CBLS
1. Summary
- CBLS is an actively managed, fundamental long/short equity ETF. It picks stocks around macro and thematic ideas, holds 30 to 50 longs and 10 to 50 shorts, and targets net long exposure of 30% to 70%.
- It runs well under 2.0x gross. On September 30, 2026 it was 89.68% long and 38.79% short, or 128.47% gross and 50.89% net.
- It shorts stocks directly through an unnamed broker. It also uses single-stock options and index futures to hedge and add exposure. No swaps are described.
- Most relevant for us: CBLS shows its short costs openly. Dividends, interest and borrowing expense on shorts were 0.54% of average net assets in fiscal 2025, on top of a 1.35% unitary fee. But it gives no precedent for gross above 2.0x, and it doesn't name its broker or margin type.
2. Key facts
| Item | Detail | Source |
|---|---|---|
| Name and ticker | Clough Hedged Equity ETF (CBLS) | CBLS-FS, page 1, header and "ETF Information" |
| Exchange | NYSE Arca, Inc. The fact sheet says only "a NYSE listed ETF". | CBLS-PR, page 1, cover; CBLS-SAI, page 4, cover; CBLS-FS, page 2, "Disclosures" |
| CUSIP | 210322806 | CBLS-FS, page 1, "ETF Information" |
| Inception date | November 13, 2020 (fact sheet). Conflict: the prospectus says the predecessor fund "commenced operations on November 12, 2020," and its returns table uses "Since Inception 11/12/20". | CBLS-FS, page 1, "ETF Information"; CBLS-PR, page 30, "Financial Highlights" footnote (b); CBLS-PR, page 9, "Average Annual Total Returns" |
| Trust | A series of Elevation Series Trust, a Delaware statutory trust organized March 7, 2022. The SAI says the trust has "seven investment series." A later supplement (June 26, 2026) counts "all series of the Trust (38 funds)" in the fund complex. Trustees and officers use the address "c/o Paralel Technologies LLC." So it is a multi-client series trust run with Paralel (my inference). | CBLS-SAI, page 6, "General Description of the Trust and the Funds"; CBLS-SAI, page 1, supplement |
| Fiscal year end | October 31 | CBLS-PR, page 3, "Portfolio Turnover"; CBLS-PR, page 30, "Financial Highlights" |
| Net assets and NAV | $56.70 million net assets; NAV $31.15; market price $31.16; premium 0.03%; 1,820,000 shares outstanding. All as of September 30, 2026. Shares times NAV gives $56.69 million (my arithmetic). | CBLS-FS, page 1, "ETF Information" |
| Morningstar category and rating | Equity Hedged. As of September 30, 2026: 3-star overall, 4-star 3-year, 2-star 5-year, out of 140, 140 and 120 funds. | CBLS-FS, page 1, Morningstar box and "Peer Group Performance" |
| Number of long and short positions | 35 long and 39 short on September 30, 2026. Stated range: "30 to 50 long positions and 10 to 50 short positions." | CBLS-FS, page 1, "Portfolio Characteristics"; CBLS-PR, page 5, "Principal Investment Strategies of the Fund" |
| Distribution frequency | Dividends and capital gains "at least annually" | CBLS-PR, page 25, "Dividends and Distributions" |
| Creations and redemptions | "in exchange for a portfolio of securities and/or a designated amount of U.S. cash." The SAI says redemptions are "primarily for a basket of Deposit Securities together with a Cash Component." So mainly in kind (my inference). Creation Unit is generally 10,000 shares. | CBLS-PR, page 10, "Purchase and Sale of Shares"; CBLS-SAI, page 6, "General Description of the Trust and the Funds" |
Other trading data as of September 30, 2026: median 30-day bid/ask spread 0.23% (CBLS-FS, page 1, "ETF Information").
3. Service providers
| Role | Firm | Source |
|---|---|---|
| Adviser | Clough Capital Partners L.P., Boston. About $1.4 billion in assets under management at December 31, 2025. Controlled by Chuck Clough. | CBLS-PR, page 23, "Investment Adviser"; CBLS-SAI, page 23, "Investment Adviser" |
| Sub-adviser | Not stated. The SAI contents list "Investment Adviser and Sub-Advisers," but the section names none. | CBLS-SAI, page 5, contents; CBLS-SAI, page 23 |
| Portfolio managers | Vincent Lorusso, portfolio manager since inception in November 2020. The fact sheet also shows Chuck Clough as Chief Investment Officer. | CBLS-PR, page 10, "Management"; CBLS-PR, page 24, "Portfolio Manager"; CBLS-FS, page 1 |
| Administrator | Paralel Technologies LLC (parent of the distributor) | CBLS-SAI, page 25, "The Administrator, Custodian, and Transfer Agent"; CBLS-PR, page 33 |
| Fund accountant | Paralel Technologies LLC | CBLS-SAI, page 25; CBLS-PR, page 33 |
| Custodian | State Street Bank and Trust Company | CBLS-SAI, page 26, "The Administrator, Custodian, and Transfer Agent"; CBLS-PR, page 33 |
| Transfer agent | State Street Bank and Trust Company | CBLS-SAI, page 26; CBLS-PR, page 33 |
| Distributor | Paralel Distributors LLC | CBLS-SAI, page 25, "The Distributor"; CBLS-FS, page 2, "Disclosures" |
| Auditor | Cohen & Company, Ltd. | CBLS-SAI, page 26, "Independent Registered Public Accounting Firm"; CBLS-PR, page 29 |
| Prime broker | Not stated. The prospectus says only "a broker." | CBLS-PR, page 17, "Additional Information About the Funds" |
| Swap counterparties | Not stated (no swaps described in the strategy) | |
| Securities lending agent | Not stated | CBLS-SAI, page 15, "Securities Lending" |
4. Strategy
- Objective and benchmark. The fund "seeks long-term capital appreciation while minimizing volatility" (CBLS-PR, page 3, "Investment Objective"). The primary index is the Bloomberg World All-Cap Equal Weight TR Index. The secondary index is a 50/50 blend of that index and the Bloomberg US Treasury 0-1 Year index (CBLS-PR, page 9, "Performance"; CBLS-FS, page 1, "ETF Information").
- Universe.
- The prospectus says the fund "primarily invests in U.S.-listed equity securities and sponsored depositary receipts" (CBLS-PR, page 4, "Principal Investment Strategies of the Fund"). It reaches emerging markets through U.S.-listed securities (CBLS-PR, page 4).
- The fact sheet describes "long and short global equity positions" (CBLS-FS, page 1, "Strategy Overview"). On September 30, 2026, North America was 81.95% long and -36.77% short (CBLS-FS, page 2, "Geographic Exposure").
- All market caps. On September 30, 2026, large caps were 68.96% long and -27.45% short (CBLS-FS, page 2, "Market Capitalization Exposure").
- No fixed sector weights: the fund "does not adhere to strict sector weighting parameters" (CBLS-PR, page 5).
- How it picks stocks. Fundamental. The adviser starts from macro and "global investment themes," then does "bottom-up research to find specific companies" (CBLS-PR, page 4). It screens for quality, value and growth measures such as return on invested capital and price to earnings (CBLS-PR, pages 3 and 4). It also manages the fund in a "tax-aware manner" (CBLS-PR, page 4).
- Neutrality targets. None. The fund aims for lower volatility than the broader market, not beta, dollar or sector neutrality (CBLS-PR, page 4).
- Net exposure. "The Fund generally maintains a net long exposure of between 30%-70% of its net assets" (CBLS-PR, page 5). It was 50.89% on September 30, 2026 (CBLS-FS, page 1, "Portfolio Characteristics").
- Limits on position size.
- No numeric limit is stated.
- The fund is "diversified" under the 40 Act. On 75% of total assets, it may not put more than 5% in one issuer (CBLS-SAI, page 6, "Diversification").
- Fundamental policy bars more than 25% of total assets in one industry (CBLS-SAI, page 16, "Investment Restrictions").
- On September 30, 2026 the largest long was 3.40% (Crowdstrike) and the largest short was -1.38% (Trade Desk) (CBLS-FS, page 2, "Top 15 Long Positions" and "Top 10 Short Positions").
5. Exposure and leverage
- Measured exposure, September 30, 2026 (CBLS-FS, page 1, "Portfolio Characteristics"):
- Long 89.68%, short -38.79%, gross 128.47%, net 50.89%.
- These are "calculated as a % of net assets and excludes cash positions." The fact sheet doesn't say whether options and futures are included, or on what basis.
- Top 15 longs total 40.12%. Top 10 shorts total -12.13% (my arithmetic).
- Stated targets or limits.
- Net long 30% to 70% (CBLS-PR, page 5).
- The fact sheet repeats this and adds "hedging within exposure limits" (CBLS-FS, page 2, "CBLS Portfolio Construction").
- No gross, long or short limit is stated.
- How it gets exposure above 100%. It doesn't, on the measured figures. Long exposure was below 100% (my inference). The prospectus says options and index futures can gain exposure "without directly buying or selling the underlying securities" (CBLS-PR, page 5). Options and futures strategies "are not used to replace the core equity portfolio" (CBLS-PR, page 5).
- Borrowing limits. "Although the Funds do not intend to borrow money," a fund "may borrow up to one-third (1/3) of its total assets," only "for short-term or emergency purposes" (CBLS-SAI, page 7, "Borrowing"). One-third of total assets equals 300% asset coverage (my inference). No line of credit is named. The SAI mentions a line of credit fee only as a possible borrowing cost (CBLS-SAI, page 7).
6. Shorting, financing and collateral
- How it shorts. A mix (my inference):
- Direct short sales: "the Fund arranges through a broker to borrow the security it does not own" (CBLS-PR, page 17, "Additional Information About the Funds"). The SAI says CBLS "intends to" engage in short sales (CBLS-SAI, page 15, "Short Sales").
- Single-stock options: the fund buys puts or writes calls "on securities it believes are overvalued" (CBLS-PR, page 5).
- Index futures, for hedging: "buying or selling an index future when the broader market appears to be overbought" (CBLS-PR, page 5).
- No split between methods is given. All ten top shorts on the fact sheet are single stocks (CBLS-FS, page 2).
- Who lends the stock and who holds collateral. An unnamed broker. "The broker effecting the short sale typically holds the proceeds as part of the collateral securing the Fund's obligation to cover the short position" (CBLS-PR, page 17).
- What is posted.
- The fund will "designate on its records as collateral cash or liquid assets." The designated assets "plus any amount deposited with the broker" must equal the value of the shorts, marked to market daily (CBLS-SAI, page 15, "Short Sales").
- Whether long stocks are pledged to the broker is not stated.
- This is older asset segregation wording. The same SAI also describes Rule 18f-4 (CBLS-SAI, page 8). So the wording may predate the rule (my inference).
- Short sale proceeds used to buy longs. Not stated. The proceeds are held by the broker as collateral (CBLS-PR, page 17). With longs under 100% of net assets, the fund doesn't need short proceeds to fund its longs (my inference).
- Segregated or tri-party account. None named. Written covered calls are "earmarked on the books of the Fund as segregated" (CBLS-SAI, page 10).
- Margin. The fact sheet's cost line is "Margin Interest & Dividends on Short Sales" (CBLS-FS, page 1, "ETF Expenses"). That is the only mention of margin interest. Margin type (Reg T or portfolio margin) is not stated.
- Securities lending. Permitted: each fund "may lend portfolio securities in an amount up to one-third of its total assets" (CBLS-SAI, page 15, "Securities Lending"). The adviser pays for "securities lending" services out of the unitary fee (CBLS-PR, page 23). The documents don't say whether CBLS actually lends.
- Permitted only. Repurchase agreements, money market instruments, rights and warrants, REITs, and other ETFs, including leveraged and inverse ETFs (CBLS-SAI, pages 12 to 14). None is a principal strategy.
7. Derivatives and Rule 18f-4
- Derivatives used.
- Principal strategy: options on individual securities, and "futures contracts on stock indices" (CBLS-PR, page 5).
- Option and futures holdings are "generally less than two years" in duration (CBLS-PR, page 5).
- Mostly exchange-traded options (CBLS-PR, page 21, "Options Risk"). The same risk text mentions "an over-the-counter options transaction" (CBLS-PR, page 21).
- The SAI lists swaps and forwards as examples of derivatives (CBLS-SAI, page 8, "Derivative Instruments"). Neither is in the principal strategy.
- Short sales: the SAI doesn't say whether it treats them as derivatives under Rule 18f-4.
- Limited derivatives user or full program. Not stated. The SAI only describes the rule in general: funds above "a limited specified exposure amount" must keep a risk management program and "appoint a derivatives risk manager" (CBLS-SAI, page 8). It doesn't say which applies to CBLS. No risk manager is named.
- VaR test and reference portfolio. Not stated. VaR (value at risk) estimates the most a fund could lose over a set period at a set confidence level.
- Commodity pool status (CFTC Rule 4.5). Not stated. The fundamental policy on commodities "shall not prevent the Funds from purchasing or selling options and futures contracts" (CBLS-SAI, page 17, "Investment Restrictions").
8. Costs
| Item | Amount | Source |
|---|---|---|
| Management fee | 1.35%. Unitary: the adviser pays "substantially all expenses" except listed items. Was 1.70% until February 29, 2024. | CBLS-PR, page 3, fee table; CBLS-PR, page 23, "Investment Adviser" |
| Other expenses | 0.54%. "'Other Expenses' include dividends, interest and borrowing expense on securities sold short." | CBLS-PR, page 3, fee table and footnote 1 |
| Dividend and interest expense on short sales | 0.54% combined with borrowing expense, fiscal year ended October 31, 2025. Earlier years: 0.54% (2024), 1.23% (2023), 0.78% (2022), 0.44% annualized (2021). | CBLS-PR, page 30, "Financial Highlights" |
| Borrowing costs | Included in the 0.54% above. No separate figure. | CBLS-PR, page 3, footnote 1 |
| Acquired fund fees | 0.00% | CBLS-FS, page 1, "ETF Expenses" (no line in CBLS-PR fee table) |
| Gross and net expense ratio | 1.89% and 1.89% (no waiver) | CBLS-PR, page 3; CBLS-FS, page 1 |
| Fee waivers or caps | None stated. No 12b-1 fee will be paid in the 12 months from the prospectus date (February 27, 2026). | CBLS-PR, page 3, footnote 2 |
| Stated financing spreads or rates | Not stated | |
| Where financing costs are reported | In the expense ratio, as part of "Other Expenses," lumped with short dividends | CBLS-PR, page 3; CBLS-PR, page 30 |
- Who pays what.
- The adviser pays transfer agency, custody, administration, securities lending and other services out of the unitary fee (CBLS-PR, page 23).
- The fund pays the rest. That includes "interest charges on any borrowings, dividends and other expenses on securities sold short," taxes, brokerage commissions, acquired fund fees, 12b-1 fees and extraordinary expenses (CBLS-PR, page 23).
- The adviser pays the administrator and custodian directly (CBLS-SAI, page 26).
- Advisory fees paid were $574,977 (2025), $277,582 (2024) and $90,798 (2023). The SAI labels the 2025 figure "Predecessor" too (CBLS-SAI, page 23).
- Expense example. $192 for 1 year, $594 for 3 years, $1,021 for 5 years and $2,209 for 10 years per $10,000 (CBLS-PR, page 3).
- Brokerage commissions (CBLS-SAI, page 28, "Brokerage Transactions"):
- $545,407 in fiscal 2025, $360,738 in 2024 and $114,353 in 2023. The rise came with higher turnover.
- In fiscal 2025, $108,315 of commissions went to brokers for research services (CBLS-SAI, page 29).
- The 2025 advisory fee at 1.35% implies average net assets of about $42.6 million. On that base, commissions were about 1.28% of average net assets (my arithmetic). Commissions sit outside the expense ratio (CBLS-PR, page 3, "Portfolio Turnover").
- Portfolio turnover. 719% (2025), 509% (2024), 784% (2023), 379% (2022) and 160% (2021) (CBLS-PR, page 30). This excludes in-kind transactions.
- Gap between total expense ratio and management fee. 1.89% minus 1.35% is 0.54% (my arithmetic). The gap is entirely the short sale line: dividends, interest and borrowing expense. The documents don't split it among those three.
9. Performance and risk
Returns from the fact sheet, as of September 30, 2026. Periods over one year are annualized (CBLS-FS, page 1, "Performance Summary"). The fact sheet prints this table twice with the same figures.
| Period | NAV | Market price | World All-Cap Index | 50/50 Index | Morningstar Equity Hedged average |
|---|---|---|---|---|---|
| 3 months | -8.50% | -8.50% | -1.13% | -0.11% | 0.50% |
| Year to date | 13.30% | 13.33% | 7.45% | 5.24% | 8.15% |
| 1 year | 9.37% | 9.36% | 9.17% | 6.57% | 9.64% |
| 3 years | 18.65% | 18.68% | 14.75% | 9.56% | 12.95% |
| 5 years | 4.04% | 4.03% | 5.22% | 4.57% | 8.27% |
| Since inception | 8.20% | 8.21% | 8.59% | 5.98% | 8.62% |
Morningstar rank percentile: 50% (1 year), 11% (3 years), 80% (5 years), 44% (since inception) (CBLS-FS, page 1).
- Calendar-year returns (CBLS-PR, page 9, bar chart, read from the page image): 2021 3.01%, 2022 -11.57%, 2023 -2.78%, 2024 28.45%, 2025 6.08%.
- Best and worst quarters. Best 14.01% (quarter ended March 31, 2021). Worst -14.07% (quarter ended June 30, 2022) (CBLS-PR, page 9).
- Average annual returns to December 31, 2025, before taxes (CBLS-PR, page 9):
- Fund: 6.08% (1 year), 3.83% (5 years), 6.82% (since November 12, 2020).
- World All-Cap Index: 21.47%, 6.18% and 8.38%.
- 50/50 index: 12.44%, 4.76% and 5.83%.
- Fiscal-year NAV returns (CBLS-PR, page 30): 13.21% (2025), 34.77% (2024), -19.46% (2023), -10.95% (2022), 31.06% (2021, from November 12, 2020, not annualized).
- Risk statistics. None given: no beta, correlation, volatility, Sharpe ratio, drawdown or capture figures.
- Note. The fund's aim is to minimize volatility. But the -8.50% quarter to September 30, 2026 compares with -1.13% for the equity index (my inference that this cuts against the aim; one quarter only).
10. History and structural changes
- Predecessor fund. Clough Hedged Equity ETF, a series of Listed Funds Trust. It reorganized into the current fund "in a tax-free reorganization on January 17, 2025." The current fund "is a continuation of the Predecessor Fund" (CBLS-PR, page 9, "Performance"; CBLS-SAI, page 6).
- Adviser change. From inception to August 28, 2023, the predecessor was advised by Changebridge Capital, LLC (CBLS-PR, page 9; CBLS-PR, page 23). Changebridge stopped being the adviser "effective August 29, 2023" (CBLS-PR, page 29). Lorusso founded Changebridge, then rejoined Clough in 2023 (CBLS-PR, page 24).
- Fee change. Management fee cut from 1.70% to 1.35% effective February 29, 2024 (CBLS-PR, page 23).
- 351 conversions. None. Section 351 appears only in a rule letting the trust reject creation orders that would give a buyer 80% or more of shares (CBLS-SAI, page 40, "Federal Income Taxes").
- Name, ticker or strategy changes. Not stated.
- Document dates.
- The prospectus and SAI are dated February 27, 2026.
- A supplement dated June 26, 2026 is bound in front of the SAI (CBLS-SAI, pages 1 to 3). It adds a trustee and an assistant secretary. It doesn't change the strategy.
- The fact sheet is as of September 30, 2026.
- The latest audited figures are for the fiscal year ended October 31, 2025. The fiscal year ended October 31, 2026 is closed, but no annual report was attached.
- Conflicts between documents.
- Inception: November 13, 2020 (CBLS-FS, page 1) versus November 12, 2020 (CBLS-PR, page 30, footnote (b); CBLS-PR, page 9). One may be the launch date and the other the first trading date (my inference).
- Number of series in the trust: "seven" (CBLS-SAI, page 6) versus "38 funds" (CBLS-SAI, page 1, June 2026 supplement). The supplement is later, so the trust may have grown (my inference).
- Universe: "global equity positions" (CBLS-FS, page 1) versus "primarily invests in U.S.-listed equity securities" (CBLS-PR, page 4).
- Short cost label: "Margin Interest & Dividends on Short Sales" (CBLS-FS, page 1) versus "dividends, interest and borrowing expense on securities sold short" (CBLS-PR, page 3). Same 0.54%.
11. Principal risks
Summary list: CBLS-PR, pages 5 to 8, "Principal Risks of Investing in the Fund". Longer descriptions: CBLS-PR, pages 17 to 23.
- Equity Market Risk (page 5).
- Investment Themes Risk (page 5).
- Security Selection Risk (page 5).
- Counterparty Risk (page 6; also page 18). Flag: counterparties. It names "the counterparty to an OTC derivatives contract" and possible delays in the "return or delivery of collateral."
- Depositary Receipts Risk (page 6).
- Derivatives Risk (page 6; also page 18). Flag: leverage. The longer text notes that derivatives "involve economic leverage" (page 19).
- Emerging Markets Risk (page 6).
- ETF Risks (page 6): Authorized Participants, Market Makers, and Liquidity Providers Concentration Risk; Costs of Buying or Selling Shares; Shares May Trade at Prices Other Than NAV; Trading.
- Foreign Markets Risk (page 7).
- Growth Investing Risk (page 7).
- Hedging Risk (page 7). Flag: options may not protect the fund.
- Liquidity Risk (page 7).
- Long/Short Risk (page 7). Flag: shorting.
- Management Risk (page 7).
- Market Capitalization Risk: large, mid and small caps (page 7).
- Options Risk (page 7; also page 21). Flag: counterparties for OTC options (page 21).
- Portfolio Turnover Risk (page 7).
- Sector Risk (page 8): consumer, energy, health care, industrials and information technology.
- Short Selling Risk (page 8; also page 23). Flag: shorting and counterparties. Loss is "theoretically unlimited." It also "involves counterparty risk."
- Tax Risk (page 8).
- Value Investing Risk (page 8).
No principal risk is named for leverage as such, for the prime broker, or for borrowing. The SAI covers borrow recalls (a lender demanding its stock back) under "Short Sales" (CBLS-SAI, page 16).
12. Relevance to our fund
- How close is its structure and leverage? Not close (my inference).
- CBLS is a net-long hedged equity fund (net 30% to 70%), not market neutral.
- It runs about 1.28x gross, against our 3.0x.
- It holds 74 positions, against our 150 or more.
- It is on a different platform: Elevation Series Trust with Paralel, not Tidal.
- What it shares with us: a 40 Act ETF wrapper, direct shorting through a broker, and a unitary fee.
- What does it show about 3.0x gross in a 40 Act ETF? Little (my inference).
- CBLS never needs more than 100% long, so it never tests Reg T or portfolio margin limits.
- It uses options and index futures to adjust exposure. It describes them as hedges, not as a path to leverage. That is one of the routes Tidal raised (futures and options), but CBLS shows it only at low gross.
- What does it show about financing, collateral, custody and costs? (my inference)
- Custody. Longs sit with State Street as custodian. Short proceeds are held by an unnamed broker as collateral. The fund also designates "cash or liquid assets" on its own records as extra cover. This fits Tidal's point that shorts sit away from the main custodian.
- Cost visibility. This is the most useful point. CBLS shows short costs inside its expense ratio as a separate line: 0.54% of average net assets in fiscal 2025. But dividends, interest and borrow fees are lumped together. So the true financing cost can't be split from short dividends, and that is the trap noted in
fund_context.md. - Rough cost scale. Short exposure was 38.79% on September 30, 2026. If it averaged about that in fiscal 2025 (not stated), 0.54% would be about 1.39% of short notional per year, dividends included (my arithmetic). At 150% short, the same rate would be about 2.1% of net assets (my arithmetic). Treat this as a loose upper marker, since it includes dividends.
- Formula. Using
fund_context.md, CBLS's cost above the base rate is about $38.79 × c + $38.79 × b per $100, with no broker debit. Our 150/150 would be $150 × c + $50 × d + $150 × b. - Trading costs. Turnover of 719% and commissions of about 1.28% of average net assets (my arithmetic) are a cost on top of the expense ratio. Our fund's turnover will drive a similar hidden cost.
13. Gaps and open questions
What the documents don't answer, for a 150/150 fund:
- The broker's name and the margin type (Reg T or portfolio margin).
- How the 0.54% splits among short dividends, margin interest and borrow fees.
- Whether the broker pays a rebate on short sale proceeds, and at what rate.
- Whether long stocks are pledged to the broker. Whether any collateral sits in a tri-party or control account at State Street.
- How much exposure came from options and index futures, and whether the fact sheet's 38.79% short includes them.
- Rule 18f-4 status: limited derivatives user or full program, VaR test, reference portfolio and derivatives risk manager.
- Whether the fund lends securities, and through which agent.
- Beta, volatility and drawdown figures.
- Fiscal 2026 annual report figures (year ended October 31, 2026).
Questions to ask:
- To Clough or Paralel: Which broker holds CBLS's shorts? Is the account Reg T or portfolio margin? Is it held under Rule 17f-1 or through a control agreement with State Street?
- To Clough: What is the split of the 0.54% into dividends, margin interest and borrow fees? Why does the fact sheet say "Margin Interest" when longs are under 100%?
- To Clough: Does the fact sheet's short exposure include put options and index futures?
- To Paralel: Would Elevation Series Trust support a series above 2.0x gross? If so, through which broker and margin structure?
- To Paralel or the fund: Is CBLS a limited derivatives user under Rule 18f-4? If not, which VaR test and reference index apply?
- To the fund: Which inception date is correct, November 12 or November 13, 2020?
Search terms tried for fields left "Not stated":
- Prime broker and margin type: prime broker, borrow, margin, Regulation T, Reg T, portfolio margin, counterparty, segregat, earmark, tri-party.
- Leverage cost: short sale, sold short, interest expense, dividends on short, borrowing, line of credit, credit facility, swap, box spread, reverse repurchase.
- Rule 18f-4 and VaR: 18f-4, value at risk, VaR, derivatives risk manager, limited derivatives user.
- Commodity pool: Rule 4.5, commodity pool, futures, options.
- Securities lending agent: securities lending, lending agent, lend portfolio.
- Beta and risk data: searched the fact sheet in full; no beta, Sharpe, volatility or drawdown figures.
- Name or strategy changes: predecessor, reorganiz, 351.
- Sub-adviser: sub-adviser (SAI contents and adviser section).
14. Documents used
| Code | Document | Date | Pages | Pages read | File name |
|---|---|---|---|---|---|
| CBLS-FS | Fact sheet | As of September 30, 2026 | 2 | 1 and 2 (all, text and page images) | 9d598e58-CBLS_fact_sheet.pdf |
| CBLS-PR | Prospectus for CBLS and the Clough Select Equity ETF (CBSE). No supplement attached. | February 27, 2026 | 33 | In full: 1 to 10 (CBLS summary; page 9 also as an image), 23 (management section), 29, 30, 33. Keyword passages only: 17 to 21, 24 to 27. Checked only: 31 (CBSE highlights, not used), 32 (privacy notice). | e64c886d-CBLS_prospectus.pdf |
| CBLS-SAI | Statement of Additional Information for CBLS and CBSE, with a supplement dated June 26, 2026 bound in front | SAI February 27, 2026; supplement June 26, 2026 | 48 | In full: 1 to 5. Keyword passages only: 6 to 17, 23 to 29, 39, 40, 44. | f8ee34bc-CBLS_SAI.pdf |
Page numbering.
- CBLS-FS: no printed page numbers. Page 1 is the performance page; page 2 is portfolio construction and holdings.
- CBLS-PR: PDF page number equals printed page number throughout. CBLS's own summary is pages 3 to 10. CBSE's summary (pages 11 to 16) was skipped. Pages 17 to 33 are shared by both funds; only shared or CBLS-specific passages were used.
- CBLS-SAI: PDF pages 1 to 3 are the June 26, 2026 supplement. PDF page 4 is the cover; PDF page 5 is the contents (printed "i"). From PDF page 6 on, PDF page = printed page + 5. The SAI covers both funds; only shared or CBLS-specific passages were used.
15. Snapshot sources
- Ticker: CBLS-FS, page 1, "ETF Information".
- Fund name: CBLS-FS, page 1, header.
- As of date: "Fact Sheet | As of 9/30/2026" (CBLS-FS, page 1, header).
- Adviser: CBLS-FS, page 1, "Firm Overview"; CBLS-PR, page 10, "Management".
- Platform: (my inference). The fund is "a series of Elevation Series Trust" (CBLS-SAI, page 4, cover). Paralel Technologies LLC is administrator and parent of the distributor (CBLS-SAI, page 25). Trustees and officers are "c/o Paralel Technologies LLC" (CBLS-SAI, page 1, supplement). The trust holds funds from other advisers (38 funds per CBLS-SAI, page 1), so it isn't Clough's own trust.
- Exchange: "Principal U.S. Listing Exchange: NYSE Arca, Inc." (CBLS-PR, page 1, cover). The fact sheet says "a NYSE listed ETF" (CBLS-FS, page 2).
- Inception: "Inception 11/13/2020" (CBLS-FS, page 1, "ETF Information"). Conflict: the predecessor "commenced operations on November 12, 2020" (CBLS-PR, page 30, footnote (b)).
- Net assets: "Net Assets $56.70 million" (CBLS-FS, page 1, "ETF Information"), as of September 30, 2026.
- Strategy type: (my inference) from "net long exposure of between 30%-70% of its net assets" (CBLS-PR, page 5, "Principal Investment Strategies of the Fund"). Morningstar places it in the Equity Hedged category (CBLS-FS, page 1).
- Long %: "Long Exposure 89.68%" (CBLS-FS, page 1, "Portfolio Characteristics"), September 30, 2026, "as a % of net assets and excludes cash positions."
- Short %: "Short Exposure -38.79%" (CBLS-FS, page 1, "Portfolio Characteristics"), September 30, 2026.
- Gross: "Gross Exposure 128.47%" (CBLS-FS, page 1, "Portfolio Characteristics"), shown here as a multiple.
- Above 2.0x: based on the 128.47% gross above.
- Net: "Net Exposure 50.89%" (CBLS-FS, page 1, "Portfolio Characteristics").
- Short method: (my inference) direct short sales, "the Fund arranges through a broker to borrow the security it does not own" (CBLS-PR, page 17), plus put options "on securities it believes are overvalued" and index futures used "to hedge portfolio risks" (CBLS-PR, page 5).
- Prime broker or counterparty: the documents say only "a broker" (CBLS-PR, page 17).
- Custodian: CBLS-SAI, page 26, "The Administrator, Custodian, and Transfer Agent"; CBLS-PR, page 33 ("State Street").
- Management fee: CBLS-PR, page 3, fee table; CBLS-FS, page 1, "ETF Expenses". Unitary fee (CBLS-PR, page 23).
- Total expense ratio: "Total Annual Fund Operating Expenses 1.89%" (CBLS-PR, page 3; CBLS-FS, page 1). No waiver. Fiscal 2025 actual was also 1.89% (CBLS-PR, page 30).
- Short costs in expense ratio: "'Other Expenses' include dividends, interest and borrowing expense on securities sold short" (CBLS-PR, page 3, footnote 1).
- 3-month return: -8.50% at NAV, 3 months to September 30, 2026 (CBLS-FS, page 1, "Trailing Return as of 9/30/2026").
- 1-year return: 9.37% at NAV, 1 year to September 30, 2026 (CBLS-FS, page 1, "Trailing Return as of 9/30/2026").
- Beta: not given in any of the three documents.
- Beta benchmark: not stated, because no beta is given.
- Beta period: not stated, because no beta is given.
- Leverage Method: direct shorts from "the Fund arranges through a broker to borrow the security it does not own" (CBLS-PR, page 17); single-stock options from "The Fund buys put options or write (sell) call options on securities" (CBLS-PR, page 5); index futures and options from "the Fund uses futures contracts on stock indices" (CBLS-PR, page 5). No document says Reg T, Regulation T or portfolio margin. Whether options and futures were held on September 30, 2026 is not shown.
- Leverage cost: "Ratio of dividends, interest and borrowing expense on securities sold short 0.54%" for the year ended October 31, 2025 (CBLS-PR, page 30, "Financial Highlights"). Dividends are not split out.
- Short dividend expense: combined in the 0.54% above (CBLS-PR, page 30; CBLS-PR, page 3, footnote 1).
- Ranking properties (Rank to Score): from the ranking of the 27 LS peers prepared November 11, 2026, using only the project's fund profiles. Each of the seven criteria scores Yes = 1, Partly = 0.5, No or Not stated = 0. Funds sort first by Portfolio margin (YES, LIKELY, POSSIBLE, UNLIKELY, NO), then by Score, then Tidal funds first, then higher gross exposure (my inference).
- Rank: 9 of 27, as of November 11, 2026.
- Long/short: 30 to 50 long and 10 to 50 short positions, with net long exposure of 30% to 70% (CBLS-PR, page 5).
- Portfolio margin: POSSIBLE. The fund shorts directly through "a broker" (CBLS-PR, page 17), and no document says Reg T or portfolio margin.
- Cross-collateral: Not stated. The fund designates "cash or liquid assets" on its own records, plus any amount deposited with the broker (CBLS-SAI, page 15). Whether long stocks are pledged is not stated.
- Outside Reg T: Not stated.
- Short costs (includes dividends): Partly. 0.54% for the fiscal year ended October 31, 2025 (CBLS-PR, page 30).
- Over 2.0x: No. 1.28x on September 30, 2026 (CBLS-FS, page 1).
- Tidal: No. The fund is a series of Elevation Series Trust, run with Paralel (CBLS-SAI, page 4, cover).
- Score: 1.5 (my arithmetic).