicable
iv. Foreign country, if applicable
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)?   Yes   No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent?   Yes   No
b. Has a shareholder servicing agent been hired or terminated during the reporting period?   Yes X No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Citi Fund Services Ohio, Inc.
ii. LEI, if any, or other identifying number

549300OX9HIV34JOX333

Description of other identifying number

iii. State, if applicable
OHIO
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)?   Yes X No
vi. Is the administrator a sub-administrator?   Yes X No
b.Has a third-party administrator been hired or terminated during the reporting period?   Yes X No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
Alts Fund Distributors, LLC
b. SEC file number

008-67829

c. CRD number
000146547
d. LEI, if any

00000000000000000000

e. State, if applicable
NEW YORK
f. Foreign country, if applicable
UNITED STATES OF AMERICA
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
WEDBUSH MORGAN SECURITIES
ii. SEC file number

008-12987

iii. CRD number
000000877
iv. LEI, if any

549300CSX55MXZ47EI78

v. State, if applicable
CALIFORNIA
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

128,104.45

Brokers Record: 2
i. Full name of broker
WALLACHBETH CAPITAL LLC
ii. SEC file number

008-67936

iii. CRD number
000147853
iv. LEI, if any

549300R371KUKXEXC133

v. State, if applicable
NEW JERSEY
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

266,888.72

Brokers Record: 3
i. Full name of broker
J.P. MORGAN SECURITIES LLC
ii. SEC file number

008-35008

iii. CRD number
000000079
iv. LEI, if any

ZBUT11V806EZRVTWT807

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

220,191.55

Brokers Record: 4
i. Full name of broker
BTIG, LLC.
ii. SEC file number

008-65473

iii. CRD number
000122225
iv. LEI, if any

549300GTG9PL6WO3EC51

v. State, if applicable
CALIFORNIA
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

66,271.95

Brokers Record: 5
i. Full name of broker
WEEDEN & CO.
ii. SEC file number

008-37267

iii. CRD number
000016835
iv. LEI, if any

549300OYBLKSN8M8EW67

v. State, if applicable
CONNECTICUT
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

42,527.97

Brokers Record: 6
i. Full name of broker
ESPOSITO PARTNERS LLC
ii. SEC file number

008-67596

iii. CRD number
000143710
iv. LEI, if any

5493005PRA6C64RLD847

v. State, if applicable
TEXAS
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

64,117.73

Brokers Record: 7
i. Full name of broker
TOURMALINE
ii. SEC file number

008-68644

iii. CRD number
000154492
iv. LEI, if any

5493002XAV50EJHN6Y32

v. State, if applicable
CONNECTICUT
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

284,466.56

Brokers Record: 8
i. Full name of broker
JONES TRADING INSTITUTION
ii. SEC file number

008-26089

iii. CRD number
000006888
iv. LEI, if any

2138008JJ5PA8H5UIL69

v. State, if applicable
CALIFORNIA
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

31,784.63

Brokers Record: 9
i. Full name of broker
CAPITAL INSTIT SERVICES CAPIS
ii. SEC file number

008-22273

iii. CRD number
000007551
iv. LEI, if any

54930061X8RDWFDJIS05

v. State, if applicable
TEXAS
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

31,599.66

Brokers Record: 10
i. Full name of broker
KNIGHT SECURITIES
ii. SEC file number

008-25576

iii. CRD number
000008504
iv. LEI, if any

00000000000000000000

v. State, if applicable
GEORGIA
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

96,685.46

b. Aggregate brokerage commissions paid by Fund during the reporting period:

1,353,525.41


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
VIRTU AMERICAS LLC
ii. SEC file number

008-68193

iii. CRD number
000149823
iv. LEI, if any

549300RA02N3BNSWBV74

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

151,414,805.15

Principal Transactions Record: 2
i. Full name of dealer
J.P. MORGAN SECURITIES LLC
ii. SEC file number

008-35008

iii. CRD number
000000079
iv. LEI, if any

ZBUT11V806EZRVTWT807

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

139.82

Principal Transactions Record: 3
i. Full name of dealer
WEEDEN & CO.
ii. SEC file number

008-37267

iii. CRD number
000016835
iv. LEI, if any

549300OYBLKSN8M8EW67

v. State, if applicable
CONNECTICUT
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

1,972,408.35

Principal Transactions Record: 4
i. Full name of dealer
MERRILL LYNCH PROFESSIONAL CLEARING CORP.
ii. SEC file number

008-07221

iii. CRD number
000007691
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

51,010,739.92

Principal Transactions Record: 5
i. Full name of dealer
CITIGROUP GLOBAL MARKETS INC.
ii. SEC file number

008-08177

iii. CRD number
000007059
iv. LEI, if any

MBNUM2BPBDO7JBLYG310

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

16,675,332.89

Principal Transactions Record: 6
i. Full name of dealer
CANTOR FITZGERALD & CO.
ii. SEC file number

008-00201

iii. CRD number
000000134
iv. LEI, if any

5493004J7H4GCPG6OB62

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

866,867.43

Principal Transactions Record: 7
i. Full name of dealer
GOLDMAN, SACHS & CO.
ii. SEC file number

008-00129

iii. CRD number
000000361
iv. LEI, if any

FOR8UP27PHTHYVLBNG30

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

800,992.87

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

222,741,286.43


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)?   Yes X No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

188,525,552.87

b. Provide the money market fund's daily average net assets during the reporting period


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?  Yes X No

b. Did the Fund engage in interfund lending?   Yes X No

c.Did the Fund engage in interfund borrowing?   Yes X No

Management Investment Record: 3

Item C.1. Background information.

a. Full Name of the Fund

Strategy Shares EcoLogical Strategy ETF

b. Series identication number, if any

S000031176

c. LEI

00000000000000000000

d. Is this the first filing on this form by the Fund? X Yes   No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

1

b. How many new Classes of shares of the Fund were added during the reporting period?

0

c. How many Classes of shares of the Fund were terminated during the reporting period?

0

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
STRATEGY SHARES ECOLOGICAL STRATEGY ETF 1
ii. Class identification number, if any

C000096747

iii. Ticker symbol, if any

HECO


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund
i. X Exchange-Traded Fund
ii.   Exchange-Traded Managed Fund
b.   Index Fund

c.   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark
d.   Interval Fund
e.   Fund of Funds
f.   Master-Feeder Fund
g.   Money Market Fund
h.   Target Date Fund
i.   Underlying fund to a variable annuity or variable life insurance contract
  N/A

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))?   Yes X No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities?   Yes X No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions?   Yes X No
b. Did the Fund lend any of its securities during the reporting period?   Yes X No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund?   Yes   No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent?   Yes   No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period?   Yes   No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund?   Yes   No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund?   Yes   No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply):   i. Revenue sharing split
  ii. Non-revenue sharing split (other than administrative fee)
  iii. Administrative fee
  iv. Cash collateral reinvestment fee
  v. Indemnification fee
  vi. Other
X N/A
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A

g. Provide the net income from securities lending activities

N/A


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply)   a. Rule 10f-3 (17 CFR 270.10f-3)
X b. Rule 12d1-1 (17 CFR 270.12d1-1)
  c. Rule 15a-4 (17 CFR 270.15a-4)
  d. Rule 17a-6 (17 CFR 270.17a-6)
  e. Rule 17a-7 (17 CFR 270.17a-7)
  f. Rule 17a-8 (17 CFR 270.17a-8)
  g. Rule 17e-1 (17 CFR 270.17e-1)
X h. Rule 22d-1 (17 CFR 270.22d-1)
  i. Rule 23c-1 (17 CFR 270.23c-1)
X j. Rule 32a-4 (17 CFR 270.32a-4)
  N/A

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? X Yes   No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? X Yes   No
c. Are the fees waived subject to recoupment? X Yes   No
d. Were any expenses previously waived recouped during the period?   Yes X No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Rational Advisors, Inc.
ii. SEC file number ( e.g., 801- )

801-60176

iii.CRD number
000111452
iv. LEI, if any

00000000000000000000

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Was the investment adviser hired during the reporting period?   Yes X No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
ii. SEC file number ( e.g., 801- )

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Termination date

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Tuttle Tactical Management, LLC
ii. SEC file number ( e.g., 801- ), if applicable

801-76982

iii. CRD number
000164937
iv. LEI, if any

00000000000000000000

v. State, if applicable
CONNECTICUT
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)?   Yes X No
viii. Was the sub-adviser hired during the reporting period? X Yes   No
1. If the sub-adviser was hired during the period, indicate the sub-adviser's start date:

2018-07-01

d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
ii. SEC file number ( e.g., 801- )

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Termination date


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Citi Fund Services Ohio, Inc.
ii.SEC file number ( e.g., 84- or 85- )

085-11408

iii. LEI, if any

549300OX9HIV34JOX333

iv. State, if applicable
OHIO
v. Foreign country, if applicable
UNITED STATES OF AMERICA
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)?   Yes X No
vii. Is the transfer agent a sub-transfer agent?   Yes X No
b. Has a transfer agent been hired or terminated during the reporting period?   Yes X No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Intercontinental Exchange, Inc.
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92

Description of other identifying number

iii. State, if applicable
GEORGIA
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)?   Yes X No
b. Was a pricing service hired or terminated during the reporting period?   Yes X No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
Citibank, N.A.
ii. LEI, if any

00000000000000000000

iii. State, if applicable
NEW YORK
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)?   Yes X No
vi. Is the custodian a sub-custodian?   Yes X No
vii. With respect to the custodian, check below to indicate the type of custody:   1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
  2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
  3.Self - rule 17f-2 (17 CFR 270.17f-2)
X 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
  5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
  6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
  7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
  8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
  9.Other

b. Has a custodian been hired or terminated during the reporting period?*   Yes X No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
i. Full name
ii. LEI, if any, or provide and describe other identifying number

Description of other identifying number

iii. State, if applicable
iv. Foreign country, if applicable
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)?   Yes   No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent?   Yes   No
b. Has a shareholder servicing agent been hired or terminated during the reporting period?   Yes X No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Citi Fund Services Ohio, Inc.
ii. LEI, if any, or other identifying number

549300OX9HIV34JOX333

Description of other identifying number

iii. State, if applicable
OHIO
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)?   Yes X No
vi. Is the administrator a sub-administrator?   Yes X No
b.Has a third-party administrator been hired or terminated during the reporting period?   Yes X No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
Alts Fund Distributors, LLC
b. SEC file number

008-67829

c. CRD number
000146547
d. LEI, if any

00000000000000000000

e. State, if applicable
NEW YORK
f. Foreign country, if applicable
UNITED STATES OF AMERICA
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
JANE STREET
ii. SEC file number

008-52275

iii. CRD number
000103782
iv. LEI, if any

549300ZM16HMPEPNV857

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

11,752.05

Brokers Record: 2
i. Full name of broker
TOURMALINE
ii. SEC file number

008-68644

iii. CRD number
000154492
iv. LEI, if any

5493002XAV50EJHN6Y32

v. State, if applicable
CONNECTICUT
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

43,227.88

Brokers Record: 3
i. Full name of broker
WEDBUSH MORGAN SECURITIES
ii. SEC file number

008-12987

iii. CRD number
000000877
iv. LEI, if any

549300CSX55MXZ47EI78

v. State, if applicable
CALIFORNIA
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

24,191.89

Brokers Record: 4
i. Full name of broker
J.P. MORGAN SECURITIES LLC
ii. SEC file number

008-35008

iii. CRD number
000000079
iv. LEI, if any

ZBUT11V806EZRVTWT807

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

23,490.68

Brokers Record: 5
i. Full name of broker
JONES TRADING INSTITUTION
ii. SEC file number

008-26089

iii. CRD number
000006888
iv. LEI, if any

2138008JJ5PA8H5UIL69

v. State, if applicable
CALIFORNIA
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

12,812.78

Brokers Record: 6
i. Full name of broker
WALLACHBETH CAPITAL LLC
ii. SEC file number

008-67936

iii. CRD number
000147853
iv. LEI, if any

549300R371KUKXEXC133

v. State, if applicable
NEW JERSEY
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

81,445.85

Brokers Record: 7
i. Full name of broker
BTIG, LLC.
ii. SEC file number

008-65473

iii. CRD number
000122225
iv. LEI, if any

549300GTG9PL6WO3EC51

v. State, if applicable
CALIFORNIA
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

10,245.53

Brokers Record: 8
i. Full name of broker
KNIGHT SECURITIES
ii. SEC file number

008-25576

iii. CRD number
000008504
iv. LEI, if any

00000000000000000000

v. State, if applicable
GEORGIA
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

7,796.32

Brokers Record: 9
i. Full name of broker
RW PRESSPRICH
ii. SEC file number

008-42547

iii. CRD number
000026460
iv. LEI, if any

549300N7J0JV1QRBLW74

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

24,854.7

Brokers Record: 10
i. Full name of broker
ESPOSITO PARTNERS LLC
ii. SEC file number

008-67596

iii. CRD number
000143710
iv. LEI, if any

5493005PRA6C64RLD847

v. State, if applicable
TEXAS
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

48,699.94

b. Aggregate brokerage commissions paid by Fund during the reporting period:

304,195.71


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
MERRILL LYNCH PROFESSIONAL CLEARING CORP.
ii. SEC file number

008-07221

iii. CRD number
000007691
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

12,071,241.47

Principal Transactions Record: 2
i. Full name of dealer
VIRTU AMERICAS LLC
ii. SEC file number

008-68193

iii. CRD number
000149823
iv. LEI, if any

549300RA02N3BNSWBV74

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

41,417,066.76

Principal Transactions Record: 3
i. Full name of dealer
ESPOSITO PARTNERS LLC
ii. SEC file number

008-67596

iii. CRD number
000143710
iv. LEI, if any

5493005PRA6C64RLD847

v. State, if applicable
TEXAS
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

147,968.05

Principal Transactions Record: 4
i. Full name of dealer
CITIGROUP GLOBAL MARKETS INC.
ii. SEC file number

008-08177

iii. CRD number
000007059
iv. LEI, if any

MBNUM2BPBDO7JBLYG310

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

84,606.58

Principal Transactions Record: 5
i. Full name of dealer
CITADEL SECURITIES LLC
ii. SEC file number

008-53574

iii. CRD number
000116797
iv. LEI, if any

12UUJYTN7D3SW8KCSG25

v. State, if applicable
ILLINOIS
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

1,865,238.66

Principal Transactions Record: 6
i. Full name of dealer
J.P. MORGAN SECURITIES LLC
ii. SEC file number

008-35008

iii. CRD number
000000079
iv. LEI, if any

ZBUT11V806EZRVTWT807

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

13.1

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

55,586,134.62


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)?   Yes X No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

44,622,064.67

b. Provide the money market fund's daily average net assets during the reporting period


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?  Yes X No

b. Did the Fund engage in interfund lending?   Yes X No

c.Did the Fund engage in interfund borrowing?   Yes X No

N-CEN/A:Part E: Additional Questions for Exchange-Traded Funds and Exchange-Traded Managed Funds


Exchange Record: 1


Fund Name
Strategy Shares Nasdaq 7 HANDL(TM) Index ETF

Item E.1. Exchange.

Security Exchanges Record: 1
a. Exchange where listed. Provide the name of the national securities exchange on which the Fund’s shares are listed:
NASDAQ - ALL MARKETS
b. Ticker. Provide the Fund's ticker symbol:
HNDL

Item E.2. Authorized participants.

Instructions: The term "authorized participant" means a broker-dealer that is also a member of a clearing agency registered with the Commission, and which has a written agreement with the Exchange-Traded Fund or Exchange-Traded Managed Fund or one of its designated service providers that allows it place orders to purchase or redeem creation units of the Exchange-Traded Fund or Exchange-Traded Managed Fund.
For each authorized participant of the Fund, provide the following information:

Authorized Participants Record: 1
a. Full Name
CITADEL SECURITIES LLC
b. SEC file number
008-53574
c. CRD number
000116797
d. LEI, if any
12UUJYTN7D3SW8KCSG25
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 2
a. Full Name
GOLDMAN SACHS & CO. LLC
b. SEC file number
008-00129
c. CRD number
000000361
d. LEI, if any
FOR8UP27PHTHYVLBNG30
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 3
a. Full Name
VIRTU AMERICAS LLC
b. SEC file number
008-68193
c. CRD number
000149823
d. LEI, if any
549300RA02N3BNSWBV74
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 4
a. Full Name
CANTOR FITZGERALD & CO.
b. SEC file number
008-00201
c. CRD number
000000134
d. LEI, if any
5493004J7H4GCPG6OB62
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
2,969,937.91
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 5
a. Full Name
MERRILL LYNCH PROFESSIONAL CLEARING CORP.
b. SEC file number
008-33359
c. CRD number
000016139
d. LEI, if any
549300PMHS66E71I2D34
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
2,334,813.76
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
1,146,853.46
Authorized Participants Record: 6
a. Full Name
J.P. MORGAN SECURITIES LLC
b. SEC file number
008-35008
c. CRD number
000000079
d. LEI, if any
ZBUT11V806EZRVTWT807
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
4,779,519.38
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 7
a. Full Name
Cowen Execution Services LLC
b. SEC file number
008-46838
c. CRD number
000035693
d. LEI, if any
5493005RJDJD18OPUP27
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 8
a. Full Name
BofA Securities Inc.
b. SEC file number
008-69787
c. CRD number
000283942
d. LEI, if any
549300HN4UKV1E2R3U73
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 9
a. Full Name
RBC Capital Markets LLC
b. SEC file number
008-45411
c. CRD number
000031194
d. LEI, if any
549300LCO2FLSSVFFR64
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 10
a. Full Name
UBS Securities LLC
b. SEC file number
008-22651
c. CRD number
000007654
d. LEI, if any
T6FIZBDPKLYJKFCRVK44
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 11
a. Full Name
Deutsche Bank Securities Inc.
b. SEC file number
008-17822
c. CRD number
000002525
d. LEI, if any
9J6MBOOO7BECTDTUZW19
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 12
a. Full Name
Credit Suisse Securities (USA) LLC
b. SEC file number
008-00422
c. CRD number
000000816
d. LEI, if any
1V8Y6QCX6YMJ2OELII46
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
g. Did the Fund require that an authorized participant post collateral to the Fund or any of its designated service providers in
connection with the purchase or redemption of Fund shares during the reporting period?
  Yes X No

Item E.3. Creation units.

Instructions. The term “creation unit” means a specified number of Exchange-Traded Fund or Exchange-Traded Managed Fund shares that the fund will issue to (or redeem from) an authorized participant in exchange for the deposit (or delivery) of specified securities, positions, cash, and other assets or positions.
a. Number of Fund shares required to form a creation unit as of the last business day of the reporting period:
25,000
b. Based on the dollar value paid for each creation unit purchased by authorized participants during the reporting period, provide:
i. The average percentage of that value composed of cash:
0.086567 %
ii. The standard deviation of the percentage of that value composed of cash:
0.045425 %
iii. The average percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0.913433 %
iv. The standard deviation of the percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0.045425 %
c. Based on the dollar value paid for creation units redeemed by authorized participants during the reporting period, provide:
i. The average percentage of that value composed of cash:
0.101585 %
ii. The standard deviation of the percentage of that value composed of cash:
0 %
iii. The average percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0.898415 %
iv. The standard deviation of the percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0 %
d. For creation units purchased by authorized participants during the reporting period, provide:
i. The average transaction fee charged to an authorized participant for transacting in the creation units, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
1,354.15
3. A percentage of the value of each creation unit, if charged on that basis:
0 %
ii. The average transaction fee charged to an authorized participant for transacting in those creation units the consideration for which was fully or partially composed of cash, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
0
3. A percentage of the value of each creation unit, if charged on that basis:
0 %
e. For creation units redeemed by authorized participants during the reporting period, provide:
i. The average transaction fee charged to an authorized participant for transacting in the creation units, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
1,375
3. A percentage of the value of each creation unit, if charged on that basis:
0 %
ii. The average transaction fee charged to an authorized participant for transacting in those creation units the consideration for which was fully or partially composed of cash, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
0
3. A percentage of the value of each creation unit, if charged on that basis:
0 %

Item E.5. In-Kind ETF.

Is the Fund an "In-Kind Exchange-Traded Fund" as defined in rule 22e-4 under the Act (17 CFR 270.22e-4)? X Yes   No

Exchange Record: 2


Fund Name
Strategy Shares EcoLogical Strategy ETF

Item E.1. Exchange.

Security Exchanges Record: 1
a. Exchange where listed. Provide the name of the national securities exchange on which the Fund’s shares are listed:
NEW YORK STOCK EXCHANGE, INC.
b. Ticker. Provide the Fund's ticker symbol:
HECO

Item E.2. Authorized participants.

Instructions: The term "authorized participant" means a broker-dealer that is also a member of a clearing agency registered with the Commission, and which has a written agreement with the Exchange-Traded Fund or Exchange-Traded Managed Fund or one of its designated service providers that allows it place orders to purchase or redeem creation units of the Exchange-Traded Fund or Exchange-Traded Managed Fund.
For each authorized participant of the Fund, provide the following information:

Authorized Participants Record: 1
a. Full Name
CITADEL SECURITIES LLC
b. SEC file number
008-53574
c. CRD number
000116797
d. LEI, if any
12UUJYTN7D3SW8KCSG25
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
2,055,251.78
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 2
a. Full Name
CANTOR FITZGERALD & CO.
b. SEC file number
008-00201
c. CRD number
000000134
d. LEI, if any
5493004J7H4GCPG6OB62
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 3
a. Full Name
VIRTU AMERICAS LLC
b. SEC file number
008-68193
c. CRD number
000149823
d. LEI, if any
549300RA02N3BNSWBV74
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
64,404,192.3
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
4,145,306.99
Authorized Participants Record: 4
a. Full Name
MERRILL LYNCH PROFESSIONAL CLEARING CORP.
b. SEC file number
008-33359
c. CRD number
000016139
d. LEI, if any
549300PMHS66E71I2D34
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
7,501,262.09
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
10,046,576.32
Authorized Participants Record: 5
a. Full Name
J.P. MORGAN SECURITIES LLC
b. SEC file number
008-35008
c. CRD number
000000079
d. LEI, if any
ZBUT11V806EZRVTWT807
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 6
a. Full Name
GOLDMAN SACHS & CO. LLC
b. SEC file number
008-00129
c. CRD number
000000361
d. LEI, if any
FOR8UP27PHTHYVLBNG30
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 7
a. Full Name
BofA Securities Inc.
b. SEC file number
008-69787
c. CRD number
000283942
d. LEI, if any
549300HN4UKV1E2R3U73
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 8
a. Full Name
UBS Securities LLC
b. SEC file number
008-22651
c. CRD number
000007654
d. LEI, if any
T6FIZBDPKLYJKFCRVK44
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 9
a. Full Name
Deutsche Bank Securities Inc.
b. SEC file number
008-17822
c. CRD number
000002525
d. LEI, if any
9J6MBOOO7BECTDTUZW19
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 10
a. Full Name
Cowen Execution Services LLC
b. SEC file number
008-46838
c. CRD number
000035693
d. LEI, if any
5493005RJDJD18OPUP27
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 11
a. Full Name
Credit Suisse Securities (USA) LLC
b. SEC file number
008-00422
c. CRD number
000000816
d. LEI, if any
1V8Y6QCX6YMJ2OELII46
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 12
a. Full Name
RBC Capital Markets LLC
b. SEC file number
008-45411
c. CRD number
000031194
d. LEI, if any
549300LCO2FLSSVFFR64
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
g. Did the Fund require that an authorized participant post collateral to the Fund or any of its designated service providers in
connection with the purchase or redemption of Fund shares during the reporting period?
  Yes X No

Item E.3. Creation units.

Instructions. The term “creation unit” means a specified number of Exchange-Traded Fund or Exchange-Traded Managed Fund shares that the fund will issue to (or redeem from) an authorized participant in exchange for the deposit (or delivery) of specified securities, positions, cash, and other assets or positions.
a. Number of Fund shares required to form a creation unit as of the last business day of the reporting period:
25,000
b. Based on the dollar value paid for each creation unit purchased by authorized participants during the reporting period, provide:
i. The average percentage of that value composed of cash:
0.320278 %
ii. The standard deviation of the percentage of that value composed of cash:
0.120289 %
iii. The average percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0.679722 %
iv. The standard deviation of the percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0.120289 %
c. Based on the dollar value paid for creation units redeemed by authorized participants during the reporting period, provide:
i. The average percentage of that value composed of cash:
0.250304 %
ii. The standard deviation of the percentage of that value composed of cash:
0.150206 %
iii. The average percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0.749696 %
iv. The standard deviation of the percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0.150206 %
d. For creation units purchased by authorized participants during the reporting period, provide:
i. The average transaction fee charged to an authorized participant for transacting in the creation units, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
99.96
3. A percentage of the value of each creation unit, if charged on that basis:
0 %
ii. The average transaction fee charged to an authorized participant for transacting in those creation units the consideration for which was fully or partially composed of cash, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
0
3. A percentage of the value of each creation unit, if charged on that basis:
0 %
e. For creation units redeemed by authorized participants during the reporting period, provide:
i. The average transaction fee charged to an authorized participant for transacting in the creation units, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
1,096.06
3. A percentage of the value of each creation unit, if charged on that basis:
0 %
ii. The average transaction fee charged to an authorized participant for transacting in those creation units the consideration for which was fully or partially composed of cash, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
0
3. A percentage of the value of each creation unit, if charged on that basis:
0 %

Item E.5. In-Kind ETF.

Is the Fund an "In-Kind Exchange-Traded Fund" as defined in rule 22e-4 under the Act (17 CFR 270.22e-4)?   Yes X No

Exchange Record: 3


Fund Name
Strategy Shares US Market Rotation Strategy ETF

Item E.1. Exchange.

Security Exchanges Record: 1
a. Exchange where listed. Provide the name of the national securities exchange on which the Fund’s shares are listed:
NEW YORK STOCK EXCHANGE, INC.
b. Ticker. Provide the Fund's ticker symbol:
HUSE

Item E.2. Authorized participants.

Instructions: The term "authorized participant" means a broker-dealer that is also a member of a clearing agency registered with the Commission, and which has a written agreement with the Exchange-Traded Fund or Exchange-Traded Managed Fund or one of its designated service providers that allows it place orders to purchase or redeem creation units of the Exchange-Traded Fund or Exchange-Traded Managed Fund.
For each authorized participant of the Fund, provide the following information:

Authorized Participants Record: 1
a. Full Name
MERRILL LYNCH PROFESSIONAL CLEARING CORP.
b. SEC file number
008-33359
c. CRD number
000016139
d. LEI, if any
549300PMHS66E71I2D34
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
21,995,262.29
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
39,896,089.31
Authorized Participants Record: 2
a. Full Name
CANTOR FITZGERALD & CO.
b. SEC file number
008-00201
c. CRD number
000000134
d. LEI, if any
5493004J7H4GCPG6OB62
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
969,723.93
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 3
a. Full Name
CITADEL SECURITIES LLC
b. SEC file number
008-53574
c. CRD number
000116797
d. LEI, if any
12UUJYTN7D3SW8KCSG25
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 4
a. Full Name
J.P. MORGAN SECURITIES LLC
b. SEC file number
008-35008
c. CRD number
000000079
d. LEI, if any
ZBUT11V806EZRVTWT807
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 5
a. Full Name
GOLDMAN SACHS & CO. LLC
b. SEC file number
008-00129
c. CRD number
000000361
d. LEI, if any
FOR8UP27PHTHYVLBNG30
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
876,940.4
Authorized Participants Record: 6
a. Full Name
VIRTU AMERICAS LLC
b. SEC file number
008-68193
c. CRD number
000149823
d. LEI, if any
549300RA02N3BNSWBV74
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
157,089,275.72
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
8,317,478.03
Authorized Participants Record: 7
a. Full Name
Cowen Execution Services LLC
b. SEC file number
008-46838
c. CRD number
000035693
d. LEI, if any
5493005RJDJD18OPUP27
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 8
a. Full Name
UBS Securities LLC
b. SEC file number
008-22651
c. CRD number
000007654
d. LEI, if any
T6FIZBDPKLYJKFCRVK44
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 9
a. Full Name
Deutsche Bank Securities Inc.
b. SEC file number
008-17822
c. CRD number
000002525
d. LEI, if any
9J6MBOOO7BECTDTUZW19
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 10
a. Full Name
BofA Securities Inc.
b. SEC file number
008-69787
c. CRD number
000283942
d. LEI, if any
549300HN4UKV1E2R3U73
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 11
a. Full Name
RBC Capital Markets LLC
b. SEC file number
008-45411
c. CRD number
000031194
d. LEI, if any
549300LCO2FLSSVFFR64
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
Authorized Participants Record: 12
a. Full Name
Credit Suisse Securities (USA) LLC
b. SEC file number
008-00422
c. CRD number
000000816
d. LEI, if any
1V8Y6QCX6YMJ2OELII46
e. The dollar value of the Fund shares the authorized participant purchased from the Fund during the reporting period:
0
f. The dollar value of the Fund shares the authorized participant redeemed during the reporting period:
0
g. Did the Fund require that an authorized participant post collateral to the Fund or any of its designated service providers in
connection with the purchase or redemption of Fund shares during the reporting period?
  Yes X No

Item E.3. Creation units.

Instructions. The term “creation unit” means a specified number of Exchange-Traded Fund or Exchange-Traded Managed Fund shares that the fund will issue to (or redeem from) an authorized participant in exchange for the deposit (or delivery) of specified securities, positions, cash, and other assets or positions.
a. Number of Fund shares required to form a creation unit as of the last business day of the reporting period:
25,000
b. Based on the dollar value paid for each creation unit purchased by authorized participants during the reporting period, provide:
i. The average percentage of that value composed of cash:
0.105556 %
ii. The standard deviation of the percentage of that value composed of cash:
0.048545 %
iii. The average percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0.894444 %
iv. The standard deviation of the percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0.048545 %
c. Based on the dollar value paid for creation units redeemed by authorized participants during the reporting period, provide:
i. The average percentage of that value composed of cash:
0.179665 %
ii. The standard deviation of the percentage of that value composed of cash:
0.096582 %
iii. The average percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0.820335 %
iv. The standard deviation of the percentage of that value composed of non-cash assets and other positions exchanged on an "in-kind" basis:
0.096582 %
d. For creation units purchased by authorized participants during the reporting period, provide:
i. The average transaction fee charged to an authorized participant for transacting in the creation units, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
615.6
3. A percentage of the value of each creation unit, if charged on that basis:
0 %
ii. The average transaction fee charged to an authorized participant for transacting in those creation units the consideration for which was fully or partially composed of cash, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
0
3. A percentage of the value of each creation unit, if charged on that basis:
0 %
e. For creation units redeemed by authorized participants during the reporting period, provide:
i. The average transaction fee charged to an authorized participant for transacting in the creation units, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
828.26
3. A percentage of the value of each creation unit, if charged on that basis:
0 %
ii. The average transaction fee charged to an authorized participant for transacting in those creation units the consideration for which was fully or partially composed of cash, expressed as:
1. Dollars per creation unit, if charged on that basis:
0
2. Dollars for one or more creation units purchased on the same day, if charged on that basis:
0
3. A percentage of the value of each creation unit, if charged on that basis:
0 %

Item E.5. In-Kind ETF.

Is the Fund an "In-Kind Exchange-Traded Fund" as defined in rule 22e-4 under the Act (17 CFR 270.22e-4)?   Yes X No

N-CEN/A:Part G: Attachments

Item G.1a. Attachments.

Attachments applicable to all Registrants. All Registrants shall file the following attachments, as applicable, with the current report. Indicate the attachments filed with the current report by checking the applicable items below:   i. Legal proceedings
  ii. Provision of financial support
X iii. Independent public accountant's report on internal control (management investment companies other than small business investment companies only)
  iv. Change in accounting principles and practices
  v. Information required to be filed pursuant to exemptive orders
  vi. Other information required to be included as an attachment pursuant to Commission rules and regulations

Instructions.

1. Item G.1.a.i. Legal proceedings.

(a) If the Registrant responded "YES" to Item B.11.a., provide a brief description of the proceedings. As part of the description, provide the case or docket number (if any), and the full names of the principal parties to the proceeding.
(b) If the Registrant responded "YES" to Item B.11.b., identify the proceeding and give its date of termination.

2. Item G.1.a.ii. Provision of financial support. If the Registrant responded "YES" to Item B.14., provide the following information (unless the Registrant is a Money Market Fund): (a) Description of nature of support.

(b) Person providing support.

(c) Brief description of relationship between the person providing support and the Registrant.

(d) Date support provided.

(e) Amount of support.

(f) Security supported (if applicable). Disclose the full name of the issuer, the title of the issue (including coupon or yield, if applicable) and at least two identifiers, if available (e.g., CIK, CUSIP, ISIN, LEI).
(g) Value of security supported on date support was initiated (if applicable).

(h) Brief description of reason for support.

(i) Term of support.

(j) Brief description of any contractual restrictions relating to support.

3. Item G.1.a.iii. Independent public accountant's report on internal control (management investment companies other than small business investment companies only). Each management investment company shall furnish a report of its independent public accountant on the company's system of internal accounting controls. The accountant's report shall be based on the review, study and evaluation of the accounting system, internal accounting controls, and procedures for safeguarding securities made during the audit of the financial statements for the reporting period. The report should disclose any material weaknesses in: (a) the accounting system; (b) system of internal accounting control; or (c) procedures for safeguarding securities which exist as of the end of the Registrant's fiscal year.

The accountant's report shall be furnished as an exhibit to the form and shall: (1) be addressed to the Registrant's shareholders and board of directors; (2) be dated; (3) be signed manually; and (4) indicate the city and state where issued.

Attachments that include a report that discloses a material weakness should include an indication by the Registrant of any corrective action taken or proposed.

The fact that an accountant's report is attached to this form shall not be regarded as acknowledging any review of this form by the independent public accountant.

4. Item G.1.a.iv. Change in accounting principles and practices. If the Registrant responded "YES" to Item B.21, provide an attachment that describes the change in accounting principles or practices, or the change in the method of applying any such accounting principles or practices. State the date of the change and the reasons therefor. A letter from the Registrant's independent accountants, approving or otherwise commenting on the change, shall accompany the description.

5. Item G.1.a.v. Information required to be filed pursuant to exemptive orders. File as an attachment any information required to be reported on Form N-CEN or any predecessor form to Form N-CEN (e.g., Form N-SAR) pursuant to exemptive orders issued by the Commission and relied on by the Registrant.

6. Item G.1.a.vi. Other information required to be included as an attachment pursuant to Commission rules and regulations. File as an attachment any other information required to be included as an attachment pursuant to Commission rules and regulations.

N-CEN/A: Signature

Pursuant to the requirements of the Investment Company Act of 1940, the Registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
Registrant
Strategy Shares
Date
2020-03-13
Signature
James Szilagyi
Title

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