EMPB

1. Summary

• EMPB is an actively managed ETF that holds long and short positions mostly in other ETFs. A momentum algorithm picks which sectors and asset classes to own and which to short, and the book is reset at least monthly.
• It is a net long fund, not a market neutral one. The prospectus says about 100% long and 20% to 70% short, so gross is about 1.2x to 1.7x and well under 2.0x. The sales deck describes a "50% shorts" book.
• It shorts directly. It borrows ETF shares through "prime brokerage arrangements" with an unnamed prime broker and pays a fee and dividends on them. No swaps, futures or bank borrowing are described.
• Most relevant for us: short costs are shown openly in the fee table (0.16% interest and borrowing, 0.68% short dividends). The fund also earns interest on the cash from its short sales, which it says offsets most of its costs. This gives a real cost reading for direct shorts, but on a 100/50 book, not 150/150, and on a different platform (ETF Architect, not Tidal).

2. Key facts

Other trading data: 30-day bid/ask spread 0.12% as of November 11, 2026 (EMPB-FS, page 2, "Fund-Details"). In 2025 the fund traded at a premium on 220 days and a discount on 20. In 2026 it was 28 and 26 days in Q1, 43 and 14 in Q2, and 48 and 6 in Q3 (EMPB-FS, page 10, "Completed Calendar Quarters of Current Year" and "Most Recent Completed Calendar Year").

3. Service providers

Legal counsel to the trust is Practus, LLP (EMPB-PR, page 18).

4. Strategy

• Objective and benchmark. The prospectus objective: the fund "seeks capital appreciation." (EMPB-PR, page 3, "Investment Objective"). The fact sheet adds that it does so "by dynamically allocating capital to ETFs with the highest growth potential" while shorting ETFs "with limited growth prospects" (EMPB-FS, page 1, "Fund Objective"). Benchmarks differ by document. The prospectus compares returns with the Solactive GBS Global Markets All Cap USD Index (EMPB-PR, page 7, "Performance"). The fact sheet chart and the deck use the S&P 500 (EMPB-FS, page 7; EMPB-DECK, page 2).
• Universe. Mostly ETFs, with individual stocks allowed if more efficient. Asset classes include "U.S. equities of small-, mid-, and large-capitalization companies, U.S. Treasury securities, and foreign equity securities" plus country or regional ETFs (EMPB-PR, page 4, "Principal Investment Strategies"). ETFs must pass screens on structure, peer performance, expense ratio, assets, liquidity "and a minimum track record of five years" (EMPB-PR, page 4).
• How it picks. Quantitative. The sub-adviser's algorithm looks at the prior 24 months for "upward bias (i.e., price momentum)" using moving averages, price moves and volatility (EMPB-PR, page 4). Assets above a set threshold go long. Assets below it may be shorted (EMPB-PR, page 4). The deck says overriding the algorithm "has proven to be worthless or worse" (EMPB-DECK, page 10).
• Neutrality targets. None. The fund is built to be net long.
• Net exposure. The sub-adviser "intends to maintain a net long exposure (the market value of long positions minus the market value of short positions) for the overall portfolio of approximately 50% to 100%" (EMPB-PR, page 4). Conflict inside the same paragraph: 100% long with 20% to 70% short gives net of 30% to 80%, not 50% to 100% (my arithmetic).
• Rebalancing. The sub-adviser "expects to reallocate the Fund’s portfolio at least monthly" (EMPB-PR, page 4). The deck says this happens at month-end (EMPB-DECK, page 10).
• Limits on position size. No numeric limit. The fund is non-diversified and "may invest a significant percentage of its assets in one or more ETFs" (EMPB-PR, page 4). The concentration policy counts net exposure: "the Fund considers its net exposure (i.e., long investments in the industry minus short exposure to such industry)" (EMPB-SAI, pages 4 and 5, "Investment Policies and Restrictions"). The largest holding on November 11, 2026 was VDC at 17.30% (EMPB-FS, page 11).

5. Exposure and leverage

• Stated levels. The fund "will be approximately 100% invested in long positions, and the Fund’s short positions may range from approximately 20% to 70%" (EMPB-PR, page 4, "Principal Investment Strategies"). That is about 1.2x to 1.7x gross (my arithmetic).
• Sales deck. "uses 50% shorts to manage volatility" (EMPB-DECK, page 5) and "Short AUM, on a 50% ratio, is allocated to ETFs expected to under-perform." (EMPB-DECK, page 10). At 100% long that is 1.5x gross and 50% net (my arithmetic). The deck's performance data is as of June 30, 2026.
• Fact sheet. The overview says the algorithm decides "on a limited basis, which to short" (EMPB-FS, page 2, "Overview"). No long, short, gross or net totals are given.
• Measured holdings, November 11, 2026. Only the first page of the holdings table is printed (EMPB-FS, pages 11 and 12, "Fund Holdings"):
  • 9 long ETFs total 101.22% of net assets (my arithmetic).
  • "Cash & Other" is 51.20%.
  • No short positions appear on the printed page.
  • If no other positions exist, shorts would be about 52% (101.22% + 51.20% - 100%, my arithmetic). The cash line is about the size of a 50% short book, which fits short sale cash being held as cash (my inference). The rest of the table was not printed, so this is unconfirmed.
• How it gets exposure above 100%. Only through the short book. Longs stay at about 100%, so there is no leverage on the long side (my inference). The prospectus doesn't say whether short sale cash is used to buy longs.
• Borrowing limits. "Each Fund may borrow money for investment purposes, which is a form of leveraging." (EMPB-SAI, page 10, "Borrowing"). The 1940 Act requires "continuous asset coverage of not less than 300% with respect to all borrowings" (EMPB-SAI, page 11). Borrowing is not a principal strategy. A line of credit is mentioned only as a possible cost (EMPB-SAI, page 11). None is named.

6. Shorting, financing and collateral

• How it shorts. Direct short sales: "When taking a short position, the Fund borrows the security from a third party and sells it at the then current market price" (EMPB-PR, page 4). The shorts are mainly ETFs (EMPB-PR, page 4). No split between methods is given because no other method is described.
• Who lends and who holds collateral. "the broker-dealer through which the short sale is made must borrow the security sold short" (EMPB-SAI, page 11, "Short Sales"). "Interest expenses result from the Fund’s use of prime brokerage arrangements to execute short sales." (EMPB-PR, page 3, fee table footnote 1). The prime broker is not named.
• What is posted. "The Fund is required to make a margin deposit in connection with such short sales" (EMPB-SAI, page 11). What the deposit consists of, and whether long ETFs are pledged, is not stated.
• Short sale proceeds. The fund keeps them as cash and earns interest: "The ETF’s portfolio earns interest on the cash received from its short positions." (EMPB-FS, page 4, "Fees Partially Offset"). The documents don't say where that cash is held.
• Segregated or tri-party account. Not stated. The custodian, U.S. Bank, has no stated role in short collateral (EMPB-SAI, page 19, "Custodian").
• Securities lending. The fund lent securities through U.S. Bank in the year ended November 30, 2025. Gross income was $5,150 and net income $1,822 (EMPB-SAI, page 20, "Securities Lending Agent"). Loans are capped at "33 1/3% of its total assets" and must be collateralized at 102% for U.S. securities (EMPB-SAI, page 6, "Securities Lending").
• Broker choice. "The Trust does not expect to use one particular broker-dealer to effect the Trust’s portfolio transactions." (EMPB-SAI, page 22, "Brokerage Selection").

7. Derivatives and Rule 18f-4

• Derivatives used. None held directly in the documents. Short sales are the only leverage tool described. The fund also "may hold long or short positions in inverse ETFs and inverse leveraged ETFs" (EMPB-PR, page 4). These carry derivatives risk indirectly (EMPB-PR, page 6, "Inverse, and Inverse Leveraged ETF Risk"). No inverse ETFs appear on the printed holdings page (EMPB-FS, pages 11 and 12). So this is listed here as permitted, not as a Leverage Method.
• Other permitted items. The commodities policy does not prevent "any transaction involving currencies, options, forwards, futures contracts, options on futures contracts, swaps" (EMPB-SAI, page 4, "Investment Policies and Restrictions"). This is a carve-out, not a stated use.
• Limited derivatives user or full program. Not stated. Neither document mentions Rule 18f-4, a derivatives risk manager or a limited derivatives user.
• 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.

8. Costs

• Financial highlights, period ended November 30, 2025. Total expenses 1.96%. Dividends, interest and borrowing on securities sold short 0.96%, combined. Expenses excluding those 1.00%. These ratios exclude underlying fund costs (EMPB-PR, page 23, "Financial Highlights"). The fee table's 0.84% for the same two items is 0.12% lower (my arithmetic). The restated interest line probably explains the gap (my inference).
• Who pays what. The adviser pays fund costs except the advisory fee, 12b-1 payments, "brokerage expenses, acquired fund fees and expenses," taxes, "interest (including borrowing costs)," litigation and extraordinary expenses (EMPB-SAI, page 18). The 12b-1 fee is "set at 0% until further action by the Board" (EMPB-PR, page 20). The sub-adviser, as sponsor, "assumes the Adviser’s obligation to pay some of each Fund’s expenses" and shares in profits (EMPB-SAI, page 19, "Sponsor").
• Expense example. $224 for 1 year, $691 for 3 years, $1,185 for 5 years, $2,544 for 10 years per $10,000 (EMPB-PR, page 3).
• Brokerage commissions and turnover. $17,445 in commissions and 277% turnover for December 11, 2024 to November 30, 2025 (EMPB-SAI, page 22; EMPB-SAI, page 11; EMPB-PR, page 3). No later year is reported.
• Gap between expense ratio and management fee. 2.21% minus 1.00% is 1.21% (my arithmetic). It is made up of short dividends 0.68%, interest and borrowing 0.16% and acquired fund fees 0.37% (my arithmetic). The fund's own adjusted figure implies net interest earned on short cash of about 1.12% of net assets for April 2025 to March 2026 (2.21% minus 1.09%, my arithmetic). That income is larger than the 0.84% of short costs.

9. Performance and risk

Month-end returns to October 31, 2026 (EMPB-FS, page 8, "Month-End Performance"). Periods under 1 year are cumulative. Since inception is annualized. No benchmark figures are given in this table.

Quarter-end returns to September 30, 2026 (EMPB-FS, page 8, "Quarter-End Performance"): YTD 20.80% NAV and 20.89% market; 3 months 5.13% and 5.10%; 1 year 19.38% and 19.20%; since inception annualized 20.27% and 20.33%.

Deck returns to June 30, 2026 (EMPB-DECK, page 2, "Fund Performance (6/30/2026)"):

• Calendar-year returns. 2025: 14.97% (EMPB-PR, page 7, "Performance"). Best quarter 11.89% (June 30, 2025). Worst quarter -1.18% (December 31, 2025).
• Prospectus table to December 31, 2025. 1 year 14.97% and since inception 14.61% before taxes, against 22.52% and 17.18% for the Solactive GBS Global Markets All Cap USD Index (EMPB-PR, page 7).
• Financial highlights. Total return 16.47% at NAV for December 11, 2024 to November 30, 2025, not annualized (EMPB-PR, page 23).
• Risk statistics. None given: no beta, correlation, volatility, Sharpe ratio, drawdown or capture figures. The deck claims that from February to April 2025 markets fell about 21% while "EMPB fell less than 8%" (EMPB-DECK, page 2). That is a marketing statement without a stated basis.
• Conflicts in the deck. The cumulative gain to June 30, 2026 is given three ways: 32.68% at NAV (EMPB-DECK, page 2), "a gain of 33.03%" (EMPB-DECK, page 3) and "a total return of 34.20%" (EMPB-DECK, page 11).

10. History and structural changes

• Predecessor funds. None stated. The fund commenced operations December 11, 2024 (EMPB-PR, page 23, footnote (g)).
• Reorganizations and 351 conversions. None. Section 351 appears only in the rule letting the trust reject creation orders tied to large holders (EMPB-SAI, page 35, "Taxes").
• Trust name change. EA Series Trust was formerly Alpha Architect ETF Trust. No date is given (EMPB-SAI, page 1, cover).
• Adviser trade name. The prospectus says "dba EA Advisers" (EMPB-PR, page 7). The fact sheet says the adviser does business "as ETF Architect" (EMPB-FS, page 15).
• Sibling fund. The same prospectus and SAI cover the Efficient Market Portfolio Long ETF (EMPL), which had not started operations at the SAI date (EMPB-SAI, page 11).
• Document dates.
  • The prospectus is dated March 31, 2026 (EMPB-PR, page 1).
  • The SAI is dated March 31, 2026, "as supplemented June 11, 2026" (EMPB-SAI, page 1). The supplement's content is not identified in the file.
  • Both predate the November 11, 2026 fact sheet. The latest audited figures are for the period ended November 30, 2025. The fiscal year ending November 30, 2026 is not yet reported in these documents.
• Other conflicts.
  • Net exposure: 100% long and 20% to 70% short versus a 50% to 100% net target (EMPB-PR, page 4, my arithmetic).
  • Short size: "on a limited basis" (EMPB-FS, page 2) versus "50% shorts" (EMPB-DECK, page 5) versus up to 70% (EMPB-PR, page 4).
  • Benchmark: Solactive index (EMPB-PR, page 7) versus S&P 500 (EMPB-FS, page 7; EMPB-DECK, page 2).

11. Principal risks

Summary list: EMPB-PR, pages 4 to 7, "Principal Investment Risks". Longer descriptions: EMPB-PR, pages 13 to 16. The fact sheet repeats most of these (EMPB-FS, pages 13 and 14).

• Investment Risk (pages 4 and 5).
• Momentum Style Risk (page 5).
• Non-Diversification Risk (page 5).
• Equity Investing Risk (page 5).
• Short Sale Risk (page 5; also page 14). Flag: shorting and counterparty. It names unlimited loss, loan recalls, and "the risk that its prime broker will be unwilling or unable to perform its contractual obligations."
• Foreign Investment Risk (page 5).
• Government Securities Risk (page 5).
• Risk of Investing in Other ETFs (page 5).
• ETF Risks (pages 5 and 6): Authorized Participants, Market Makers and Liquidity Providers Concentration Risk; Premium-Discount Risk; Cost of Trading Risk; Trading Risk.
• Sector Risk (page 6). The text says the fund may invest heavily "in the following sectors" but lists none.
• Management Risk (page 6).
• Monthly Reallocation Risk (page 6).
• High Portfolio Turnover Risk (page 6).
• Inverse, and Inverse Leveraged ETF Risk (page 6). Flag: leverage and derivatives, held indirectly through other ETFs.
• Large Cap Risk (page 6).
• Small- and Mid-Capitalization Companies Risk (page 7).

No principal risk is named for leverage as such, for borrowing, or for the custody of short collateral.

12. Relevance to our fund

• How close is its structure and leverage? Not close (my inference). EMPB runs about 100/50, net long, in ETFs, on ETF Architect's platform. Our fund is 150/150, market neutral, in single stocks, on Tidal. It adds a second direct-short precedent to ORR and BTAL in fund_context.md, but at lower gross.
• What does it show about 3.0x gross in a 40 Act ETF? Little (my inference). Its gross tops out at 1.7x, inside the Reg T cap of about 2.0x. It uses no swaps, futures, bank borrowing or box spreads. It does show that a multi-client trust will run a direct-short book with a prime broker.
• What does it show about financing, collateral, custody and costs? (my inference)
  • Costs are visible. Unlike swap funds, EMPB shows short dividends (0.68%) and interest and borrowing (0.16%) as separate fee table lines. This is the cleaner reporting our fund would get with direct shorts.
  • Short sale cash earns interest. The fund says net interest on short cash offset about 1.12% of net assets (my arithmetic). At 100/50 there is no broker debit, so its cost above the base rate is about $50 × c + $50 × b per $100, against $150 × c + $50 × d + $150 × b for our 150/150 (formulas from fund_context.md).
  • The 0.16% line can't be split into borrow fees (b) and the rebate shortfall (c). So it doesn't give us usable spread inputs without the annual report.
  • Custody: U.S. Bank holds fund assets, and shorts run through an unnamed prime broker. The documents don't say where the margin deposit or short cash sits. This matches, but doesn't confirm, Tidal's point that shorts are "custodied away" from the main custodian.
  • Short dividends as a share of costs: for a 50% ETF short book they ran 0.68% of net assets. A 150% single-stock short book would face roughly three times the dividend drag, before the offsetting price effect (my inference).

13. Gaps and open questions

What the documents don't answer, for a 150/150 fund:

• The prime broker's name and the margin type (Reg T or portfolio margin).
• Where the margin deposit and short sale cash are held, and whether long ETFs are pledged.
• The full holdings list, so measured short, gross and net exposure can't be computed.
• How the 0.16% interest and borrowing line splits into borrow fees, margin interest and any rebate shortfall.
• Rule 18f-4 status, VaR test, reference portfolio and derivatives risk manager.
• Commodity pool status under CFTC Rule 4.5.
• What the June 11, 2026 SAI supplement changed.
• Beta and other risk statistics.

Questions to ask:

• To EA Advisers (ETF Architect): Which prime broker do you use for EMPB? Is the account Reg T or portfolio margin? Is it held under Rule 17f-1 or a tri-party agreement with U.S. Bank?
• To EA Advisers: How is interest on short sale cash booked, and what rebate rate below the base rate does the fund receive?
• To EA Advisers: What made up the 0.16% restated interest and borrowing expense?
• To EA Advisers: Is EMPB a limited derivatives user under Rule 18f-4, given short sales count as derivatives exposure?
• To NextGen EMP: Why does the prospectus give a 50% to 100% net target when 100% long and 20% to 70% short gives 30% to 80%?
• To Tidal: Would Tidal accept a prime brokerage setup like EMPB's, and could it extend to a 150/150 single-stock book?

Search terms tried for fields left "Not stated":

• Prime broker and margin type: prime broker, borrow, margin, Regulation T, portfolio margin, counterparty, collateral, pledge, segregat, earmark, tri-party, custod.
• Rule 18f-4 and VaR: 18f-4, 18f, value at risk, value-at-risk, VaR, derivatives risk, limited derivatives, derivative.
• Commodity pool: Rule 4.5, commodity pool, CFTC, commodity.
• Leverage routes: swap, futures, options, box spread, reverse repurchase, leverag, line of credit, asset coverage.
• Beta and risk data: beta, Sharpe, volatil, drawdown, correlat, capture, standard dev, Morningstar.
• History: predecessor, reorganiz, 351, formerly, conversion, supplement, June 11.

14. Documents used

Page numbering.

• EMPB-FS: a web page printout with no printed page numbers. PDF pages are used.
• EMPB-PR: PDF pages 1 and 2 are the cover and contents (no printed number). From PDF page 3 on, PDF page = printed page + 2. EMPB's summary is PDF pages 3 to 8 (printed 1 to 6).
• EMPB-SAI: PDF page 1 is the cover and contents. From PDF page 2 to 45, PDF page = printed page + 1. PDF page 46 is printed A-1, and PDF pages 46 to 135 are the proxy voting appendix. The SAI covers both funds; only shared or EMPB-specific passages were used. No separate supplement page was found.
• EMPB-DECK: printed slide numbers, where shown, match PDF pages.

15. Snapshot sources

• Ticker: EMPB-FS, page 2, "Fund-Details" ("Ticker EMPB").
• Fund name: EMPB-FS, page 1, header ("Efficient Market Portfolio Plus ETF").
• As of date: EMPB-FS, page 2, "Fund-Details" ("As of Date 11/11/2026"). The holdings table carries the same date (EMPB-FS, page 12).
• Adviser: EMPB-PR, page 7, "Investment Adviser" ("Empowered Funds, LLC dba EA Advisers"). The fact sheet calls it "Empowered Funds LLC, which is doing business as ETF Architect" (EMPB-FS, page 15).
• Platform: (my inference) ETF Architect is the adviser's trade name (EMPB-FS, page 15). The fund is a series of EA Series Trust, whose trustees oversee 107 funds and whose funds are sponsored by outside sub-advisers (EMPB-SAI, pages 1 and 12; EMPB-PR, page 16, "Fund Sponsor").
• Exchange: EMPB-FS, page 2, "Fund-Details"; EMPB-PR, page 18, "Buying and Selling Shares on the Secondary Market".
• Inception: EMPB-FS, page 2, "Fund-Details" ("Inception 12/11/2024").
• Net assets: EMPB-FS, page 2, "Fund-Details" ("Net Assets $32.65 million"), as of November 11, 2026.
• Strategy type: (my inference) from "approximately 100% invested in long positions," shorts of "approximately 20% to 70%", and a net long target of "approximately 50% to 100%" (EMPB-PR, page 4, "Principal Investment Strategies"). The fund is net long and holds equity ETFs, so it is not equity market neutral.
• Long %: "approximately 100% invested in long positions" (EMPB-PR, page 4). This is a stated normal level, not a measured figure. The printed holdings page shows longs of 101.22% for 9 ETFs (my arithmetic), but the table is incomplete (EMPB-FS, pages 11 and 12).
• Short %: "short positions may range from approximately 20% to 70%" (EMPB-PR, page 4). The deck says "50% shorts" (EMPB-DECK, page 5). No measured figure is given.
• Gross: (my arithmetic) 100% plus 20% to 70% gives 1.2x to 1.7x, from EMPB-PR, page 4. Not stated as a figure in any document.
• Above 2.0x: (my arithmetic) the top of the stated range is 1.7x (EMPB-PR, page 4).
• Net: "net long exposure ... of approximately 50% to 100%" (EMPB-PR, page 4). Conflict: the stated long and short ranges give 30% to 80% (my arithmetic).
• Short method: "When taking a short position, the Fund borrows the security from a third party and sells it at the then current market price" (EMPB-PR, page 4, "Principal Investment Strategies").
• Prime broker or counterparty: the documents say only "prime brokerage arrangements" (EMPB-PR, page 3, footnote 1) and "its prime broker" (EMPB-PR, page 5, "Short Sale Risk"). No firm is named.
• Custodian: EMPB-PR, page 18, "Other Service Providers"; EMPB-SAI, page 19, "Custodian".
• Management fee: EMPB-PR, page 3, "Fees and Expenses"; EMPB-FS, page 2, "Fees". Unitary (EMPB-PR, page 17).
• Total expense ratio: "Total Annual Fund Operating Expenses 2.21%" (EMPB-PR, page 3); "Gross Expense Ratio 2.21%" (EMPB-FS, page 2). No waiver line, so net equals gross. The fact sheet's 1.09% "Adjusted Expense Ratio" nets out interest earned, not waivers (EMPB-FS, page 3).
• Short costs in expense ratio: the fee table has lines for "Interest and Borrowing Expenses" 0.16% and "Dividends on Short Positions" 0.68% (EMPB-PR, page 3).
• 3-month return: 3.63% at NAV, 3 months to October 31, 2026 (EMPB-FS, page 8, "Month-End Performance"). The fact sheet also gives 5.13% at NAV for 3 months to September 30, 2026 (EMPB-FS, page 8, "Quarter-End Performance").
• 1-year return: 15.52% at NAV, 1 year to October 31, 2026 (EMPB-FS, page 8, "Month-End Performance").
• Beta: not given in any of the four documents. The deck defines beta in its glossary but gives no figure (EMPB-DECK, page 19).
• Beta benchmark: not stated, because no beta is given.
• Beta period: not stated, because no beta is given.
• Leverage Method: "the Fund borrows the security from a third party and sells it" (EMPB-PR, page 4) and "Interest expenses result from the Fund’s use of prime brokerage arrangements to execute short sales." (EMPB-PR, page 3, footnote 1). The SAI says only "margin deposit" (EMPB-SAI, page 11). No document says Reg T, Regulation T or portfolio margin.
• Leverage cost: "Interest and Borrowing Expenses" 0.16%, footnoted "Restated to reflect current fees." (EMPB-PR, page 3; EMPB-FS, page 2). The fee table gives no fiscal year. The latest audited period, December 11, 2024 to November 30, 2025, reports 0.96% for dividends, interest and borrowing combined (EMPB-PR, page 23, "Financial Highlights").
• Short dividend expense: "Dividends on Short Positions" 0.68% (EMPB-PR, page 3; EMPB-FS, page 2). The fee table gives no fiscal year. It is probably based on the period ended November 30, 2025, since only the interest line is marked as restated (my inference).
• 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: 8 of 27, as of November 11, 2026.
• Long/short: about 100% long and 20% to 70% short, mostly in ETFs (EMPB-PR, page 4).
• Portfolio margin: POSSIBLE. The fund shorts through "prime brokerage arrangements" (EMPB-PR, page 3, footnote 1). The SAI says only "margin deposit" (EMPB-SAI, page 11). No document says Reg T or portfolio margin.
• Cross-collateral: Not stated. "The Fund is required to make a margin deposit in connection with such short sales" (EMPB-SAI, page 11). What the deposit consists of is not stated.
• Outside Reg T: Not stated.
• Short costs (includes dividends): Partly. "Interest and Borrowing Expenses" of 0.16%, restated to reflect current fees, shown apart from "Dividends on Short Positions" of 0.68% (EMPB-PR, page 3). This is the only line in the 27 profiles that splits financing from short dividends.
• Over 2.0x: No. Up to about 1.7x from the stated ranges (EMPB-PR, page 4; my arithmetic).
• Tidal: No. The fund is a series of EA Series Trust, on the ETF Architect platform (EMPB-SAI, page 1, cover; EMPB-FS, page 15).
• Score: 1.5 (my arithmetic).

16. Fund Documents

Deck

Fact Sheet

Prospectus

SAI