CLSE

1. Summary

• CLSE is an actively managed U.S. long/short equity ETF. A quantitative stock ranking model (valuation, growth, momentum and quality factors) picks mid and large cap stocks to buy and to sell short.
• It is net long, not market neutral. It targets 90% to 150% long, 20% to 70% short and 50% to 100% net. On September 30, 2026 it was 116.5% long and 55.6% short, so about 1.72x gross and 60.9% net (my arithmetic).
• It shorts directly through "prime brokerage arrangements" and may reinvest short sale proceeds in extra longs. No broker is named and no margin type (Reg T or portfolio margin) is stated.
• Most relevant for us: CLSE shows the cost of a direct-short book in plain view. Short dividends, interest and broker expenses were 0.57% of average net assets in fiscal 2025, on top of a 0.95% unitary fee. But it runs well below 2.0x gross, so it is no precedent for 3.0x.

2. Key facts

3. Service providers

Legal counsel: Godfrey & Kahn, S.C. (CLSE-SAI, page 33, "Legal Counsel").

4. Strategy

• Objective and benchmark. "to seek long-term capital growth" (CLSE-PR, page 3, "Investment Objective"). The prospectus compares returns with the Bloomberg US 3000 Total Return Index (CLSE-PR, page 7, "Average Annual Total Returns"). The fact sheet also shows the Morningstar Long-Short Equity category (CLSE-FS, page 1).
• Universe. At least 80% of net assets "in long and short positions in equity securities of domestic companies" (CLSE-PR, page 3, "Principal Investment Strategies"). It focuses on mid and large caps, defined as the upper half of the Bloomberg US 3000 Total Return Index. On January 31, 2026 that meant market caps from $2.20 billion up (CLSE-PR, page 9, "Principal Investment Strategies"). It may hold any size and may hold foreign stocks through ADRs as a non-principal strategy (CLSE-PR, page 10, "General Investment Policies of the Fund"). The short book also holds at least one ETF: iShares Semiconductor ETF at -1.22% (CLSE-FS, page 2, "Top Short Positions").
• How it picks stocks. Both quantitative and fundamental. The ranking process "was designed to capture the best attributes of both quantitative and fundamental methods" (CLSE-PR, page 4, "Principal Investment Strategies"). It scores valuation, growth, momentum and quality factors. "The Adviser aggregates similar measures into factors and each measure is equally weighted" (CLSE-PR, page 4).
• Neutrality targets. None. No beta, dollar or sector neutrality target is stated. Sector weights on 09/30/2026 were far from matched. For example, Information Technology was 43.9% long and 20.0% short (CLSE-FS, page 2, "Long Sector Allocation" and "Short Sector Allocation").
• Net exposure. "approximately 50% to 100% of the Fund's net assets" (CLSE-PR, page 3, "Principal Investment Strategies"). On 09/30/2026: 116.5% minus 55.6% is 60.9% (my arithmetic). The fact sheet gives a beta of 1.00 for the long book and 1.32 for the short book (trailing five years, current holdings). Weighting those by exposure gives a beta-adjusted net of about 43% (my arithmetic).
• Limits on position size. The fund is diversified. For 75% of total assets, it may not hold more than 5% of total assets in one issuer or more than 10% of an issuer's voting stock. It may not put 25% or more of total assets in one industry (CLSE-SAI, pages 20 and 21, "Investment Restrictions"). The largest long on 09/30/2026 was Nvidia at 6.31%. The largest short was 1.22% (CLSE-FS, page 2).

5. Exposure and leverage

• Measured exposure, as of 09/30/2026 (CLSE-FS, page 2, sector allocation totals):
  • Long 116.5% and short 55.6%. The fact sheet labels these "Percent" but doesn't say percent of what. I read them as percent of net assets (my inference).
  • Gross 172.1%, or 1.72x (my arithmetic). Net 60.9% (my arithmetic).
• Stated ranges. Under normal conditions the fund's "long positions may range from approximately 90% to 150% of the Fund's net assets and its short positions may range from approximately 20% to 70% of the Fund's net assets" (CLSE-PR, pages 3 and 4, "Principal Investment Strategies"; also page 9). Net 50% to 100% (CLSE-PR, page 3). The top of the ranges (150% long, 70% short) would be 2.2x gross (my arithmetic). No gross target is stated.
• How it gets exposure above 100%. Reinvested short sale proceeds: "The Fund may reinvest the proceeds of its short sales by taking additional long positions, thus allowing the Fund to maintain long positions in excess of 100% of its net assets" (CLSE-PR, page 9, "Principal Investment Strategies"). The 116.5% long book suggests it does this in practice (my inference). No swaps, futures or bank loans are described as used.
• Cash position. If short proceeds count as cash, 100% + 55.6% - 116.5% leaves about 39% of net assets in cash or collateral (my arithmetic). So the book does not need net borrowing (my inference).
• Borrowing limits. Fundamental policy: the fund "may borrow from banks in amounts not exceeding one-third (33 1/3%) of its total assets (including the amount borrowed)" (CLSE-SAI, page 20, "Investment Restrictions"). That equals 300% asset coverage (my inference). No line of credit is named.

6. Shorting, financing and collateral

• How it shorts. Direct short sales only. "When the Fund sells a security short, it borrows the security from a third party and sells it at the then-current market price" (CLSE-PR, page 9). "Interest expenses result from the Fund's use of prime brokerage arrangements to execute short sales" (CLSE-PR, page 3, footnote 1). No split between methods is given because no other method is described as used.
• Who lends the stock and who holds collateral. The lender is "a third party" (CLSE-PR, page 9). No firm is named. "The net proceeds of the short sale will be retained by the broker (or by the Fund's custodian in a special custody account), to the extent necessary to meet margin requirements, until the short position is closed out" (CLSE-SAI, page 9, "Short Sales").
• What is posted. The SAI describes "collateral deposited with the broker" plus segregated "liquid assets" so that together they equal the market value of the shorts (CLSE-SAI, page 9). The type of collateral (cash, Treasuries or long stocks) is not stated. Whether long positions are pledged is not stated. The fundamental borrowing policy bars pledging assets but "shall not prohibit the Fund from engaging in options transactions or short sales" (CLSE-SAI, page 20).
• Short sale proceeds used to buy longs. Permitted ("may reinvest"), and the 116.5% long book points to actual use (CLSE-PR, page 9; my inference).
• Segregated or tri-party account. The SAI mentions a possible "special custody account" at the custodian and segregated assets (CLSE-SAI, page 9). The prospectus says the fund "is also required to segregate other assets on its books" (CLSE-PR, page 14, "Short Sales Risk", which starts on page 13). No tri-party agreement is named. The SAI also says the custodian "has custody of all assets and securities of the Fund" (CLSE-SAI, page 33, "Custodian"). That sits uneasily with proceeds "retained by the broker" (my inference).
• Margin. The prospectus names "margin account maintenance costs" (CLSE-PR, page 13, "Short Sales Risk"). The SAI says proceeds are held "to meet margin requirements" (CLSE-SAI, page 9). Neither says Reg T, Regulation T or portfolio margin.
• Securities lending. A non-principal strategy. Loans may not exceed "one-third of the Fund's total net assets" and must be fully collateralized (CLSE-SAI, page 17, "Securities Lending"; CLSE-PR, page 10). The documents don't say whether CLSE actually lends.

7. Derivatives and Rule 18f-4

• Derivatives used or permitted. "The Fund may invest in derivative securities as a non-principal investment strategy" (CLSE-SAI, page 13, "Derivatives"). The SAI names "equity swaps and equity-basket swaps" (CLSE-SAI, page 14, "Swap Agreements"). The commodities policy does not prevent "futures contracts and options thereon" (CLSE-SAI, page 20). The borrowing policy allows "options transactions" (CLSE-SAI, page 20). None is described as a principal strategy or as in use.
• Limited derivatives user or full program. Full program: "The Fund has implemented a derivatives risk management program that complies with Rule 18f-4" (CLSE-SAI, page 14). So it is not a limited derivatives user (my inference). The derivatives risk manager is not named.
• VaR test and reference portfolio. The SAI says only that "a fund's derivatives exposure is limited through a value-at-risk test" (CLSE-SAI, page 14). VaR (value at risk) estimates the most a fund could lose over a set period at a set confidence level. Relative or absolute test and reference portfolio: Not stated.
• Commodity pool status (CFTC Rule 4.5). Not stated. The CFTC is mentioned only as a regulator of derivatives (CLSE-SAI, page 14).

8. Costs

• Who pays what. The fund pays the 0.95% unitary fee plus the excluded items above. The adviser pays U.S. Bancorp Fund Services for administration and accounting ($45,000 a year in fiscal 2023 to 2025) and pays the custodian's fees (CLSE-SAI, page 33, "Custodian"). Before the 2022 reorganization the predecessor paid an advisory fee of 1.00% (CLSE-PR, page 15, "The Adviser").
• Short costs by year (expense ratio minus the ratio excluding short dividends, interest and broker expenses, after reimbursement; CLSE-PR, page 21, footnote (f)). All (my arithmetic):
  • Fiscal 2025: 1.52% minus 0.95% = 0.57%.
  • Fiscal 2024: 1.44% minus 0.95% = 0.49%.
  • Fiscal 2023: 1.55% minus 0.95% = 0.60%.
  • Fiscal 2022: 1.38% minus 1.08% = 0.30%.
  • Fiscal 2021: 2.11% minus 1.50% = 0.61%.
• Brokerage commissions (fiscal years ended November 30): $215,186 (2025), $122,303 (2024), $35,690 (2023). All of fiscal 2025's commissions went to brokers that provided research (CLSE-SAI, page 36, "Brokerage Commissions").
• Portfolio turnover: 262% (2025), 225% (2024), 284% (2023), 244% (2022), 304% (2021, "includes in-kind transactions") (CLSE-PR, page 21; CLSE-SAI, page 37, "Portfolio Turnover").
• Gap between total expense ratio and management fee. 1.52% minus 0.95% = 0.57% (my arithmetic). The fee table explains it all as "Dividends and Interest on Short Positions" (CLSE-PR, page 3). The documents don't split the 0.57% between short dividends and financing. Brokerage commissions are outside the expense ratio.

9. Performance and risk

Average annual total returns through September 30, 2026 (CLSE-FS, page 1, "Average Annual Total Returns"). Periods under a year are not annualized.

Returns before listing on February 22, 2022 use the predecessor mutual fund's NAV for both NAV and market price (CLSE-FS, page 1, disclosures). No 3-month return is given.

Prospectus returns before taxes, periods ended December 31, 2025: 20.60% (1 year), 18.79% (5 years), 12.59% (10 years), against 17.21%, 13.09% and 14.27% for the Bloomberg US 3000 Total Return Index (CLSE-PR, page 7, "Average Annual Total Returns"). Best quarter 19.70% (quarter ended March 31, 2024). Worst quarter -18.08% (quarter ended March 31, 2020) (CLSE-PR, page 7).

Calendar-year returns at NAV (CLSE-FS, page 1, "Calendar Year Total Returns"; CLSE-PR, page 7, "Calendar Year Returns as of December 31"):

Conflict: the two documents differ by 0.01 to 0.02 points for 2017, 2018 and 2021.

Fiscal-year total returns (years ended November 30): 17.13% (2025), 39.57% (2024), 11.28% (2023), 2.39% (2022), 28.26% (2021) (CLSE-PR, page 21).

Risk statistics, 3 years as of 09/30/2026, at NAV (CLSE-FS, page 1, "3-Year Statistics"):

• Standard deviation 11.39% (Bloomberg US 3000: 12.90%).
• Alpha 12.23%. Beta 0.71. Sharpe ratio 2.16. Correlation 0.81.
• The Bloomberg US 3000 row shows beta 1.00 and alpha 0.00%, so it is the reference index (my inference).
• Drawdown and up and down capture: Not stated.

10. History and structural changes

• Predecessor fund. Convergence Long/Short Equity Fund, a mutual fund series of the same trust, advised by the same adviser. It began in December 2009 (CLSE-PR, page 8, "Portfolio Managers"; CLSE-FS, page 1). It was named Convergence Core Plus Fund until June 18, 2019 (CLSE-SAI, page 3, "The Trust").
• Mutual fund to ETF conversion. "The Predecessor Fund converted to an ETF as a result of the reorganization of the Predecessor Fund into the Fund on February 18, 2022" (CLSE-PR, page 6, "Performance"). The ETF listed on February 22, 2022 (CLSE-FS, page 1). This was a fund reorganization, not a 351 conversion of a private fund. Section 351 appears only in a rule letting the trust reject creation orders (CLSE-SAI, page 52).
• Fee change. The predecessor paid 1.00%. The ETF pays a 0.95% unitary fee (CLSE-PR, pages 14 and 15).
• Adviser name changes. Founded in November 2004 as QIS Advisors, LLC. Renamed Mariner Quantitative Solutions, LLC on December 16, 2008, and Convergence Investment Partners, LLC on January 27, 2011 (CLSE-PR, page 15, "The Adviser").
• Document dates.
  • The prospectus is dated "March 30, 2026, as supplemented October 21, 2026" (CLSE-PR, page 1). It has no separate supplement page, and it doesn't say what the October 21, 2026 supplement changed.
  • The SAI is dated March 30, 2026 and shows no supplement (CLSE-SAI, page 1). It is older than the October 21, 2026 prospectus supplement.
  • The fact sheet data are as of September 30, 2026, so it is also older than the October 21, 2026 supplement.
• Other conflicts.
  • Calendar-year returns differ slightly between the fact sheet and the prospectus (section 10).
  • The fact sheet says "a mutual fund investor's risk is limited to one's amount of investment in a mutual fund" (CLSE-FS, page 2, disclosures). That wording looks left over from the mutual fund era (my inference).

11. Principal risks

Summary list: CLSE-PR, pages 4 to 6, "Principal Risks". Longer descriptions: CLSE-PR, pages 10 to 14, "Principal Risks of Investing in the Fund".

• General Market Risk (page 4; also page 12).
• Short Sales Risk (page 4; also pages 13 and 14). Flag: shorting. "theoretically unlimited loss". The long version adds lender recalls, borrowing and margin account costs, short dividends, and assets that must be segregated.
• Management Risk (page 4; also page 13).
• ETF Risk (page 5; also pages 11 and 12): Authorized Participants, Market Makers, and Liquidity Providers Concentration Risk; Cash Redemption Risk (flag: shorting, since the strategy may force cash redemptions); Costs of Buying or Selling Shares; Shares May Trade at Prices Other Than NAV; Trading.
• Recent Market Events Risk (page 5; also page 13).
• Common Stock Risk (page 5; also pages 10 and 11).
• Large-Capitalization Company Risk (page 6; also pages 12 and 13).
• Medium-Capitalization Company Risk (page 6; also page 13).
• Small- and Micro-Capitalization Company Risk (page 6; also page 14).
• Sector Risk, with Computer and Electronic Product Manufacturing Sub-Sector Risk (page 6; also page 14).
• High Portfolio Turnover Rate Risk (page 6; also page 12).
• Cybersecurity Risk (page 6; also page 11). Flag: counterparties. The long version names incidents at "counterparties with which the Fund engages in transactions".
• Foreign Securities Risk (page 12 only; not in the summary).
• Securities Lending Risk (page 13 only; not in the summary). Flag: counterparties. Borrower "default or insolvency".

No principal risk is named for leverage, the prime broker or swap counterparties.

12. Relevance to our fund

• How close is its structure and leverage? Not close (my inference). CLSE is net long (60.9%), not market neutral, and runs 1.72x gross, not 3.0x. It shares some features with our plan: a 40 Act ETF, a quantitative multi-factor model, a broad book (164 long, 219 short), U.S. stocks and direct shorting. But it is on a U.S. Bank series trust, not Tidal.
• What does it show about 3.0x gross in a 40 Act ETF? (my inference)
  • Not much. Its stated maximum (150% long, 70% short) is 2.2x gross (my arithmetic). Its actual 1.72x fits within the Reg T cap of about 2.0x in fund_context.md.
  • Its route to more than 100% long matches ours: reinvest short sale proceeds in extra longs. At 150/150 that route needs more than Reg T allows, which CLSE never tests.
  • Like ORR and BTAL in fund_context.md, it is a direct-short ETF that doesn't state its margin type.
• What does it show about financing, collateral, custody and costs? (my inference)
  • Cost visibility: CLSE reports short costs inside its expense ratio, unlike swap-based funds such as NTRL where they hide in swap returns. But its 0.57% lumps short dividends with interest and broker expenses. So we can't isolate the borrow fee (b) or the rebate shortfall (c) from the fund_context.md formulas.
  • Scale check: 0.57% on a short book of about 56% is about 1.0% of short exposure per year, including dividends (my arithmetic). At 150% short, the same rate would be about 1.5% of net assets before any margin debit (my arithmetic). Most of that would likely be dividends, which aren't a true financing cost.
  • Custody: the SAI lets short proceeds sit with "the broker" or in a "special custody account" at U.S. Bank (CLSE-SAI, page 9, "Short Sales"). That supports the Tidal view that shorts sit away from the main custodian, with a possible special custody account as a middle path.
  • Unitary fee: like many platform ETFs, the unitary fee excludes short costs. We should expect the same split on Tidal.
  • Rule 18f-4: CLSE runs a full derivatives risk management program even though it describes no derivatives as principal. Short sales count as derivatives exposure under the rule (fund_context.md). A 150/150 book would need the same full program.

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).
• How the 0.57% splits between short dividends, borrow fees, margin interest and broker expenses.
• Where longs bought with short proceeds sit (U.S. Bank or the broker), and whether longs are pledged as collateral.
• Whether a special custody account or tri-party agreement is in use.
• Which Rule 18f-4 VaR test the fund uses and the reference portfolio.
• What the October 21, 2026 prospectus supplement changed.
• Net assets and exposure on dates after November 30, 2025 (net assets) and September 30, 2026 (exposure).
• Whether the fund lends securities, and through which agent.
• CFTC Rule 4.5 status.

Questions to ask:

• To Convergence: Which firm is your prime broker, and is the account Reg T or portfolio margin?
• To Convergence: What were fiscal 2025's short dividends versus borrow fees and interest within the 0.57%?
• To Convergence or U.S. Bank: Are short proceeds and longs held at the broker under Rule 17f-1, or in a special custody account at U.S. Bank?
• To Convergence: Has the fund ever run near the 150% long / 70% short top of its ranges? What limited it?
• To Convergence: Which VaR test and reference index did the board approve under Rule 18f-4?
• To Tidal: Would Tidal accept a direct-short structure like CLSE's at 150/150, and with which margin arrangement?

Search terms tried for fields left "Not stated":

• Prime broker and margin type: prime broker, borrow, margin, Regulation T, portfolio margin, counterparty, pledge, segregat, special custody, tri-party, 17f.
• Leverage cost split: short sale, sold short, interest, borrowing, line of credit, swap, box spread, reverse repurchase.
• VaR test: value at risk, 18f-4, derivatives risk manager, limited derivatives user.
• Commodity pool: Rule 4.5, commodity pool, CFTC, Commodity Exchange Act, futures, options.
• Securities lending agent: securities lending, lend.
• 3-month return and recent net assets: fact sheet read in full.
• Supplement: supplement, October 21.

14. Documents used

Page numbering.

• CLSE-FS: no printed page numbers.
• CLSE-PR: PDF pages 1 and 2 (cover and contents) have no printed number. From PDF page 3 on, PDF page = printed page + 2. The summary section is PDF pages 3 to 8.
• CLSE-SAI: PDF page 1 (cover) has no printed number. From PDF page 2 on, PDF page = printed page + 1.

No annual report was attached. Fiscal-year figures come from the prospectus's financial highlights and the SAI.

15. Snapshot sources

• Ticker: CLSE-FS, page 1, "Overview" ("Fund Ticker CLSE").
• Fund name: CLSE-FS, page 1, header.
• As of date: "As of 09/30/2026" (CLSE-FS, page 1, header).
• Adviser: CLSE-PR, page 7, "Management"; CLSE-FS, page 1, disclosures.
• Platform: (my inference). The fund is "a series of Trust for Professional Managers" (CLSE-SAI, page 1). The trust has "thirty other series" (CLSE-SAI, page 29). U.S. Bancorp Fund Services is administrator, accountant and transfer agent (CLSE-SAI, page 32), and trust officers work for it (CLSE-SAI, pages 23 and 24).
• Exchange: "Primary Listing CBOE" (CLSE-FS, page 1, "Overview"); "Listed on Cboe BZX Exchange, Inc." (CLSE-PR, page 1, cover).
• Inception: "Fund Inception Date 12/29/2009" (CLSE-FS, page 1, "Overview"); "Prior to listing on February 22, 2022, the ETF operated as a mutual fund" (CLSE-FS, page 1, disclosures).
• Net assets: "Net assets, end of year (in thousands)" $256,780 for the year ended November 30, 2025 (CLSE-PR, page 21, "Financial Highlights"). The fact sheet gives no net assets.
• Strategy type: (my inference) from a net long target of "approximately 50% to 100% of the Fund's net assets" (CLSE-PR, page 3, "Principal Investment Strategies").
• Long %: "Total 116.5" (CLSE-FS, page 2, "Long Sector Allocation"), as of 09/30/2026. Basis taken as net assets (my inference).
• Short %: "Total 55.6" (CLSE-FS, page 2, "Short Sector Allocation"), as of 09/30/2026. Basis taken as net assets (my inference).
• Gross: 116.5% plus 55.6% = 172.1%, or 1.72x (my arithmetic).
• Above 2.0x: 1.72x is below 2.0x (my arithmetic).
• Net: 116.5% minus 55.6% = 60.9% (my arithmetic).
• Short method: "When the Fund sells a security short, it borrows the security from a third party and sells it at the then-current market price" (CLSE-PR, page 9, "Principal Investment Strategies").
• Prime broker or counterparty: only "prime brokerage arrangements" (CLSE-PR, page 3, footnote 1). No firm is named.
• Custodian: CLSE-SAI, page 33, "Custodian"; CLSE-PR, page 22.
• Management fee: CLSE-PR, page 3, "Fees and Expenses of the Fund". It is a unitary fee (CLSE-PR, page 14, "The Adviser").
• Total expense ratio: "Total Annual Fund Operating Expenses 1.52%" (CLSE-PR, page 3); "Total Expense Ratio on the fund is applicable to investors is 1.52%" (CLSE-FS, page 1, disclosures). No waiver line.
• Short costs in expense ratio: "Dividends and Interest on Short Positions(1) 0.57%" is a line in the fee table (CLSE-PR, page 3).
• 3-month return: not given. The fact sheet shows month, year to date, 1, 3, 5 and 10 years and since inception, through September 30, 2026 (CLSE-FS, page 1, "Average Annual Total Returns").
• 1-year return: 31.84% at NAV, 1 year to September 30, 2026 (CLSE-FS, page 1, "Average Annual Total Returns").
• Beta: 0.71, CLSE @ NAV (CLSE-FS, page 1, "3-Year Statistics (As of 09/30/2026)").
• Beta benchmark: (my inference) the Bloomberg US 3000 row shows beta 1.00 and alpha 0.00% in the same table (CLSE-FS, page 1, "3-Year Statistics").
• Beta period: "3-Year Statistics (As of 09/30/2026)" (CLSE-FS, page 1).
• Leverage Method: "Interest expenses result from the Fund's use of prime brokerage arrangements to execute short sales" (CLSE-PR, page 3, footnote 1); "it borrows the security from a third party" (CLSE-PR, page 9); "The Fund may reinvest the proceeds of its short sales by taking additional long positions" (CLSE-PR, page 9). The documents mention "margin requirements" (CLSE-SAI, page 9) but never Reg T, Regulation T or portfolio margin.
• Leverage cost: "Dividends and Interest on Short Positions" 0.57% (CLSE-PR, page 3). For fiscal 2025, 1.52% minus 0.95% excluding "dividends on short positions, interest and broker expenses" = 0.57% (my arithmetic, from CLSE-PR, page 21, "Financial Highlights", footnote (f)).
• Short dividend expense: reported together with interest and broker expenses (CLSE-PR, page 3, footnote 1; CLSE-PR, page 21, footnote (f)).
• 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: 7 of 27, as of November 11, 2026.
• Long/short: 90% to 150% long and 20% to 70% short (CLSE-PR, pages 3 and 4); 164 long and 219 short holdings on September 30, 2026 (CLSE-FS, page 2).
• Portfolio margin: POSSIBLE. The fund shorts through "prime brokerage arrangements" (CLSE-PR, page 3, footnote 1) and may reinvest short sale proceeds in longs (CLSE-PR, page 9). No document says Reg T or portfolio margin.
• Cross-collateral: Not stated. Short collateral is "collateral deposited with the broker" plus segregated liquid assets (CLSE-SAI, page 9). Whether long stocks are pledged is not stated.
• Outside Reg T: Not stated.
• Short costs (includes dividends): Partly. 0.57% for the fiscal year ended November 30, 2025, including dividends, interest and broker expenses on short positions (CLSE-PR, page 21).
• Over 2.0x: No. 1.72x on September 30, 2026 (CLSE-FS, page 2; my arithmetic).
• Tidal: No. The fund is a series of Trust for Professional Managers (CLSE-SAI, page 1).
• Score: 1.5 (my arithmetic).

16. Fund Documents

Fact Sheet

Prospectus

SAI