ETF Opportunities Trust

11/05/2025 | Press release | Distributed by Public on 11/05/2025 12:05

Annual Report by Investment Company (Form N-CSR)

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM N-CSR

CERTIFIED SHAREHOLDER REPORT OF REGISTERED

MANAGEMENT INVESTMENT COMPANIES

Investment Company Act file number: 811-23439
Exact name of registrant as specified in charter: ETF Opportunities Trust
Address of principal executive offices:

8730 Stony Point Parkway,

Suite 205

Richmond, VA 23235

Name and address of agent for service

The Corporation Trust Co.

Corporation Trust Center

1209 Orange St.

Wilmington, DE 19801

With Copy to:

Practus, LLP

11300 Tomahawk Creek Parkway,

Suite 310

Leawood, KS 66211

Registrant's telephone number, including area code: (804) 267-7400
Date of fiscal year end: August 31
Date of reporting period: August 31, 2025
Brendan Wood TopGun ETF



ITEM 1.(a). Reports to Stockholders.

Brendan Wood TopGun ETFTailored Shareholder Report

Annual Shareholder Report August 31, 2025

Brendan Wood TopGun ETF

Ticker: BWTG(Listed on the Cboe BZX Exchange, Inc.)

This annual shareholder reportcontains important information about the Brendan Wood TopGun ETF for the period of September 1, 2024 to August 31, 2025. You can find additional information about the Fund at brendanwoodtopgunetf.com. You can also request this information by contacting us at (833) 759-6110.

What were the Fund costs for the past year?

(based on a hypothetical $10,000 investment)

Fund Name
Costs of a $10,000 investment
Costs paid as a percentage of a $10,000 investment
Brendan Wood TopGun ETF
$100
0.95%

How did the Fund perform?

For the period of September 1, 2024 to August 31, 2025, the Brendan Wood TopGun ETF (the "Fund") gained 10.18%, while the S&P 500® Index advanced 15.88%.

What key factors affected the Fund's performance?

The Fund invests in companies identified by Brendan Wood International as "TopGun" companies, recognized by institutional investors for strong fundamentals, management quality, and shareholder alignment.

Over the past year, equity markets were led higher by the "Magnificent 7" technology companies and continued enthusiasm around artificial intelligence. While the Fund participated in the rally, its diversified approach across sectors such as financials, industrials, and healthcare lagged the concentrated strength in mega-cap technology that drove the S&P 500® Index.

Stock selection in defensive and quality-oriented sectors contributed positively, but underweights to the largest tech names were the primary factor behind relative underperformance. The result was a solid double-digit gain of 10.18% for shareholders, albeit behind the S&P 500®'s 15.88% return.

Cumulative Performance

(based on a hypothetical $10,000 investment)

* Inception

Annual Performance

One Year
Average Annual
Total Return
Since Inception
Brendan Wood TopGun ETF
10.18%
25.03%
S&P 500® Index
15.88%
26.19%

The S&P 500® Index is a broad-based unmanaged index of 500 stocks, which is widely recognized as representative of the equity market in general.

Visit www.brendanwoodtopgunetf.com/#performance for more recent performance information.

The Fund's past performance is not a good predictor of how the Fund will perform in the future. The graph and table do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or redemption of Fund shares.

Brendan Wood TopGun ETFTailored Shareholder Report

Sector Breakdown

Top Ten Holdings
Welltower, Inc.
4.87%
HCA Healthcare, Inc.
4.82%
JPMorgan Chase & Co.
4.56%
Nvidia Corp.
4.53%
Royal Bank of Canada
4.36%
Microsoft Corp.
4.35%
Parker-Hannifin Corp.
4.30%
T-Mobile US, Inc.
4.12%
Brookfield Corp.
4.11%
Broadcom, Inc.
4.09%

Key Fund Statistics

(as of August 31, 2025)

Fund Net Assets
$16,786,244
Number of Holdings
25
Total Advisory Fee
$121,187
Portfolio Turnover Rate
21.03%

For additional information about the Fund; including its summary prospectus, prospectus, financial information, holdings and proxy information, visit brendanwoodtopgunetf.com.

What did the Fund invest in?

(% of Net Assets as of August 31, 2025)

ITEM 1.(b). Not applicable.

ITEM 2. CODE OF ETHICS.

(a) The registrant, as of the end of the period covered by this report, has adopted a code of ethics that applies to the registrant's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party.

(c) There have been no amendments, during the period covered by this report, to a provision of the code of ethics that applies to the registrant's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party, and that relates to any element of the code of ethics description.

(d) The registrant has not granted any waivers, including an implicit waiver, from a provision of the code of ethics that applies to the registrant's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party, that relates to one or more of the items set forth in paragraph (b) of this item's instructions.

(e) Not applicable.

(f) The code of ethics is attached hereto as exhibit 19(a)(1).

ITEM 3. AUDIT COMMITTEE FINANCIAL EXPERT.

(a)(1) The registrant does not have an audit committee financial expert serving on its audit committee.

(a)(2) Not applicable.

(a)(3) At this time, the registrant believes that the collective experience provided by the members of the audit committee together offer the registrant adequate oversight for the registrant's level of financial complexity.

ITEM 4. PRINCIPAL ACCOUNTANT FEES AND SERVICES.

(a) Audit Fees. The aggregate fees billed for each of the last two fiscal years for professional services rendered by the principal accountant for the audit of the registrant's annual financial statements or services that are normally provided by the accountant in connection with statutory and regulatory filings or engagements for those fiscal years are $13,500 for 2025 and $13,500 for 2024.

(b) Audit-Related Fees. The aggregate fees billed in each of the last two fiscal years for assurance and related services by the principal accountant that are reasonably related to the performance of the audit of the registrant's financial statements and are not reported under paragraph (a) of this Item are $0 for 2025 and $0 for 2024.

(c) Tax Fees. The aggregate fees billed in each of the last two fiscal years for professional services rendered by the principal accountant for tax compliance, tax advice, and tax planning are $3,300 for 2025 and $3,300 for 2024. The nature of the services comprising these fees include preparation of excise filings and income tax returns and assistance with calculation of required income, capital gain and excise distributions.

(d) All Other Fees. The aggregate fees billed in each of the last two fiscal years for products and services provided by the principal accountant, other than the services reported in paragraphs (a) through (c) of this Item are and $0 for 2025 and $0 for 2024.

(e)(1) Disclose the audit committee's pre-approval policies and procedures described in paragraph (c)(7) of Rule 2-01 of Regulation S-X.

Pursuant to its charter, the registrant's Audit Committee must pre-approve all audit and non-audit services to be provided to the registrant. The Audit Committee also pre-approves any non-audit services provided by the registrant's principal accountant to the adviser or any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the registrant, if the engagement relates directly to the operations and financial reporting of the registrant.

(e)(2) The percentage of services described in each of paragraphs (b) through (d) of this Item that were approved by the audit committee pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X are as follows:

(b) NA
(c) 0%
(d) NA

(f) The percentage of hours expended on the principal accountant's engagement to audit the registrant's financial statements for the most recent fiscal year that were attributed to work performed by persons other than the principal accountant's full-time, permanent employees was zero percent (0%).

(g) The aggregate non-audit fees billed by the registrant's accountant for services rendered to the registrant, and rendered to the registrant's investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the registrant for each of the last two fiscal years of the registrant was $0 for 2025 and $0 for 2024.

(h) Not applicable.

(i) Not applicable.

(j) Not applicable.

ITEM 5. AUDIT COMMITTEE OF LISTED REGISTRANTS.
(a) The registrant has an audit committee which was established by the Board of Trustees of the registrant in accordance with Section 3(a)(58)(A) of the Securities Exchange Act of 1934, as amended. Each of the registrant's Trustees serves as a member of its Audit Committee.
(b) Not applicable.
ITEM 6. INVESTMENTS.
(a) The Registrant's Schedule of Investments is included as part of the Financial Statements and Financial Highlights filed under Item 7 of this Form.
(b) Not applicable.
ITEM 7. FINANCIAL STATEMENTS AND FINANCIAL HIGHLIGHTS FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES.

FINANCIAL STATEMENTS

AND OTHER INFORMATION

Year Ended August 31, 2025

BRENDAN WOOD TOPGUN ETF

1

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Schedule of InvestmentsAugust 31, 2025

See Notes to Financial Statements

Shares

Value

98.97%

COMMON STOCKS

10.63%

COMMUNICATION SERVICES

Alphabet, Inc. Class C

3,161

$674,968

Meta Platforms, Inc.

565

417,365

T-Mobile US, Inc.

2,746

691,964

1,784,297

7.45%

CONSUMER DISCRETIONARY

Amazon.com, Inc.(A)

2,711

620,819

Home Depot, Inc.

1,547

629,273

1,250,092

3.66%

CONSUMER STAPLES

Costco Wholesale Corp.

652

615,045

24.78%

FINANCIALS

Brookfield Corp. ADR

10,493

689,600

JPMorgan Chase & Co.

2,538

765,004

Mastercard, Inc. Class A

1,145

681,607

The Progressive Corp

2,505

618,885

Royal Bank of Canada ADR

5,040

732,614

Visa, Inc. Class A

1,911

672,252

4,159,962

8.03%

HEALTH CARE

Danaher Corp.

2,621

539,454

HCA Healthcare, Inc.

2,002

808,728

1,348,182

15.81%

INDUSTRIALS

Canadian Pacific Kansas City
Southern ADR

8,174

622,777

Parker-Hannifin Corp.

951

722,142

Transdigm Group, Inc.

470

657,474

Waste Connections, Inc. ADR

3,528

652,010

2,654,403

2

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Schedule of Investments - continuedAugust 31, 2025

See Notes to Financial Statements

Shares

Value

12.28%

INFORMATION TECHNOLOGY - HARDWARE

Broadcom, Inc.

2,310

$686,971

Nvidia Corp.

4,369

760,992

Taiwan Semiconductor Manufacturing Co. Ltd. ADR

2,654

612,729

2,060,692

4.35%

INFORMATION TECHNOLOGY - SOFTWARE &

services

Microsoft Corp.

1,440

729,634

11.98%

REAL ESTATE

AvalonBay Communities, Inc. REIT

2,755

539,567

Prologis, Inc. REIT

5,743

653,439

Welltower, Inc. REIT

4,861

818,009

2,011,015

98.97%

TOTAL COMMON STOCKS

(Cost: $13,776,517)

16,613,322

98.97%

TOTAL INVESTMENTS

(Cost: $13,776,517)

16,613,322

1.03%

Other assets, net of liabilities

172,922

100% NET ASSETS $16,786,244

(A)Non-income producing.

ADR - Security represented is held by the custodian in the form of American Depositary Receipts.

REIT - Real Estate Investment Trust.

3

FINANCIAL STATEMENTS | AUGUST 31, 2025

See Notes to Financial Statements

BRENDAN WOOD TOPGUN ETF

Statement of Assets and LiabilitiesAugust 31, 2025

ASSETS

Investments at value (cost of $13,776,517) (Note 1)

$16,613,322

Cash

189,035

Receivable for securities sold

365,768

Dividends recievable

4,844

TOTAL ASSETS

17,172,969

LIABILITIES

Payable for capital stock redeemed

373,047

Accrued net advisory fees

13,678

TOTAL LIABILITIES

386,725

NET ASSETS

$16,786,244

Net Assets Consist of:

Paid-in capital

$14,277,811

Distributable earnings (accumulated deficits)

2,508,433

Net Assets

$16,786,244

NET ASSET VALUE PER SHARE

Shares Outstanding (unlimited number of shares of beneficial interest authorized without par value)

450,000

Net Asset Value and Offering Price Per Share

$37.30

4

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Statement of OperationsYear Ended August 31, 2025

See Notes to Financial Statements

INVESTMENT INCOME

Dividend income (net of foreign tax withheld of $4,351)

$155,003

Total investment income

155,003

EXPENSES

Investment advisory fees (Note 2)

125,014

Investment advisory fees waived (Note 2)

(3,827

)

Net expenses

121,187

Net investment income (loss)

33,816

REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS

Net realized gain (loss) on investments(1)

(58,840

)

Net change in unrealized appreciation (depreciation)
of investments

1,444,828

Net realized and unrealized gain (loss) on investments

1,385,988

INCREASE (DECREASE) IN NET ASSETS FROM OPERATIONS

$1,419,804

(1)Includes realized gains (losses) as a result of in-kind transactions (Note 3).

5

FINANCIAL STATEMENTS | AUGUST 31, 2025

See Notes to Financial Statements

BRENDAN WOOD TOPGUN ETF

Statements of Changes in Net Assets

Year Ended
August 31, 2025

Period Ended
August 31, 2024*

INCREASE (DECREASE) IN NET ASSETS FROM

OPERATIONS

Net investment income (loss)

$33,816

$5,989

Net realized gain (loss) on investments

(58,840

)

(71,221

)

Net change in unrealized appreciation (depreciation) of investments

1,444,828

1,391,977

Increase (decrease) in net assets from operations

1,419,804

1,326,745

DISTRIBUTIONS TO SHAREHOLDERS

Distributions from earnings

(25,905

)

(6,934

)

Return of capital

-

(76

)

Decrease in net assets from distributions

(25,905

)

(7,010

)

CAPITAL STOCK TRANSACTIONS (NOTE 5)

Shares sold

8,645,608

6,146,881

Shares redeemed

(719,879

)

-

Increase (decrease) in net assets from capital stock transactions

7,925,729

6,146,881

NET ASSETS

Increase (decrease) during period

9,319,628

7,466,616

Beginning of period

7,466,616

-

End of period

$16,786,244

$7,466,616

*The Fund commenced operations on November 9, 2023.

6

FINANCIAL STATEMENTS | AUGUST 31, 2025

See Notes to Financial Statements

BRENDAN WOOD TOPGUN ETF

Financial Highlights Selected Per Share Data Throughout Each Period​

Year Ended
August 31, 2025

Period Ended
August 31, 2024*

Net asset value, beginning of period

$33.94

$25.00

Investment activities

Net investment income (loss)(1)

0.09

0.04

Net realized and unrealized gain (loss) on investments

3.35

8.95

Total from investment activities

3.44

8.99

Distributions

Net investment income

(0.08

)

(0.05

)

Return of capital

-

(-)

(2)

Total distributions

(0.08

)

(0.05

)

Net asset value, end of period

$37.30

$33.94

Total Return(3)

10.18

%

36.02

%

Ratios/Supplemental Data

Ratios to average net assets(4)

Expenses, gross

0.98

%

0.98

%

Expenses, net of waiver (Note 2)

0.95

%

0.95

%

Net investment income (loss)

0.26

%

0.14

%

Portfolio turnover rate(5)

21.03

%

24.74

%

Net assets, end of period (000's)

$16,786

$7,467

(1)Per share amounts calculated using the average shares outstanding during the period.

(2)Less than $0.005 per share.

(3)Total return is for the period indicated and has not been annualized for periods less than one year.

(4)Ratios to average net assets have been annualized.

(5)Portfolio turnover rate excludes the effect of securities received or delivered from processing in-kind creations or redemptions, and has not been annualized for periods less than one year.

*The Fund commenced operations on November 9, 2023.

7

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Notes to Financial StatementsAugust 31, 2025

NOTE 1 - ORGANIZATION AND SIGNIFICANT ACCOUNTING POLICIES

The Brendan Wood TopGun ETF (the "Fund") is a non-diversified series of ETF Opportunities Trust, a Delaware statutory trust (the "Trust") which was organized on March 18, 2019, and is registered under the Investment Company Act of 1940, as amended (the "1940 Act"), as an open-end management investment company. The offering of the Fund's shares is registered under the Securities Act of 1933, as amended. The Fund commenced operations on November 9, 2023.

The Fund's investment objective is to seeks to provide growth consistent with the preservation of capital.

The Fund is deemed to be an individual reporting segment and is not part of a consolidated reporting entity. The objective and strategy of the Fund is used by Tuttle Capital Management, LLC (the "Advisor") to make investment decisions, and the results of the Fund's operations, as shown in its Statement of Operations and Financial Highlights, is the information utilized for the day-today operations of the Fund. Due to the significance of oversight and its role in the Fund's management, the Advisor's portfolio manager is deemed to be the Chief Operating Decision Maker.

The following is a summary of significant accounting policies consistently followed by the Fund. The policies are in conformity with accounting principles generally accepted in the United States of America ("GAAP"). The Fund follows the investment company accounting and reporting guidance of the Financial Accounting Standards Board ("FASB") Accounting Standards Codification Topic 946 "Financial Services - Investment Companies".

Security Valuation

The Fund records its investments at fair value. Generally, the Fund's domestic securities (including underlying ETFs which hold portfolio securities primarily listed on foreign (non-U.S.) exchanges) are valued each day at the last quoted sales price on each security's primary exchange. Securities traded or dealt in upon one or more securities exchanges for which market quotations are readily available and not subject to restrictions against resale are valued at the last quoted sales price on the primary exchange or, in the absence of a sale on the primary exchange, at the mean between the current bid and ask prices on such exchange. If market quotations are not readily available, securities are valued at their fair market value as determined in good faith under procedures approved by the Trust's Board of Trustees (the "Board"). Although the Board is ultimately responsible for fair value determinations under Rule 2a-5 of the 1940 Act, the Board has delegated day-to-day responsibility for oversight of the valuation of the Fund's assets to the Advisor as the Valuation Designee pursuant to the Fund's policies and procedures. Securities that are not traded or dealt in any securities exchange (whether domestic or foreign) and for which over-the-counter market quotations are readily available generally are valued at the last sale price or, in the absence of a sale, at the mean between the current bid and ask price on such over-the-counter market.

8

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Notes to Financial Statements - continuedAugust 31, 2025

The Fund has a policy that contemplates the use of fair value pricing to determine the Net Asset Value ("NAV") per share of the Fund when market prices are unavailable as well as under special circumstances, such as: (i) if the primary market for a portfolio security suspends or limits trading or price movements of the security; and (ii) when an event occurs after the close of the exchange on which a portfolio security is principally traded, but prior to the time as of which the Fund's NAV is calculated, that is likely to have changed the value of the security.

When the Fund uses fair value pricing to determine the NAV per share of the Fund, securities will not be priced on the basis of quotations from the primary market in which they are traded, but rather may be priced by another method that the Valuation Designee believes accurately reflects fair value. Any method used will be approved by the Board and results will be monitored to evaluate accuracy. The Fund's policy is intended to result in a calculation of the Fund's NAV that fairly reflects security values as of the time of pricing.

The Fund has adopted fair valuation accounting standards that establish an authoritative definition of fair value and set out a hierarchy for measuring fair value. These standards require additional disclosures about the various inputs used to develop the measurements of fair value. These inputs are summarized in the three broad levels listed below.

Various inputs are used in determining the value of the Fund's investments. GAAP established a three-tier hierarchy of inputs to establish a classification of fair value measurements for disclosure purposes. Level 1 includes quoted prices in active markets for identical securities. Level 2 includes other significant observable market-based inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.). Level 3 includes significant unobservable inputs (including the Fund's own assumptions in determining fair value of investments).

The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities.

9

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Notes to Financial Statements - continuedAugust 31, 2025

The following is a summary of the level of inputs used to value the Fund's investments as of August 31, 2025:

Level 1
Quoted Prices

Level 2
Other Significant Observable Inputs

Level 3
Significant Unobservable Inputs

Total

Common Stocks

$16,613,322

$-

$-

$16,613,322

$16,613,322

$-

$-

$16,613,322

Refer to the Fund's Schedule of Investments for a listing of the securities by type and sector. The Fund held no Level 3 securities at any time during the year ended August 31, 2025.

Security Transactions and Income

Security transactions are accounted for on the trade date. The cost of securities sold is determined generally on specific identification basis. Realized gains and losses from security transactions are determined on the basis of identified cost for book and tax purposes. Dividends are recorded on the ex-dividend date. Interest income is recorded on an accrual basis. Withholding taxes on foreign dividends have been provided for in accordance with the Fund's understanding of the applicable country's tax rules.

Accounting Estimates

In preparing financial statements in conformity with GAAP, management makes estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures of contingent assets and liabilities at the date of the financial statements, as well as the reported amounts of investment income and expenses during the reporting period. Actual results could differ from those estimates.

Federal Income Taxes

The Fund has complied and intends to continue to comply with the requirements of the Internal Revenue Code applicable to regulated investment companies and to distribute all of its taxable income to its shareholders. The Fund also intends to distribute sufficient net investment income and net capital gains, if any, so that it will not be subject to excise tax on undistributed income and gains. Therefore, no federal income tax or excise provision is required.

10

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Notes to Financial Statements - continuedAugust 31, 2025

Management has concluded that no liability for unrecognized tax benefits should be recorded related to uncertain tax positions taken in the Fund's tax returns. The Fund has no examinations in progress and management is not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly change in the next twelve months. Interest and penalties, if any, associated with any federal or state income tax obligations are recorded as income tax expense as incurred.

Reclassification of Capital Accounts

GAAP requires that certain components of net assets relating to permanent differences be reclassified between financial and tax reporting. During the year ended August 31, 2025, such reclassifications were attributable primarily to the tax treatment of redemptions in-kind:

Paid-in Capital

$205,277

Distributable Earnings

(205,277

)

Dividends and Distributions

Dividends from net investment income, if any, are declared and paid at least annually by the Fund. The Fund distributes its net realized capital gains, if any, to shareholders annually. The Fund may also pay a special distribution at the end of a calendar year to comply with federal tax requirements. All distributions are recorded on the ex-dividend date.

Creation Units

The Fund issues and redeems shares to certain institutional investors (typically market makers or other broker-dealers) only in large blocks of at least 10,000 shares known as "Creation Units." Purchasers of Creation Units ("Authorized Participants") will be required to pay to Citibank, N.A. (the "Custodian") a fixed transaction fee ("Creation Transaction Fee") in connection with creation orders that is intended to offset the transfer and other transaction costs associated with the issuance of Creation Units. The standard Creation Transaction Fee will be the same regardless of the number of Creation Units purchased by an investor on the applicable Business Day. The Creation Transaction Fee charged by the Custodian for each creation order is $250. Authorized Participants wishing to redeem shares will be required to pay to the Custodian a fixed transaction fee ("Redemption Transaction Fee") to offset the transfer and other transaction costs associated with the redemption of Creation Units. The standard Redemption Transaction Fee will be the same regardless of the number of Creation Units redeemed by an investor on the applicable Business Day. The Redemption Transaction Fee charged by the Custodian for each redemption order is $250.

11

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Notes to Financial Statements - continuedAugust 31, 2025

Except when aggregated in Creation Units, shares are not redeemable securities. Shares of the Fund may only be purchased or redeemed by Authorized Participants. An Authorized Participant is either (i) a broker-dealer or other participant in the clearing process through the Continuous Net Settlement System of the National Securities Clearing Corporation or (ii) a Depository Trust Company ("DTC") participant and, in each case, must have executed an agreement with the Fund's principal underwriter (the "Distributor") with respect to creations and redemptions of Creation Units ("Participation Agreement"). Most retail investors will not qualify as Authorized Participants or have the resources to buy and sell whole Creation Units. Therefore, they will be unable to purchase or redeem the shares directly from the Fund. Rather, most retail investors will purchase shares in the secondary market with the assistance of a broker and will be subject to customary brokerage commissions or fees. The following table discloses the Creation Unit breakdown based on the NAV as of August 31, 2025:

Creation
Unit Shares

Creation Transaction Fee

Value

BRENDAN WOOD TOPGUN ETF

10,000

$250

$373,000

To the extent contemplated by a participant agreement, in the event an Authorized Participant has submitted a redemption request in proper form but is unable to transfer all or part of the shares comprising a Creation Unit to be redeemed to the Distributor, on behalf of the Fund, by the time as set forth in a participant agreement, the Distributor may nonetheless accept the redemption request in reliance on the undertaking by the Authorized Participant to deliver the missing shares as soon as possible, which undertaking will be secured by the Authorized Participant's delivery and maintenance of collateral equal to a percentage of the value of the missing shares as specified in the participant agreement. A participant agreement may permit the Fund to use such collateral to purchase the missing shares, and could subject an Authorized Participant to liability for any shortfall between the cost of the Fund acquiring such shares and the value of the collateral. Amounts are disclosed as Segregated Cash Balance from Authorized Participants for Deposit Securities and Collateral Payable upon Return of Deposit Securities on the Statement of Assets and Liabilities, when applicable.

Officers and Trustees Indemnification

Under the Trust's organizational documents, its officers and trustees are indemnified against certain liabilities arising out of the performance of their duties to the Fund. In addition, in the normal course of business, the Fund enters into contracts with its vendors and others that provide for general indemnifications. The Fund's maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Fund. However, based on experience, the Fund expects that risk of loss to be remote.

12

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Notes to Financial Statements - continuedAugust 31, 2025

NOTE 2 - INVESTMENT ADVISORY AND DISTRIBUTION AGREEMENTS AND OTHER TRANSACTIONS WITH AFFILIATES

The Advisor currently provides investment advisory services pursuant to an investment advisory agreement (the "Advisory Agreement"). Under the terms of the Advisory Agreement, the Advisor is responsible for the day-to-day management of the Fund's investments. The Advisor also: (i) furnishes office space and all necessary office facilities, equipment and executive personnel necessary for managing the assets of the Fund; and (ii) provides guidance and policy direction in connection with its daily management of the Fund's assets, subject to the authority of the Board. Under the Advisory Agreement, the Adviser assumes and pays, at its own expense and without reimbursement from the Trust, all ordinary expenses of the Fund, except the fee paid to the Adviser pursuant to the Advisory Agreement, distribution fees or expenses under a Rule 12b-1 plan (if any), interest expenses, taxes, acquired fund fees and expenses, brokerage commissions and any other portfolio transaction related expenses and fees arising out of transactions effected on behalf of the Fund, credit facility fees and expenses, including interest expenses, and litigation and indemnification expenses and other extraordinary expenses not incurred in the ordinary course of the Fund's business.

For its services with respect to the Fund, the Advisor is entitled to receive an annual advisory fee of 0.98%, calculated daily and payable monthly as a percentage of the Fund's average daily net assets. The Advisor has contractually agreed to waive its management fee to an annual rate of 0.95% of the average daily net assets of the Fund until December 31, 2025, and the Advisor may not terminate this arrangement prior to that date. The Advisor is not entitled to recover any previously waived fees.

The Advisor has retained Brendan Wood TopGun Partnerships, Inc. (the "Sub-Advisor"), to serve as sub-advisor for the Fund. Pursuant to an Investment Sub-Advisory Agreement between the Advisor and the Sub-Advisor (the "Sub-Advisory Agreement"), the Sub-Advisor assists the Advisor in providing day-to-day management of the Fund's portfolios. For its services, the Sub-Advisor is paid a fee by the Advisor, which is calculated daily and paid monthly, based on the Fund's average daily net assets, at an annual rate of 0.69%.

13

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Notes to Financial Statements - continuedAugust 31, 2025

Fund Administrator

Commonwealth Fund Services, Inc. ("CFS") acts as the Fund's administrator. As administrator, CFS supervises all aspects of the operations of the Fund except those performed by the Advisor and the Sub-Advisor. For its services, fees to CFS are computed daily and paid monthly based on the average daily net assets of the Fund. The Advisor pays these fees monthly.

Custodian

Citibank, N.A. serves as the Fund's Custodian pursuant to a Global Custodial and Agency Services Agreement. For its services, Citibank, N.A. is entitled to a fee. The Advisor pays these fees monthly.

Fund Accountant and Transfer Agent

Citi Fund Services, Ohio, Inc. serves as the Fund's Fund Accountant and Transfer Agent pursuant to a Services Agreement. The Advisor pays these fees monthly.

Distributor

Foreside Fund Services, LLC serves as the Fund's principal underwriter pursuant to an ETF Distribution Agreement. The Advisor pays these fees monthly.

Trustees and Officers

Each Trustee who is not an "interested person" of the Trust receives compensation for their services to the Fund. Each Trustee receives an annual retainer fee, paid quarterly. Trustees are reimbursed for any out-of-pocket expenses incurred in connection with attendance at meetings. The Advisor pays these costs.

Certain officers of the Trust are also officers and/or directors of CFS. Additionally, Practus LLP, serves as legal counsel to the Trust. John H. Lively, Secretary of the Trust, is Managing Partner of Practus LLP. J. Stephen King, Jr., Assistant Secretary of the Trust, is a Partner of Practus LLP. Neither the officers and/or directors of CFS, Mr. Lively or Mr. King receive any special compensation from the Trust or the Fund for serving as officers of the Trust.

The Fund's Chief Compliance Officer and Assistant Chief Compliance Officer are not compensated directly by the Fund for it's service. However, the Assistant Chief Compliance Officer is the Managing Member of Watermark Solutions, LLC ("Watermark"), which provides certain compliance services to the Fund, including the provision of the Chief Compliance Officer and the Assistant Chief Compliance Officer. The Chief Compliance Officer is the Managing Member of Fit Compliance, LLC, which has been retained by Watermark to provide the Chief Compliance Officer's services. The Advisor pays these fees monthly.

14

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Notes to Financial Statements - continuedAugust 31, 2025

NOTE 3 - INVESTMENTS

The costs of purchases and proceeds from the sales of securities, other than in-kind transactions and short-term investments for the year ended August 31, 2025, were as follows:

Purchases

Sales

$2,706,105

$2,653,759

The costs of purchases and proceeds from the sales of in-kind transactions associated with creations and redemptions for the year ended August 31, 2025, were as follows:

Purchases

Sales

Realized Gains

$8,480,626

$706,669

$204,761

NOTE 4 - DISTRIBUTIONS TO SHAREHOLDERS AND TAX COMPONENTS OF CAPITAL

Distributions are determined on a tax basis and may differ from net investment income and realized capital gains for financial reporting purposes. Differences may be permanent or temporary. Permanent differences are reclassified among capital accounts in the financial statements to reflect their tax character. Temporary differences arise when certain items of income, expense, gain or loss are recognized in different periods for financial statement and tax purposes; these differences will reverse at some time in the future. Differences in classification may also result from the treatment of short-term gains as ordinary income for tax purposes. The tax character of distributions paid during the year ended August 31, 2025 and period ended August 31, 2024, were as follows:

Year Ended
August 31, 2025

Period Ended
August 31, 2024

Distributions paid from:

Ordinary income

$25,905

$6,934

Return of capital

-

76

$25,905

$7,010

15

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Notes to Financial Statements - continuedAugust 31, 2025

As of August 31, 2025, the components of distributable earnings (accumulated deficits) on a tax basis were as follows:

Accumulated undistributed net investment income (loss)

$6,966

Other accumulated losses

(335,723

)

Net unrealized appreciation (depreciation) on investments

2,837,190

$2,508,433

As of August 31, 2025, the Fund had a capital loss carryforward of $335,723, of which $275,561 is considered short-term and $60,162 is considered long-term. This loss may be carried forward indefinitely.

Cost of securities for Federal Income tax purpose and the related tax-based net unrealized appreciation (depreciation) consists of:

Cost

Gross Unrealized Appreciation

Gross Unrealized Depreciation

Total Unrealized Appreciation (Depreciation)

$13,776,132

$2,936,810

$(99,620)

$2,837,190

The difference between book basis and tax basis accumulated appreciation (depreciation) is attributable primarily to the return of capital basis adjustments.

NOTE 5 - TRANSACTIONS IN SHARES OF BENEFICIAL INTEREST

Shares of the Fund are listed for trading on the Cboe BZX Exchange (the "Exchange") and trade at market prices rather than at NAV. Shares of the Fund may trade at a price that is greater than, at, or less than NAV. The Fund will issue and redeem shares at NAV only in large blocks of 10,000 shares (each block of shares is called a "Creation Unit"). Creation Units are issued and redeemed for cash and/or in-kind for securities. Individual shares may only be purchased and sold in secondary market transactions through brokers. Except when aggregated in Creation Units, the shares are not redeemable securities of the Fund.

All orders to create Creation Units must be placed with the Fund's distributor or transfer agent either (1) through the Continuous Net Settlement System of the NSCC ("Clearing Process"), a clearing agency that is registered with the Securities and Exchange Commission ("SEC"), by a "Participating Party," i.e., a broker-dealer or other participant in the Clearing Process; or (2) outside the Clearing Process by a DTC Participant. In each case, the Participating Party or the DTC Participant must have executed an agreement with the Distributor with respect to creations and redemptions of Creation Units ("Participation Agreement"); such parties are collectively referred to as "APs" or "Authorized Participants." Investors should contact the Distributor for the names of Authorized Participants. All Fund shares, whether created through or outside the Clearing Process, will be entered on the records of DTC for the account of a DTC Participant.

16

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Notes to Financial Statements - continuedAugust 31, 2025

Shares of beneficial interest transactions for the Fund were:

Year Ended
August 31, 2025

Period Ended
August 31, 2024

Shares sold

250,000

220,000

Shares redeemed

(20,000

)

-

Net increase (decrease)

230,000

220,000

NOTE 6 - RISKS OF INVESTING IN THE FUND

It is important that you closely review and understand the risks of investing in the Fund. The Fund's NAV and investment return will fluctuate based upon changes in the value of its portfolio securities. You could lose money on your investment in the Fund, and the Fund could underperform other investments. There is no guarantee that the Fund will meet its investment objective. An investment in the Fund is not a deposit of a bank and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. A complete description of the principal risks is included in the Fund's prospectus under the heading "Principal Risks."

NOTE 7 - SUBSEQUENT EVENTS

Management has evaluated all transactions and events subsequent to the date of the Statement of Assets and Liabilities through the date on which these financial statements were issued. Except as already included in the notes to these financial statements, no additional items require disclosure.

17

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Report of Independent Registered Public Accounting Firm

To the Shareholders of Brendan Wood TopGun ETF and Board of Trustees of ETF Opportunities Trust

Opinion on the Financial Statements

We have audited the accompanying statement of assets and liabilities, including the schedule of investments, of Brendan Wood TopGun ETF (the "Fund"), a series of ETF Opportunities Trust, as of August 31, 2025, the related statement of operations for the year then ended, the statements of changes in net assets and the financial highlights for the year ended August 31, 2025 and for the period November 9, 2023 (commencement of operations) through August 31, 2024, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Fund as of August 31, 2025, the results of its operations for the year then ended, the changes in net assets and the financial highlights for year ended August 31, 2025 and for the period November 9, 2023 (commencement of operations) through August 31, 2024, in conformity with accounting principles generally accepted in the United States of America.

Basis for Opinion

These financial statements are the responsibility of the Fund's management. Our responsibility is to express an opinion on the Fund's financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and are required to be independent with respect to the Fund in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement whether due to error or fraud.

Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our procedures included confirmation of securities owned as of August 31, 2025, by correspondence with the custodian and broker; when replies were not received from brokers, we performed other auditing procedures. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

We have served as the auditor of one or more investment companies advised by Tuttle Capital Management, LLC since 2019.

COHEN & COMPANY, LTD.
Cleveland, Ohio
October 30, 2025

18

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Supplemental Information

Changes in and disagreements with accountants for open-end management investment companies.

Not applicable.

Proxy disclosures for open-end management investment companies.

Not applicable.

Remuneration paid to Directors, Officers, and others of open-end management investment companies.

Because Tuttle Capital Management, LLC (the "Advisor") has agreed in the Investment Advisory Agreement to cover all operating expenses of the Funds, subject to certain exclusions as provided for therein, the Advisor pays the compensation to each Independent Trustee and the Chief Compliance Officer for services to the Fund from the Advisor's management fees.

Statement Regarding Basis for Approval of Investment Advisory Contract.

At a meeting held on June 18-19, 2025 (the "Meeting"), the Board considered the continuation of the Investment Advisory Agreement (the "Tuttle Advisory Agreement") between the Trust, with respect to the Brendan Wood TopGun ETF (the "Fund"), and Tuttle Capital Management, LLC ("Tuttle," or the "Adviser"), and the Investment Sub-Advisory Agreement (the "Sub-Advisory Agreement") between Tuttle, Brendan Wood TopGun Partnerships Inc. ("Brendan Wood"), and the Trust, with respect to the Fund. The Board reflected on its discussions with the representatives from Tuttle and Brendan Wood earlier in the Meeting regarding the manner in which the Fund is managed and the roles and responsibilities of Tuttle and Brendan Wood under the Tuttle Advisory Agreement and Sub-Advisory Agreement (collectively, the "Advisory Agreements").

Counsel to the Trust ("Counsel") referred the Board to the board materials that included a memorandum from Counsel that addressed the Trustees' duties when considering the approval of the Advisory Agreements and the responses of Tuttle and Brendan Wood to requests for information from Counsel on behalf of the Board. Counsel noted that the responses included information on the personnel of and services to be provided by Tuttle and Brendan Wood, an expense comparison analysis for the Fund and comparable ETFs, and the Advisory Agreements. Counsel discussed the types of information and factors that should be considered by the Board in order to make an informed decision regarding the approval of the continuation of the Advisory Agreements, including

19

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Supplemental Information - continuedAugust 31, 2025

the following material factors: (i) the nature, extent, and quality of the services provided by Tuttle and Brendan Wood; (ii) the investment performance of the Fund; (iii) the costs of the services provided and profits to be realized by Tuttle and Brendan Wood from the relationship with the Fund; (iv) the extent to which economies of scale would be realized if the Fund grows and whether advisory fee levels reflect those economies of scale for the benefit of its investors; and (v) possible conflicts of interest and other benefits.

In assessing these factors and reaching its decisions, the Board took into consideration information specifically prepared or presented at this Meeting. The Board requested or was provided with information and reports relevant to the approval of the Advisory Agreements, including: (i) information regarding the services and support provided by Tuttle and by Brendan Wood to the Fund and its shareholders; (ii) presentations by management of Tuttle and Brendan Wood addressing the investment philosophy, investment strategy, personnel and operations utilized in managing the Fund; (iii) information pertaining to the compliance structure of Tuttle and Brendan Wood; (iv) disclosure information contained in the Fund's registration statement and each firm's Form ADV and/or the policies and procedures of each firm; and (v) the memorandum from Counsel that summarized the fiduciary duties and responsibilities of the Board in reviewing and approving the Advisory Agreements, including the material factors set forth above and the types of information included in each factor that should be considered by the Board in order to make an informed decision.

Counsel reminded the Board that it also requested and received various informational materials including, without limitation: (i) documents containing information about Tuttle and Brendan Wood, including financial information, personnel and the services provided by Tuttle and by Brendan Wood to the Fund, each firm's compliance program, current legal matters, and other general information; (ii) the Fund's expenses and comparative expense information for other ETFs with strategies similar to the Fund prepared by an independent third party; (iii) the anticipated effect of size on the Fund's performance and expenses; and (iv) benefits to be realized by Tuttle and Brendan Wood from their relationship with the Fund.

The Board did not identify any particular information that was most relevant to its consideration to approve the Advisory Agreements and each Trustee may have afforded different weight to the various factors. In deciding whether to approve the Advisory Agreements, the Trustees considered numerous factors, including:

20

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Supplemental Information - continuedAugust 31, 2025

The nature, extent, and quality of the services provided by Tuttle and Brendan Wood.

In this regard, the Board considered the responsibilities of Tuttle and Brendan Wood under the Advisory Agreements. The Board reviewed the services provided by Tuttle and Brendan Wood to the Fund, including, without limitation, Brendan Wood's process for constructing a model portfolio, the processes of Tuttle and Brendan Wood for assuring compliance with the Fund's investment objectives and limitations; Tuttle's processes for trade execution and broker-dealer selection for portfolio transactions; the coordination of services by Tuttle for the Fund among the service providers; and the efforts of Tuttle to promote the Fund and grow its assets. The Board considered: the staffing, personnel, and methods of operating of Tuttle and Brendan Wood; the education and experience of each firm's personnel; and information provided regarding each firm's compliance program and policies and procedures. After reviewing the foregoing and further information from Tuttle and Brendan Wood, the Board concluded that the quality, extent, and nature of the services provided by Tuttle and Brendan Wood, was satisfactory and adequate for the Fund.

The investment performance of Tuttle and Brendan Wood.

The Board reviewed the Fund's performance. In considering the investment performance of the Fund, the Trustees compared the performance of the Fund with the performance of its benchmark index, the Russell 1000 Growth TR Index, funds in its Morningstar category, Large Growth ("Category"), and a peer group selected from its Category ("Peer Group"). The Trustees noted that the Fund outperformed the Russell 1000 Growth TR Index, the median of funds in its Category and the median of funds in its Peer Group for the one-year period ended March 31, 2025. In addition, the Trustees considered Tuttle's experience in managing swap-based ETFs and Brendan Wood's experience in constructing indexes using a similar methodology as that used to create the model portfolio for the Fund. After a detailed discussion of the Fund's performance, the Board concluded, in light of all the facts and circumstances, that the investment performance of the Fund was satisfactory.

The costs of services to be provided and profits realized by Tuttle and Brendan Wood from the relationship with the Fund.

In this regard, the Board considered the financial condition of Tuttle and the level of commitment to the Fund by Tuttle as well as from Brendan Wood. The Board also considered the assets and expenses of the Fund, including the nature

21

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Supplemental Information - continuedAugust 31, 2025

and frequency of advisory payments. The Trustees noted the information on profitability provided by Tuttle and Brendan Wood. The Trustees considered the unitary fee structure of the Advisory Agreement and the Adviser's contractual agreement to waive a portion of its advisory fee for the Fund such that the net advisory fee (after waiver) will be reduced from 0.98% to 0.95% of the Fund's average daily net assets through December 31, 2025. The Board compared the unitary fee of the Fund to the fees of funds in the Category and Peer Group. The Trustees noted that the gross and net expense ratio and gross and net advisory fee of the Fund were higher than the median of the Peer Group and the Category. The Trustees acknowledged Tuttle's representation that the advisory fees are appropriate and competitively priced for an actively managed fund that requires unique services such as those provided by Tuttle. The Trustees also noted that Tuttle does not manage any separate accounts with strategies similar to those of the Fund. The Trustees also considered the split of the advisory fees paid to Tuttle versus those paid to Brendan Wood and the respective services provided by each to the Fund. After further consideration, the Board concluded that the profitability and fees to be paid to Tuttle were within an acceptable range in light of the services to be rendered by Tuttle.

The extent to which economies of scale would be realized as the Fund grows and whether advisory fee levels reflect these economies of scale for the benefit of the Fund's investors.

The Trustees considered that the Fund is not of sufficient size to achieve economies of scale. The Board noted that the unitary fee structure limits the shareholders' exposure to underlying operating expense increases.

Possible conflicts of interest and other benefits.

In evaluating the possibility for conflicts of interest, the Board considered such matters as: the experience and ability of the advisory personnel assigned to the Fund; the basis of decisions to buy or sell securities for the Fund; and the substance and administration of the Code of Ethics and other relevant policies of Tuttle and Brendan Wood. The Board noted that Tuttle and Brendan Wood have each represented that it has not and does not anticipate utilizing soft dollars or commission recapture with regard to the Fund. The Board also considered potential benefits for Tuttle and Brendan Wood in managing the Fund. Following further consideration and discussion, the Board concluded that the standards and practices of Tuttle and Brendan Wood relating to the identification and mitigation of potential conflicts of interest, as well as the benefits to be derived by Tuttle and by Brendan Wood from managing the Fund were satisfactory.

22

FINANCIAL STATEMENTS | AUGUST 31, 2025

BRENDAN WOOD TOPGUN ETF

Supplemental Information - continuedAugust 31, 2025

After additional consideration of the factors delineated in the memorandum provided by Trust Counsel and further discussion and careful review by the Trustees, the Board determined that the compensation payable under the Advisory Agreements was fair, reasonable and within a range of what could have been negotiated at arms-length in light of all the surrounding circumstances, and they approved the continuation of the Advisory Agreements for another one-year period.

ITEM 8. CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES.

Not applicable.

ITEM 9. PROXY DISCLOSURES FOR OPEN-END MANAGEMENT INVESTMENT COMPANIES.

Not applicable.

ITEM 10. REMUNERATION PAID TO DIRECTORS, OFFICERS, AND OTHERS OF OPEN-END MANAGEMENT INVESTMENT COMPANIES.

Reference Item 7 which includes remuneration paid to the Trustees and Officers in the Supplemental Information.

ITEM 11. STATEMENT REGARDING BASIS FOR APPROVAL OF INVESTMENT ADVISORY CONTRACT.

Reference Item 7 which includes investment advisory contract renewal in the Supplemental Information.

ITEM 12. DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

Not applicable because it is not a closed-end management investment company.

ITEM 13. PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

Not applicable because it is not a closed-end management investment company.

ITEM 14. PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS.

Not applicable because it is not a closed-end management investment company.

ITEM 15. SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS.

There have been no material changes to the procedures by which shareholders may recommend nominees to the registrant's board of trustees.

ITME 16. CONTROLS AND PROCEDURES.

(a) The registrant's principal executive and principal financial officers, or persons performing similar functions, have concluded that the registrant's disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940, as amended (the "1940 Act") (17 CFR 270.30a-3(c))) are effective, as of a date within 90 days of the filing date of the report that includes the disclosure required by this paragraph, based on their evaluation of these controls and procedures required by Rule 30a-3(b) under the 1940 Act (17 CFR 270.30a-3(b)) and Rules 13a-15(b) or 15d-15(b) under the Securities Exchange Act of 1934, as amended (17 CFR 240.13a-15(b) or 240.15d- 15(b)).

(b) There were no changes in the registrant's internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act (17 CFR 270.30a-3(d)) that occurred during the period covered by this report that have materially affected, or are reasonably likely to materially affect, the registrant's internal control over financial reporting.

ITEM 17. DISCLOSURE OF SECURITIES LENDING ACTIVITIES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

Not applicable because it is not a closed-end management investment company.

ITEM 18. RECOVERY OF ERRONEOUSLY AWARDED COMPENSATION.

Not applicable.

ITEM 19. EXHIBITS.
(a)(1) Code of Ethics in response to Item 2 of this Form N-CSR is attached hereto.
(a)(2) Any policy required by the listing standards adopted pursuant to Rule 10D-1 under the Exchange Act of 1934 - Not applicable.
(a)(3) Certifications pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto.

(a)(3)(1) Any written solicitation to purchase securities under Rule 23c-1 under the Investment Company Act of 1940 - Not applicable.

(a)(3)(2) Change in the registrant's independent public accountant - Not applicable.

(b) Certifications pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 are attached hereto.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Registrant: ETF Opportunities Trust

By (Signature and Title)*: /s/ Karen Shupe

Karen Shupe

Principal Executive Officer

Date: November 5, 2025

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

By (Signature and Title)*: /s/ Karen Shupe

Karen Shupe

Principal Executive Officer

Date: November 5, 2025
By (Signature and Title)*: /s/ Ann MacDonald

Ann MacDonald

Principal Financial Officer

Date: November 5, 2025

* Print the name and title of each signing officer under his or her signature.

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