ORR
1. Summary
- ORR is an actively managed, fundamental long/short equity ETF. It buys mostly non-U.S. stocks it thinks are cheap, with a large tilt to Japan, and shorts U.S.-listed index ETFs, high-yield vehicles and some single stocks.
- On September 30, 2026 it was 140.6% long and 68.3% short: 2.09x gross and 72.4% net long. It is a net-long fund, not market neutral.
- It shorts directly through a broker. About 65% of the short book is index ETFs. No document names the broker or says whether the account is Reg T or portfolio margin.
- Most relevant for us: its 10.91% expense ratio is almost all short-sale costs (9.61%), reported as one lumped figure that mixes dividends paid on shorts with borrow and broker costs. Its short book leans on high-dividend ETFs and BDCs, so the dividend part is likely large. The figure says little about true financing cost (my inference).
2. Key facts
| Item | Detail | Source |
|---|---|---|
| Name and ticker | Militia Long/Short Equity ETF (ORR) | ORR-FS, page 1, header and "Fund information" |
| Exchange | Nasdaq. The prospectus says "Listed on The Nasdaq Stock Market LLC". | ORR-FS, page 1, "Quick facts"; ORR-PR, page 2, cover |
| CUSIP | 02072Q820 | ORR-FS, page 1, "Quick facts" |
| Inception date | January 14, 2025 | ORR-FS, page 1, "Quick facts"; ORR-PR, page 24, "Financial Highlights" footnote (f) |
| Trust, and whether multi-client | "a series of the EA Series Trust, formerly known as Alpha Architect ETF Trust", a Delaware statutory trust formed October 11, 2013. "Currently, the Trust consists of multiple series". Each trustee oversees 107 funds in the fund complex. The adviser does business as ETF Architect and hires an outside firm (Militia) as sub-adviser and fund sponsor. So it is a multi-client series trust (my inference). | ORR-SAI, page 1, cover; ORR-SAI, page 3, "Trust and Fund Overview"; ORR-SAI, page 27, "Organization and Description of Shares of Beneficial Interest"; ORR-SAI, page 17, "Trustees and Officers"; ORR-FS, page 2, disclosures |
| Fiscal year end | November 30 (first period: January 14, 2025 to November 30, 2025) | ORR-PR, page 4, "Portfolio Turnover"; ORR-PR, page 17, "Investment Adviser" |
| Net assets and NAV | $345.44 million; NAV $37.92; market price $37.77, at September 30, 2026. At November 30, 2025: $151,399 thousand and NAV $33.42. | ORR-FS, page 1, "Quick facts"; ORR-PR, page 24, "Financial Highlights" |
| Morningstar category and rating | Not stated | |
| Number of long and short positions | 164 long and 34 short, 198 in total, at September 30, 2026 | ORR-FS, page 1, "Portfolio characteristics" |
| Distribution frequency | Net investment income "as dividends annually"; capital gains "at least annually" | ORR-PR, page 22, "Dividends and Distributions" |
| Creations and redemptions | "Creation Units are generally issued and redeemed only in-kind for securities although a portion may be in cash." The SAI also allows "an all cash payment". | ORR-PR, page 19, "Buying and Selling Fund Shares"; ORR-SAI, page 29, "Fund Deposit" |
Other trading data, as of September 30, 2026: average premium/discount in the third quarter -0.01%; 30-day bid/ask spread 0.23% (ORR-FS, page 1, "Quick facts").
3. Service providers
| Role | Firm | Source |
|---|---|---|
| Adviser | Empowered Funds, LLC dba EA Advisers. The fact sheet says it is "doing business as ETF Architect". Wholly owned by Alpha Architect LLC. | ORR-PR, page 17, "Investment Adviser"; ORR-FS, page 2, disclosures |
| Sub-adviser | Militia Investments, LLC (Austin, Texas), founded 2024. It is also the fund sponsor. | ORR-PR, page 17, "Investment Sub-Adviser"; ORR-PR, page 18, "Fund Sponsor" |
| Portfolio managers | David Orr, Chief Investment Officer of the sub-adviser | ORR-PR, page 10, "Portfolio Manager"; ORR-FS, page 1 |
| Administrator | U.S. Bancorp Fund Services, LLC, doing business as U.S. Bank Global Fund Services | ORR-PR, page 18, "Other Service Providers"; ORR-SAI, page 24 |
| Fund accountant | U.S. Bank Global Fund Services | ORR-PR, page 18; ORR-SAI, page 24, "Administrator, Fund Accountant and Transfer Agent" |
| Custodian | U.S. Bank National Association | ORR-PR, page 19; ORR-SAI, page 24, "Custodian" |
| Transfer agent | U.S. Bank Global Fund Services | ORR-PR, page 18; ORR-SAI, page 24 |
| Distributor | PINE Distributors LLC | ORR-PR, page 18; ORR-SAI, page 26, "The Distributor"; ORR-FS, page 2 |
| Auditor | Tait, Weller & Baker LLP | ORR-PR, page 19; ORR-SAI, page 26, "Independent Registered Public Accounting Firm" |
| Prime broker | Not stated. The prospectus mentions "its prime broker" only in a risk statement. | ORR-PR, page 6, "Short Sale Risk" |
| Swap counterparties | Not stated (no swaps described as used) | |
| Securities lending agent | U.S. Bank National Association. The fund did not lend in the period ended November 30, 2025. | ORR-SAI, page 24, "Securities Lending Agent" |
Legal counsel to the trust is Practus, LLP (ORR-PR, page 19).
4. Strategy
- Objective and benchmark. "The Militia Long/Short Equity ETF (the "Fund") seeks capital appreciation." (ORR-PR, page 4, "Investment Objective"). No benchmark index is named in the prospectus. The fact sheet uses the Solactive GBS All Cap Index only for beta (ORR-FS, page 2).
- Universe.
- At least 80% of net assets, including borrowings for investment purposes, in equity securities or ETFs that give equity exposure (ORR-PR, page 4, "Principal Investment Strategies").
- Long book: the March 31, 2026 prospectus says "foreign (typically in developed markets) or U.S. companies" (ORR-PR, page 4). The August 21, 2026 supplement replaces this. It now says "The Fund's investments in foreign companies may include companies in developed or emerging markets." (ORR-PR, page 1, supplement). The fund expected "significant exposure to companies listed in Japan" (ORR-PR, page 5).
- Short book: "For the Fund's short portfolio, the Sub-Adviser seeks U.S.-listed companies" whose cash flows are expected to fall (ORR-PR, page 5). It may also short U.S.-listed ETFs, closed-end funds and business development companies (BDCs), including options-based income ETFs (ORR-PR, page 5).
- Any market cap: small, mid or large (ORR-PR, page 4).
- On September 30, 2026: Japan was 56.6% of net assets long, the U.S. 49.6% long and -59.1% short. Industrials were 44.9% long and financials 30.1% long (ORR-FS, page 2, "Country exposure" and "Sector exposure").
- How it picks stocks. Fundamental. "The Sub-Adviser selects individual equities primarily based on the net present value of anticipated future cash flows from the company." (ORR-PR, page 4). It expects to hold longs "for an extended period of time (i.e., more than one year)" (ORR-PR, page 5).
- Neutrality targets. None stated. The fact sheet says the fund "Hedges market exposure primarily through broad index shorts and selective single-name shorts." (ORR-FS, page 1, "Investment approach").
- Net exposure. No target or range stated. The limits on each side (section 5) allow anything from net long above 100% to net short. The measured figure was 72.4% on September 30, 2026 (ORR-FS, page 1).
- Limits on position size. No numeric limit per position. The fund is non-diversified (ORR-PR, page 5). It will not concentrate in an industry, measured on net exposure: "long investments in the industry minus short exposure to such industry" (ORR-SAI, pages 4 and 5, "Investment Policies and Restrictions"). Publicly traded partnerships, including MLPs, are capped at 25% of total assets (ORR-PR, page 10). The largest long was Hikari Tsushin at 11.81% and the largest short was DVY at -12.45% on September 30, 2026 (ORR-FS, page 1, "Holdings").
- Currency. The fund may short currencies such as the yen through forward contracts "to mitigate currency risk associated with foreign investments" (ORR-PR, page 5). The fact sheet's currency table (JPY 40.2% of long equity holdings) "Does not reflect active FX hedging or derivative positions." (ORR-FS, page 2). Whether the fund actually hedges is not stated.
5. Exposure and leverage
- Measured exposure, September 30, 2026 (ORR-FS, page 1, "Portfolio characteristics"):
- Long 140.6%, short 68.3%, net 72.4%, gross 208.9%.
- Cash and equivalents 27.3%.
- Check: 140.6% + 68.3% = 208.9%, and 140.6% - 68.3% = 72.3%, which differs from the stated 72.4% by rounding (my arithmetic).
- Stated limits.
- Long: "The Fund may, but is not required to, have long exposure greater than 100% of the Fund's net assets, and the Fund will cap its long exposure to typically less than 150% of its net assets, but may exceed this threshold from time to time." (ORR-PR, page 5).
- Short: "The Fund is expected to have short exposure up to 100% of its net assets." (ORR-PR, page 5).
- Together these allow up to about 2.5x gross under normal conditions (my arithmetic). No gross limit is stated as such.
- How it gets exposure above 100%. Not stated directly. Long 140.6% plus cash 27.3% minus short 68.3% equals 99.6% of net assets (my arithmetic). So the longs above 100%, and the cash, are funded by the short sale proceeds, or by broker credit backed by them (my inference). No swaps are described. Index futures and leveraged ETFs are permitted (section 6) but don't appear in the top holdings.
- Borrowing limits. The fund may borrow from a bank only if "there is an asset coverage of at least 300%" (ORR-SAI, page 4, "Investment Policies and Restrictions"). No line of credit or bank borrowing is named. The expense ratio has no separate line for bank interest (ORR-PR, page 4).
6. Shorting, financing and collateral
- How it shorts. Direct short sales. "When the Fund sells securities short, it sells a security that it does not own (but has borrowed) at its current market price" (ORR-PR, page 5). "The Sub-Adviser may also seek to sell short U.S.-listed ETFs and closed-end funds" (ORR-PR, page 5).
- Share of each. By short gross on September 30, 2026: index ETFs 65.4%, single-name equities 21.6%, BDCs and yield vehicles 13.0% (ORR-FS, page 2, "Short book composition"). The top ten shorts include DVY (-12.45%), VB (-10.08%), IJR (-9.94%), SPYD (-4.98%), EFA (-3.14%) and SDIV (-2.86%) (ORR-FS, page 1). These six ETFs total -43.45% of net assets (my arithmetic).
- Conflict on emphasis. The prospectus leads with single-stock shorts of "U.S.-listed companies" and lists ETF shorts as something the sub-adviser "may also" do (ORR-PR, page 5). The fact sheet says the fund hedges "primarily through broad index shorts" (ORR-FS, page 1). The fact sheet shows current practice; the prospectus describes it differently (my inference).
- Who lends the stock and who holds collateral. "the broker-dealer through which the short sale is made must borrow the security sold short and deliver it to the party purchasing the security" (ORR-SAI, page 16, "Short Sales"). The broker is not named. "The Trust does not expect to use one particular broker-dealer to effect the Trust's portfolio transactions." (ORR-SAI, page 25, "Brokerage Selection"). The adviser, not the sub-adviser, "is responsible for selecting brokers and placing the Fund's trades" (ORR-PR, page 17).
- What is posted. "The Fund is required to make a margin deposit in connection with such short sales" (ORR-SAI, page 16). What the deposit consists of, and whether long stocks are pledged, is not stated. The margin type (Reg T or portfolio margin) is not stated.
- Short sale proceeds used to buy longs. Not stated. The exposure arithmetic in section 5 points that way (my inference).
- Segregated or tri-party account. Not stated for short sales. For futures only, the SAI says initial margin is deposited "with its custodian in a segregated account in the name of the futures broker" (ORR-SAI, page 15, "Futures Contracts").
- Costs named. "the Fund may have to pay a fee to borrow particular securities and will often be obligated to pay over any dividends and accrued interest on borrowed securities" (ORR-SAI, page 16). "Short sales also involve transaction and financing costs that will reduce potential Fund gains and increase potential Fund losses." (ORR-PR, page 11, "Short Sale Risk").
- Securities lending. Permitted up to 33 1/3% of total assets (ORR-SAI, page 5, "Securities Lending"). U.S. Bank National Association is the agent. "The Fund did not participate in Securities Lending during the fiscal period ended November 30, 2025." (ORR-SAI, page 24).
- Permitted only. These are allowed but not shown in use:
- Broad-market index futures, including TOPIX futures, for "tactical positioning or for hedging purposes" (ORR-PR, page 5).
- Currency forwards (ORR-PR, page 5).
- Long or short positions in leveraged, inverse or inverse leveraged ETFs (ORR-PR, page 5).
- Options on securities, "including a box spread" (ORR-SAI, page 14, "Options").
- Repurchase agreements (ORR-SAI, page 8).
7. Derivatives and Rule 18f-4
- Derivatives used or permitted.
- Short sales count as derivatives: "Derivatives are defined by Rule 18f-4 to include short sales" (ORR-SAI, page 13). The prospectus says "The Fund intends to comply with the requirements of Rule 18f-4 of the Investment Company Act of 1940 as it relates to its short positions." (ORR-PR, page 5).
- Index futures and currency forwards are named in the prospectus (ORR-PR, pages 5 and 7, "Derivatives Risk").
- Options, including box spreads, are permitted in the SAI (ORR-SAI, page 14).
- Conflict. The fact sheet's risk text says "The Fund will utilize derivatives, such as options, to gain exposure to certain assets or markets with a smaller initial investment." It also has a "Counterparty Risk" item on FLEX Options and the Options Clearing Corporation (ORR-FS, page 2). Neither the prospectus summary nor its risk list names options, FLEX options or a counterparty risk (searched ORR-PR, all pages, for "FLEX", "OCC" and "Counterparty Risk"). The fact sheet's holdings show no options (ORR-FS, page 1). This text may be carried over from another fund's template (my inference).
- Limited derivatives user or full program. The SAI says Rule 18f-4 "requires the Fund to establish a derivatives risk management program, appoint a derivatives risk manager" (ORR-SAI, page 14). It does not say whether ORR has done so or uses the limited derivatives user exception. With 68.3% of net assets short, ORR's derivatives exposure is far above the rule's 10% limited-user threshold, so it likely runs a full program (my inference).
- VaR test and reference portfolio. The SAI describes the Relative VaR Test: the fund's VaR must not exceed 200% of the VaR of its "designated reference portfolio," which is "a representative unleveraged index or the Fund's own portfolio absent derivatives holdings, as determined by the Fund's derivatives risk manager." It may use the Absolute VaR Test (20% of net assets) instead (ORR-SAI, page 14). VaR (value at risk) estimates the most a fund could lose over a set period at a set confidence level. Which test ORR uses, and its reference portfolio, are not stated.
- Commodity pool status (CFTC Rule 4.5). Not stated.
8. Costs
| Item | Amount | Source |
|---|---|---|
| Management fee | 1.30%. Unitary: the prospectus calls it "a unitary management fee". The adviser pays fund expenses except listed exclusions. | ORR-PR, page 4, "Fees and Expenses"; ORR-PR, pages 17 and 18, "Investment Adviser" and "Fund Sponsor" |
| Other expenses | "All Other Expenses" 0.00%; "Total Other Expenses" 9.61% | ORR-PR, page 4 |
| Dividend and interest expense on short sales | 9.61%, as one line: "Dividend Expense, Borrowing Costs and Brokerage Expenses on Short Sales". The financial highlights give 9.61% as "dividends, interest and borrowing expenses on securities sold short" for the period ended November 30, 2025 (annualized). | ORR-PR, page 4; ORR-PR, page 24, "Financial Highlights" |
| Borrowing costs | Included in the 9.61% line; not split out | ORR-PR, page 4 |
| Acquired fund fees | No line in the fee table. Conflict: the risk text says underlying fund expenses "are identified in the fee schedule above as "Acquired Fund Fees and Expenses."" | ORR-PR, page 4; ORR-PR, page 8, "Risk of Investing in Other Investment Companies" |
| Gross and net expense ratio | 10.91% and 10.91%. No waiver line. The fact sheet also shows 10.91% at September 30, 2026. | ORR-PR, page 4; ORR-PR, page 24; ORR-FS, page 1 |
| Fee waivers or caps | None at fund level. The sub-adviser's 0.65% fee is "automatically waived" in months when the unitary fee doesn't cover it. $10,520 was waived in the period ended November 30, 2025. | ORR-PR, page 18, "Fund Sponsor"; ORR-SAI, page 23, "Investment Sub-Adviser" |
| Stated financing spreads or rates | Not stated | |
| Where financing costs are reported | In the expense ratio, lumped with short dividends and broker costs in one 9.61% line | ORR-PR, page 4; ORR-PR, page 24 |
- Who pays what. The adviser bears all fund expenses except the advisory fee, 12b-1 payments, "brokerage expenses, acquired fund fees and expenses, taxes, interest (including borrowing costs), litigation expense and other non-routine or extraordinary expenses." The fund also pays securities lending costs (ORR-PR, page 17). The custodian, administrator and transfer agent are paid "by the Adviser from its fees" (ORR-SAI, page 24). Under the sponsorship agreement, Militia takes on part of the adviser's duty to pay expenses and shares in the profit from the unitary fee. If the fee falls short, the "Fund Sponsor is obligated to reimburse the Adviser for the shortfall" (ORR-PR, page 18; ORR-SAI, pages 23 and 24, "Sponsor").
- Fee table footnotes. The 9.61% line carries footnote marker 2, but no footnote 2 text is printed. Footnote 1 says "Interest expenses result from the Fund's short sales." (ORR-PR, page 4, checked on the page image).
- 12b-1 plan. Up to 0.25% is authorized. "No fees are currently paid by any Fund under the Plan." (ORR-SAI, page 26).
- Expense example. $1,059 for 1 year, $2,992 for 3 years, $4,704 for 5 years and $8,173 for 10 years per $10,000 (ORR-PR, page 4).
- Advisory fees paid. $949,892 for January 14 to November 30, 2025 (ORR-SAI, page 23). The prospectus says this was 1.14% of average daily net assets (ORR-PR, page 17). The period is 320 days, and 1.30% × 320/365 = 1.14% (my arithmetic). So 1.14% is the un-annualized rate for a partial year, not a discount (my inference). This implies average net assets of about $83.3 million (my arithmetic), and short-sale costs of about $7.0 million for the period at 9.61% annualized (my arithmetic).
- Brokerage commissions and turnover. Commissions $124,136 for the period ended November 30, 2025 (ORR-SAI, page 25). Portfolio turnover 73% for the same period, excluding in-kind transactions (ORR-PR, page 4; ORR-SAI, page 16; ORR-PR, page 24). Later years: not stated.
- Gap between expense ratio and management fee. 10.91% - 1.30% = 9.61% (my arithmetic). All of it is the short-sale line. The prospectus doesn't split it between dividends, borrow fees, interest and broker costs. The short book includes high-dividend vehicles: DVY, SPYD, SDIV, and BDCs such as OXLC and PSEC (ORR-FS, page 1). So most of the 9.61% is likely dividends paid on shorts, which are offset by price drops and are not a true financing cost (my inference).
9. Performance and risk
Total returns to September 30, 2026 (ORR-FS, page 1, "Performance history"). Periods under one year are cumulative; 1 year and longer are average annualized. ITD means inception to date (from January 14, 2025).
| Period | NAV | Market price |
|---|---|---|
| YTD | +11.42% | +10.57% |
| 1 month | -2.59% | -2.58% |
| 3 months | +3.89% | +3.99% |
| 6 months | +5.25% | +3.62% |
| 1 year | +20.17% | +20.00% |
| ITD (annualized) | +26.50% | +26.21% |
- Benchmark returns. Not stated. The fact sheet gives no index returns.
- First fiscal period. Total return 31.74% at NAV, January 14 to November 30, 2025, not annualized. NAV rose from $25.37 to $33.42 (ORR-PR, page 24, "Financial Highlights").
- Calendar-year returns. Not stated. "Performance information is not provided below because the Fund has not yet been in operation for one full calendar year." (ORR-PR, page 10, "Performance").
- Beta. Against the Solactive GBS All Cap Index, rolling 60-day, from about April 2025 to September 2026: current 0.48, average 0.32, high 0.70, low -0.46 (ORR-FS, page 2, "Rolling 60-day beta vs. Solactive GBS All Cap"). The "Est. portfolio beta" on page 1 is also 0.48 (ORR-FS, page 1).
- Other risk statistics. No correlation, volatility, Sharpe ratio, drawdown or capture figures are given.
- Growth of $10,000 chart. The chart shows growth from inception to about $15,000 by September 2026, read from the chart (ORR-FS, page 1). Values aren't tabulated.
10. History and structural changes
- Predecessor funds. None stated. Searched "predecessor", "reorganiz" and "351". The portfolio manager has run a private fund, Militia Capital Partners, LP, since 2021 (ORR-PR, page 18, "Portfolio Manager"). The SAI lists one other pooled vehicle with $175.4 million under his management at November 30, 2025 (ORR-SAI, page 24). No document calls it a predecessor.
- Reorganizations and 351 conversions. None. Section 351 appears only in a rule letting the trust reject purchases that would give a buyer 80% or more of shares (ORR-SAI, page 39, "Purchase of Shares").
- Trust name. EA Series Trust was "formerly known as Alpha Architect ETF Trust" (ORR-SAI, page 1, cover). The date of the change is not stated.
- Strategy change. The August 21, 2026 supplement widens the long book from "typically in developed markets" to developed or emerging markets, and adds Emerging Markets Risk (ORR-PR, page 1). The fact sheet already reflects this: "Invests long in undervalued companies across developed and emerging markets." (ORR-FS, page 1).
- Document dates.
- The prospectus is dated March 31, 2026. It predates the August 21, 2026 supplement (bound in front) and the September 30, 2026 fact sheet.
- The SAI is dated March 31, 2026, "as supplemented June 9, 2026" (ORR-SAI, page 1). The file doesn't show what the June 9 supplement changed. The prospectus file doesn't mention a June 9 supplement.
- Neither document reflects the fiscal year ended November 30, 2026; no later annual report was attached.
- Conflicts between documents.
- Adviser trade name: "dba EA Advisers" (ORR-PR, page 10; ORR-SAI, page 1) versus "doing business as ETF Architect" (ORR-FS, page 2).
- Short book emphasis: single U.S.-listed stocks (ORR-PR, page 5) versus "primarily through broad index shorts" (ORR-FS, page 1).
- Options: "will utilize derivatives, such as options" and FLEX options counterparty risk (ORR-FS, page 2) versus no options in the prospectus strategy or risks (ORR-PR, pages 4 to 10).
- Risk list: the fact sheet names value stocks, inflation, issuer, small fund, concentration policy and market price risks (ORR-FS, page 2). These headings don't appear in the prospectus summary (ORR-PR, pages 5 to 10).
- Acquired fund fees: referenced in risk text but missing from the fee table (ORR-PR, pages 4 and 8).
11. Principal risks
Summary list: ORR-PR, pages 5 to 10, "Principal Investment Risks". Longer descriptions: ORR-PR, pages 11 to 17. Emerging Markets Risk was added by supplement (ORR-PR, page 1).
- Large-Capitalization Companies Risk (page 5).
- Mid-Capitalization Companies Risk (page 5).
- Small-Capitalization Companies Risk (page 6).
- Investment Risk (page 6).
- Equity Investing Risk (page 6).
- Leverage Risk (page 6; also page 12). Flag: leverage. Leverage comes from "the use of short positions or other financial instruments that may magnify gains and losses beyond the initial investment".
- Leveraged, Inverse, and Inverse-Leveraged ETF Risk (page 6; also page 12). Flag: leverage. These ETFs can "expose the Fund to complete loss of its investment."
- Short Sale Risk (page 6; also page 11). Flags: shorting and counterparties. It covers unlimited loss, a lender recalling its stock, and "the risk that its prime broker will be unwilling or unable to perform its contractual obligations." The longer version adds "Regulatory restrictions limit the extent to which the Fund may engage in short sales." (page 11).
- Foreign Investment Risk (page 6).
- Depositary Receipts Risk (pages 6 and 7).
- Derivatives Risk (page 7; also page 13). Flag: counterparties. Covers futures and currency forwards, including "the possibility that the counterparty will default" and variation margin calls.
- Developed Markets Risk (page 7).
- Geographic Focus Risk, including Japanese Investment Risk (page 7).
- Currency Risk (pages 7 and 8).
- Currency Hedging Risk (page 8).
- Risk of Investing in Other Investment Companies (page 8).
- ETF Risks (page 8): Authorized Participants, Market Makers and Liquidity Providers Concentration Risk; Premium-Discount Risk; Cost of Trading Risk; Trading Risk.
- Sector Risk (pages 8 and 9): industrials, information technology and energy.
- Management Risk (page 9).
- High Portfolio Turnover Risk (page 9).
- New Sub-Adviser Risk (page 9).
- New Fund Risk (page 9).
- Non-Diversification Risk (page 9).
- PTP Risk, MLP Risk and MLP Tax Risk (pages 9 and 10).
- Emerging Markets Risk (page 1, supplement dated August 21, 2026).
12. Relevance to our fund
- How close is its structure and leverage? Not close (my inference).
- ORR is net long (72.4%), global and Japan-heavy. Our fund is market neutral and U.S.
- Its 140/68 book is lopsided. Our 150/150 book is balanced.
- Its short book is mostly broad ETFs, not single stocks.
- What it shares with us: a 40 Act ETF on a white-label platform, direct shorting, and a book of more than 150 positions.
- What does it show about getting 3.0x gross in a 40 Act ETF? (my inference)
- ORR runs 2.09x gross, close to the Reg T ceiling of about 2.0x in
fund_context.md. A rough Reg T opening check on its book: 50% of 140.6% long plus 50% of 68.3% short needs about 104% of net assets in margin equity (my arithmetic). That is slightly above 100%. So the book is at or just past what Reg T allows at opening. Market moves after opening, or a different margin setup, could explain this. The documents don't say which. - Its prospectus allows up to about 150% long and 100% short, about 2.5x (my arithmetic). Even ORR's own documents don't contemplate 3.0x gross.
- It adds no swaps, bank borrowing or box spreads in practice. Index futures and box spreads are permitted, but nothing shows they are used. So ORR gives no precedent for reaching 3.0x through those routes.
- ORR runs 2.09x gross, close to the Reg T ceiling of about 2.0x in
- What does it show about financing, collateral, custody and costs? (my inference)
- Custody: U.S. Bank holds fund assets. Shorts are made through an unnamed broker with a margin deposit. This fits Tidal's point in
fund_context.mdthat shorts sit away from the main custodian. But ORR's documents never say where the collateral or the longs bought with short proceeds are held. - Costs: the 9.61% short-cost line shows how the short dividend trap in
fund_context.mdcan swamp a fund's expense ratio. Shorting high-yield ETFs and BDCs inflates reported cost without being financing. A peer comparison by expense ratio would overstate ORR's financing cost. - Financing cost in the
fund_context.mdformulas: ORR's 99.6% (long + cash - short) suggests short proceeds fund the extra longs, leaving no broker debit. Its cost above the base rate would then be about $68.3 × c + $68.3 × b per $100 (my arithmetic). Ours would be $150 × c + $50 × d + $150 × b. - Economics: the sub-adviser sponsors the fund under a unitary fee and bears the shortfall risk, while short costs sit outside the unitary fee and are borne by the fund. This is a model our fund could also use on a white-label platform.
- Custody: U.S. Bank holds fund assets. Shorts are made through an unnamed broker with a margin deposit. This fits Tidal's point in
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, collateral and longs bought with short proceeds are held: at U.S. Bank under a control agreement, or at the broker.
- Whether long stocks are pledged to the broker.
- How 9.61% splits between short dividends, borrow fees, interest and broker costs. The annual report for the year ended November 30, 2025 (Form N-CSR) would have these figures, but it wasn't attached.
- Short-cost figures for the fiscal year ended November 30, 2026.
- Which Rule 18f-4 VaR test ORR uses, its reference portfolio, and who its derivatives risk manager is.
- Whether index futures, currency forwards or options are actually used.
- Commodity pool status under CFTC Rule 4.5.
- Morningstar category and rating.
Questions to ask:
- To ETF Architect: Who is ORR's prime broker? Is the account Reg T or portfolio margin? Under Rule 17f-1, or a tri-party arrangement with U.S. Bank?
- To ETF Architect: How did ORR open a book that needs about 104% Reg T opening margin (my arithmetic)? Is the gross level held by drift or by a different margin setup?
- To the fund: What were short dividend expense and borrow fees, separately, for each fiscal year?
- To the fund: Does ORR use options, as the fact sheet risk text says? Where are the FLEX options it mentions?
- To ETF Architect: Which VaR test and reference portfolio did the board approve under Rule 18f-4?
- To ETF Architect: What did the June 9, 2026 SAI supplement change?
- To ETF Architect: Why does the fee table have no acquired fund fees line, and what was footnote 2 meant to say?
Search terms tried for fields left "Not stated":
- Prime broker and margin type: prime broker, borrow, margin, Regulation T, portfolio margin, pledge, segregat, collateral.
- Leverage cost split: short sale, sold short, dividend, interest expense, borrowing, line of credit, credit facility, swap, box spread, reverse repurchase.
- VaR test: value at risk, VaR, 18f-4, derivatives risk manager, limited derivatives user.
- Commodity pool: Rule 4.5, commodity pool.
- Counterparties: swap, counterparty.
- Morningstar: Morningstar (fact sheet only).
- History: predecessor, reorganiz, 351.
14. Documents used
| Code | Document | Date | Pages | Pages read | File name |
|---|---|---|---|---|---|
| ORR-FS | Fact sheet | Data as of September 30, 2026 (marked ETFAC-5992969-10/26) | 2 | 1 to 2 (all, text and page images) | 80e563c6-ORR_fact_sheet.pdf |
| ORR-PR | Prospectus, with supplement dated August 21, 2026 bound in front | Prospectus March 31, 2026; supplement August 21, 2026 | 25 | In full: 1 to 13, 17 to 19, 24, 25 (page 4 also as image). Headings only: 14 to 16. Keyword passages only: 20 to 22. | ee645c9b-ORR_prospectus.pdf |
| ORR-SAI | Statement of Additional Information | March 31, 2026, as supplemented June 9, 2026 | 138 | In full: 1 to 6, 10 to 17, 21 to 26. Keyword passages only: 7 to 9, 27 to 30, 32, 38, 39, 43 to 45. Pages 46 to 138 checked by first lines only (tax pages, then Appendix A proxy voting guidelines). | e4d5e7e3-ORR_SAI.pdf |
Page numbering.
- ORR-FS: PDF pages 1 and 2 are printed "Page 1 of 2" and "Page 2 of 2".
- ORR-PR: PDF page 1 is the supplement (no printed number). PDF page 2 is the cover and PDF page 3 is the contents (no printed numbers). From PDF page 4 on, PDF page = printed page + 3. The fund summary is PDF pages 4 to 10 (printed 1 to 7). The prospectus covers only ORR.
- ORR-SAI: PDF page 1 is the cover and contents (no printed number). From PDF page 2 on, PDF page = printed page + 1, through PDF page 48 (printed 47). PDF pages 49 to 138 are Appendix A (printed A-1 onward). The SAI covers only ORR.
15. Snapshot sources
- Ticker: ORR-FS, page 1, "Fund information" ("Ticker ORR").
- Fund name: ORR-FS, page 1, header. On the peers list.
- As of date: "As of September 30, 2026" (ORR-FS, page 1, header).
- Adviser: ORR-FS, page 1, "Fund information" ("Adviser Empowered Funds, LLC"); ORR-PR, page 17, "Investment Adviser" ("Empowered Funds, LLC dba EA Advisers").
- Platform: "The Fund's investment adviser is Empowered Funds, LLC, which is doing business as ETF Architect." (ORR-FS, page 2). The fund is a series of EA Series Trust (ORR-SAI, page 1).
- Exchange: ORR-FS, page 1, "Quick facts" ("Exchange Nasdaq"); ORR-PR, page 2, cover.
- Inception: ORR-FS, page 1, "Quick facts" ("Inception date January 14, 2025").
- Net assets: ORR-FS, page 1, "Quick facts" ("Fund net assets $345.44 million"), as of September 30, 2026.
- Strategy type: (my inference) from the fund name, "long/short global equity strategy" (ORR-FS, page 1), and net exposure of 72.4% (ORR-FS, page 1). It is not market neutral.
- Long %: ORR-FS, page 1, "Portfolio characteristics" ("Long exposure 140.6%").
- Short %: ORR-FS, page 1, "Portfolio characteristics" ("Short exposure 68.3%").
- Gross: ORR-FS, page 1, "Portfolio characteristics" ("Gross exposure 208.9%"). Converted to 2.09x (my arithmetic).
- Above 2.0x: 2.09x is above 2.0x (my arithmetic).
- Net: ORR-FS, page 1, "Portfolio characteristics" ("Net exposure 72.4%").
- Short method: "When the Fund sells securities short, it sells a security that it does not own (but has borrowed)" (ORR-PR, page 5). Short book by gross: index ETFs 65.4%, single-name equities 21.6%, BDCs and yield vehicles 13.0% (ORR-FS, page 2), all direct short sales. Futures are permitted only (ORR-PR, page 5).
- Prime broker or counterparty: no firm named. The prospectus says only "its prime broker" (ORR-PR, page 6); the SAI says "the broker-dealer through which the short sale is made" (ORR-SAI, page 16).
- Custodian: "U.S. Bank National Association is the custodian for the Fund." (ORR-PR, page 19); ORR-SAI, page 24, "Custodian".
- Management fee: ORR-PR, page 4, "Fees and Expenses" ("Management Fee 1.30%"); ORR-FS, page 1. Unitary (ORR-PR, page 18).
- Total expense ratio: ORR-PR, page 4 ("Total Annual Fund Operating Expenses 10.91%"); ORR-FS, page 1, "Quick facts" (expense ratio 10.91%, footnote 2). No waiver line.
- Short costs in expense ratio: the fee table includes "Dividend Expense, Borrowing Costs and Brokerage Expenses on Short Sales" at 9.61% (ORR-PR, page 4). The fact sheet says the expense ratio "includes all fund operating expenses including interest and dividend expense from short sales" (ORR-FS, page 1, footnote 2).
- 3-month return: +3.89% at NAV, 3 months to September 30, 2026 (ORR-FS, page 1, "Performance history").
- 1-year return: +20.17% at NAV, 1 year to September 30, 2026 (ORR-FS, page 1, "Performance history").
- Beta: "Current 0.48" on the rolling 60-day beta chart (ORR-FS, page 2); "Est. portfolio beta (vs Solactive GBS All Cap) 0.48" (ORR-FS, page 1).
- Beta benchmark: "Rolling 60-day beta vs. Solactive GBS All Cap" (ORR-FS, page 2). The index is described as "a broad-based global equity index across developed and emerging markets" (ORR-FS, page 2).
- Beta period: "Rolling 60-day" (ORR-FS, page 2), current value as of September 30, 2026.
- Leverage Method: "When the Fund sells securities short, it sells a security that it does not own (but has borrowed)" (ORR-PR, page 5); "The Fund is required to make a margin deposit in connection with such short sales" (ORR-SAI, page 16). No document says Reg T, Regulation T or portfolio margin. Longs above 100% appear to be funded by short proceeds, since long + cash - short = 99.6% (my arithmetic, my inference). Futures, leveraged ETFs, options and box spreads are permitted only (ORR-PR, page 5; ORR-SAI, page 14).
- Leverage cost: 9.61% of average net assets, annualized, for the fiscal period January 14 to November 30, 2025 (ORR-PR, page 24, "Financial Highlights", "Ratio of dividends, interest and borrowing expenses on securities sold short to average net assets"). The fee table line also includes brokerage expenses on short sales (ORR-PR, page 4). Not split.
- Short dividend expense: combined in the 9.61% above (ORR-PR, page 4; ORR-PR, page 24).
- 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: 6 of 27, as of November 11, 2026.
- Long/short: 140.6% long and 68.3% short, with 164 long and 34 short positions, on September 30, 2026 (ORR-FS, page 1).
- Portfolio margin: POSSIBLE. The fund shorts directly through "its prime broker" (ORR-PR, page 6), and no document says Reg T or portfolio margin. At 2.09x gross, a Reg T opening check needs about 104% of net assets in margin equity (ORR-FS, page 1; my arithmetic).
- Cross-collateral: Not stated. "The Fund is required to make a margin deposit in connection with such short sales" (ORR-SAI, page 16). What the deposit consists of, and whether long stocks are pledged, is not stated.
- Outside Reg T: Not stated.
- Short costs (includes dividends): No. 9.61% of average net assets, annualized, for January 14 to November 30, 2025, combining dividends, interest and borrowing expenses on securities sold short (ORR-PR, page 24).
- Over 2.0x: Yes. 2.09x on September 30, 2026 (ORR-FS, page 1).
- Tidal: No. The fund is a series of EA Series Trust, on the ETF Architect platform (ORR-SAI, page 1; ORR-FS, page 2).
- Score: 2 (my arithmetic).