N-CSR 1 setf-ncsra.htm SALT ETFS ANNUAL REPORT 12-31-19
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549


FORM N-CSR

CERTIFIED SHAREHOLDER REPORT OF REGISTERED
MANAGEMENT INVESTMENT COMPANIES


Investment Company Act file number 811-22668


ETF Series Solutions
(Exact name of registrant as specified in charter)


615 East Michigan Street
Milwaukee, WI 53202
(Address of principal executive offices) (Zip code)


Kristina R. Nelson
ETF Series Solutions
615 East Michigan Street
Milwaukee, WI 53202
(Name and address of agent for service)


(414) 765-6076
Registrant's telephone number, including area code



Date of fiscal year end: December 31


Date of reporting period:  December 31, 2019


Item 1. Reports to Stockholders.





Annual Report
December 31, 2019
 

 
 
Salt High truBeta US Market ETF
Ticker: SLT

Salt Low truBeta US Market ETF
Ticker: LSLT


Beginning on January 1, 2021, as permitted by regulations adopted by the U.S. Securities and Exchange Commission, paper copies of the Funds’ shareholder reports will no longer be sent by mail, unless you specifically request paper copies of the Funds’ reports from your financial intermediary, such as a broker-dealer or bank. Instead, the reports will be made available on a website, and you will be notified by mail each time a report is posted and provided with a website link to access the report.
 
If you already elected to receive shareholder reports electronically, you will not be affected by this change and you need not take any action. Please contact your financial intermediary to elect to receive shareholder reports and other Fund communications electronically.
 
You may elect to receive all future reports in paper free of charge. Please contact your financial intermediary to inform them that you wish to continue receiving paper copies of shareholder reports and for details about whether your election to receive reports in paper will apply to all funds held with your financial intermediary.
 

Salt ETFs

TABLE OF CONTENTS
 
 
Page
Letters to Shareholders
  1
Performance Summaries
  4
Portfolio Allocations
  8
Schedules of Investments
10
Statements of Assets and Liabilities
18
Statements of Operations
19
Statements of Changes in Net Assets
20
Financial Highlights
22
Notes to Financial Statements
24
Report of Independent Registered Public Accounting Firm
33
Trustees and Officers
35
Expense Examples
37
Approval of Advisory Agreement and Board Consideration
39
Federal Tax Information
44
Information About Portfolio Holdings
44
Information About Proxy Voting
44
Frequency Distribution of Premiums and Discounts
45


Salt High truBeta US Market ETF

Dear Salt High truBeta US Market ETF Shareholders,
 
Thank you for your investment in the Salt High truBeta US Market ETF (the “Fund” or “SLT”).  The information presented in this report relates to the operations of SLT for the period from Jan 1, 2019 through December 31, 2019 (the “Period”).
 
The Fund seeks to track the performance, before fees and expense, of the Salt High truBeta US Market Index (the “Index” or “High truBeta Index”), developed by Salt Financial Indices LLC. The Index uses truBeta estimates to select stocks with the highest sensitivity to the SPDR S&P 500 ETF (“SPY”). The objective is to magnify exposure to the SPY without the use of borrowing or derivatives through systematic stock selection by targeting higher beta securities with greater accuracy. With a historical average truBeta estimate of approximately 1.50, the Index seeks to capture 50% more variation than the market in the same direction.
 
For the Period, the Fund was up 37.93% at market and up 37.32% at NAV. This compares to the underlying Index which was up 38.03% and the S&P 500 Index (“S&P”), a broad market index, which was up 31.49% during the same Period. As a higher beta strategy with more sensitivity to market moves, the Fund outperformed the S&P as expected. In comparison, the S&P High Beta Index, which has a similar investing strategy to the Index, increased 34.44% over the Period.
 
As of December 31, the Fund was overweight Information Technology, Materials, and Energy stocks and underweight Health Care, Utilities, and Real Estate stocks relative to the S&P. For the Period, the largest positive contributor to performance was Advanced Micro Devices, Inc. (AMD), which added 1.19% to Fund performance, returning 148.43% with an average weighting of 1.09%. The second largest contributor was Snap, Inc. (SNAP), contributing 1.03% to the Fund and gaining 109.32% with an average weighting of 0.28%. The third largest positive contributor was Lam Research Corp (LRCX), adding 1.02% with a return of 115.44% and an average weighting of 0.82%.
 
For the Period, the largest negative performer was ZScaler, Inc. (ZS), which detracted 0.40% from performance, declining 33.32% with an average weighting of 0.24%. The second largest detractor was National Oilwell Varco Inc. (NOV), detracting 0.30% from the Fund and declining 24.18% with an average weighting of 0.25%. The third largest negative performer was Whiting Petroleum Corp (WLL), detracting 0.28% from performance and declining 24.77% with an average weighting of 0.45%.
 
As a reminder, the Index is rebalanced quarterly on the third Friday of March, June, September, and December.
 
We appreciate your investment in the Salt High truBeta US Market ETF.
 
Sincerely,
 
Anthony R. Barchetto, CFA
Founder and Chief Executive Officer
Salt Financial LLC, Adviser to the Fund
 
1

Salt Low truBeta US Market ETF

Dear Salt Low truBeta US Market ETF Shareholders,
 
Thank you for your investment in the Salt Low truBeta US Market ETF (the “Fund” or “LSLT”).  The information presented in this report relates to the operations of LSLT for the period from inception on March 12, 2019 through December 31, 2019 (the “Period”).
 
The Fund seeks to track the performance, before fees and expense, of the Salt Low truBeta US Market Index (the “Index” or “Low truBeta Index”), developed by Salt Financial Indices LLC. The Index targets US large and midcap stocks with lower sensitivity to the SPDR S&P 500 ETF (SPY) and less variability in their historical betas. With a truBeta estimate less than the market average of 1.0 the Index aims for lower volatility and the potential for better risk-adjusted returns.
 
For the Period, the Fund was up 16.07% at market and up 16.09% at NAV. This compares to the underlying Index which was up 16.21% and the S&P 500 Index (“S&P”), a broad market index, which was up 17.59% during the same Period. As a lower beta strategy with less sensitivity to market moves, the Fund underperformed the S&P as expected. In comparison, the S&P Low Volatility Index, which has a similar investing strategy to the Index, increased 14.63% over the Period.
 
As of December 31, the Fund was overweight Consumer Staples, Utilities, and Real Estate stocks and underweight Information Technology, Industrials, and Communications stocks relative to the S&P. For the Period, the largest positive contributor to performance was Resmed Inc. (RMD), which added 0.49% to Fund performance, returning 52.36% with an average weighting of 1.05%. The second largest contributor was Conagra Brands Inc. (CAG), contributing 0.48% to the Fund and gaining 51.93% with an average weighting of 1.04%. The third largest positive contributor was Western Union Co (WU), adding 0.46% with a return of 50.99% and an average weighting of 1.05%.
 
For the Period, the largest negative performer was PG&E Corp (PCG), which detracted 0.98% from performance, declining 68.29% with an average weighting of 0.70%. The second largest detractor was Discovery Inc. – A  (DISCA), detracting 0.16% from the Fund and declining 14.29% with an average weighting of 0.31%. The third largest negative performer was Cognizant Technology Solutions-A (CTSH), detracting 0.16% from performance and declining 14.83% with an average weighting of 0.60%.
 
As a reminder, the Index is rebalanced quarterly on the third Friday of March, June, September, and December.
 
We appreciate your investment in the Salt Low truBeta US Market ETF.
 
Sincerely,
 
Anthony R. Barchetto, CFA
Founder and Chief Executive Officer
Salt Financial LLC, Adviser to the Fund
 
2

Salt ETFs

Disclosures
 
Must be preceded or accompanied by a prospectus.
 
Risks: Investments involve risk. Principal loss is possible. To the extent the Funds invest more heavily in a particular sector of the economy, the Funds, performance may be more sensitive to developments that significantly affect those sectors. The Funds are non-diversified and may invest more of their assets in a single issuer or smaller number of issuers than a diversified fund. The High truBeta Index and the Low truBeta Index rely heavily on proprietary quantitative models as well as information and data supplied by third parties (Models and Data). When such Models and Data prove to be incorrect or incomplete, the Index and Fund may not perform as expected. The High truBeta Index universe includes securities with the highest truBeta, and consequently the Fund, can be expected to be more volatile than the broader U.S. equity market. The Low truBeta Index universe includes securities with the lowest truBeta, and consequently LSLT can be expected to be significantly less volatile than the broader U.S. equity market.  A security’s truBeta is based on historical information and may not be indicative of a security’s future profile. As with all index funds, the performance of the Funds and their Indices may differ from each other for a variety of reasons. For example, the Funds incur operating expenses and portfolio transaction costs not incurred by the Indices. In addition, the Funds may not be fully invested in the securities of the Indices at all times or may hold securities not included in the Indices. The Funds have the same risks as the underlying securities traded on the exchange through the day. Redemptions are limited and often commissions are charged on each trade. Shares of any ETF are bought and sold at market price (not NAV), may trade at a discount or premium to NAV and are not individually redeemed from the Funds.
 
Shares of each ETF may be sold throughout the day on the exchange through any brokerage account. However, shares may only be redeemed directly from the Funds by Authorized Participants, in very large creation/redemption units. There can be no assurance that an active trading market for shares of each ETF will develop or be maintained. Brokerage commissions may apply.
 
Beta describes the sensitivity of an individual stock to movements in the broader market. The beta coefficient is the slope of the line created by regressing the returns of the individual stock on the returns of the market. Alternatively, beta can be calculated as the ratio of how the stock moves with the market (covariance) to the variance of the market. A stock with an estimated beta of 1.0 tends to vary in the same direction and magnitude as the market. A stock with a beta of 1.2 would be expected to vary 20% more than the market (higher volatility); one with a beta of 0.8 would tend to move 20% less than the market (lower volatility).
 
Indexes are unmanaged, and it is not possible to invest in them directly. Current and future portfolio holdings are subject to change and risk.
 
The Salt High truBeta US Market Index measures the performance of an equal-weighted portfolio of approximately 100 large- and mid-capitalization U.S.-listed stocks with the highest forecasted systematic risk relative to the market (known as “beta”).
 
The Salt Low truBeta US Market Index measures the performance of an equal-weighted portfolio of approximately 100 large- and mid-capitalization U.S. listed stocks with a truBeta score of less than 100.
 
S&P 500 Index: stock market index based on the market capitalizations of 500 large companies having common stock listed on the NYSE or NASDAQ.
 
You cannot invest directly in an index.
 
Fund holdings and sector compositions are subject to change at any time and are not recommendations to buy or sell any security.
 
Past performance does not guarantee future results.
 
The Salt High truBeta US Market ETF and The Salt High truBeta US Market ETF are distributed by Compass Distributors, LLC.
 
3

Salt High truBeta US Market ETF
PERFORMANCE SUMMARY
(Unaudited)

Growth of $10,000


This chart illustrates the performance of a hypothetical $10,000 investment made on May 15, 2018, and is not intended to imply any future performance. The returns shown do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares. The chart assumes reinvestment of capital gains and dividends.
 
   
Since
 
Annualized Returns
 
Inception
 
Periods Ended December 31, 2019
1 Year
(5/15/2018)
Value
Salt High truBetaTM US Market ETF – NAV
37.32%
  8.55%
$11,431
Salt High truBetaTM US Market ETF – Market
37.93%
  8.51%
$11,424
Salt High truBetaTM US Market Index
38.03%
  9.13%
$11,530
S&P 500® Index
31.49%
13.60%
$12,311

Performance for periods greater than one year are annualized.
 
The performance data quoted represents past performance. Past performance does not guarantee future results. The investment return and principal value of an investment will fluctuate so that an investor’s shares, when sold or redeemed, may be worth more or less than their original cost and current performance may be lower or higher than the performance quoted. Performance data current to the most recent month end may be obtained by calling 646-779-1050 or visiting salt-funds.com.
 
4

Salt High truBeta US Market ETF
PERFORMANCE SUMMARY
(Unaudited) (Continued)

Salt Financial shares are bought and sold at market price (not NAV) and are not individually redeemed from the Fund. Total Returns are calculated using the daily 4:00pm net asset value (NAV). Market price returns reflect the midpoint of the bid/ask spread as of the close of trading on the exchange where Fund shares are listed. Market price returns do not represent the returns you would receive if you traded shares at other times.
 
5

Salt Low truBeta US Market ETF
PERFORMANCE SUMMARY
(Unaudited)

Growth of $10,000


This chart illustrates the performance of a hypothetical $10,000 investment made on March 12, 2019, and is not intended to imply any future performance. The returns shown do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares. The chart assumes reinvestment of capital gains and dividends.
 
 
Since
 
Cumulative Returns
Inception
 
Period Ended December 31, 2019
(3/12/2019)
Value
Salt Low truBetaTM US Market ETF – NAV
16.09%
$11,609
Salt Low truBetaTM US Market ETF – Market
16.07%
$11,607
Salt Low truBetaTM US Market Index
16.21%
$11,621
S&P 500® Index
17.59%
$11,759

The Fund is the successor to the investment performance of the Salt Low truBetaTM US Market ETF, a series of Salt Funds Trust (the “Predecessor Fund”), as a result of the reorganization of the Predecessor Fund into the Fund on December 16, 2019. Accordingly, any performance information for the period prior to December 16, 2019 is that of the Predecessor Fund. The Predecessor Fund was also advised by the Adviser and had the same investment objective, policies, and strategies as the Fund.
 
The performance data quoted represents past performance. Past performance does not guarantee future results. The investment return and principal value of an investment will fluctuate so that an investor’s shares, when sold or redeemed, may
 
6

Salt Low truBeta US Market ETF
PERFORMANCE SUMMARY
(Unaudited) (Continued)

be worth more or less than their original cost and current performance may be lower or higher than the performance quoted. Performance data current to the most recent month end may be obtained by calling 646-779-1050 or visiting salt-funds.com.
 
Salt Financial shares are bought and sold at market price (not NAV) and are not individually redeemed from the Fund. Total Returns are calculated using the daily 4:00pm net asset value (NAV). Market price returns reflect the midpoint of the bid/ask spread as of the close of trading on the exchange where Fund shares are listed. Market price returns do not represent the returns you would receive if you traded shares at other times.
 
Gross Expense Ratio: 0.29%
Net Expense Ratio: 0.00% *
 
*
Effective May 13, 2019, the Adviser has contractually agreed to waive the Fund’s full unitary management fee of 0.29% on the first $100 million in net assets until at least May 31, 2020 (the “Fee Waiver”) and to contribute to the Fund’s assets an amount equal to an annual rate of 0.05% of the Fund’s average daily net assets on the first $100 million in net assets.
 
7

Salt High truBeta US Market ETF
PORTFOLIO ALLOCATION
As of December 31, 2019 (Unaudited)
   
Percentage of
 
Sector
 
Net Assets
 
Technology
   
30.0
%
Financials
   
22.1
 
Materials
   
12.0
 
Energy
   
11.4
 
Consumer Discretionary
   
10.9
 
Communications
   
5.1
 
Industrials
   
4.8
 
Health Care
   
2.1
 
Consumer Staples
   
1.0
 
Short-Term Investments
   
0.5
 
Other Assets in Excess of Liabilities
   
0.1
 
     
100.0
%

To the extent that the Fund invests more heavily in particular sectors of the economy, its performance will be especially sensitive to developments that significantly affect those sectors (see Note 7).

8

Salt Low truBeta US Market ETF
PORTFOLIO ALLOCATION
As of December 31, 2019 (Unaudited)
   
Percentage of
 
Sector
 
Net Assets
 
Consumer Staples
   
25.9
%
Financials
   
22.8
 
Utilities
   
16.0
 
Health Care
   
12.9
 
Consumer Discretionary
   
6.9
 
Communications
   
4.9
 
Technology
   
3.9
 
Materials
   
3.0
 
Industrials
   
2.0
 
Energy
   
1.0
 
Short-Term Investments
   
0.4
 
Other Assets in Excess of Liabilities
   
0.3
 
     
100.0
%

To the extent that the Fund invests more heavily in particular sectors of the economy, its performance will be especially sensitive to developments that significantly affect those sectors (see Note 7).

9

Salt High truBeta US Market ETF
SCHEDULE OF INVESTMENTS
December 31, 2019
Shares
 
Security Description
 
Value
 
           
   
COMMON STOCKS – 99.4%
     
           
   
Communications – 5.1%
     
 
506
 
Netflix, Inc. (a)
 
$
163,726
 
 
9,944
 
Snap, Inc. – Class A (a)
   
162,386
 
 
9,240
 
TEGNA, Inc.
   
154,216
 
 
594
 
The Trade Desk, Inc. – Class A (a)
   
154,309
 
 
4,906
 
Twitter, Inc. (a)
   
157,237
 
           
791,874
 
     
Consumer Discretionary – 10.9%
       
 
5,456
 
American Airlines Group, Inc.
   
156,478
 
 
1,760
 
Best Buy Company, Inc.
   
154,528
 
 
3,872
 
Capri Holdings, Ltd. (a)
   
147,717
 
 
1,628
 
Carvana Company (a)
   
149,857
 
 
3,542
 
Etsy, Inc. (a)
   
156,911
 
 
9,372
 
Goodyear Tire & Rubber Company
   
145,782
 
 
10,428
 
Hanesbrands, Inc.
   
154,856
 
 
4,004
 
Harley-Davidson, Inc.
   
148,909
 
 
2,178
 
Las Vegas Sands Corporation
   
150,369
 
 
5,786
 
Tapestry, Inc.
   
156,048
 
 
1,166
 
Wynn Resorts, Ltd.
   
161,922
 
           
1,683,377
 
     
Consumer Staples – 1.0%
       
 
1,210
 
Five Below, Inc. (a)
   
154,711
 
               
     
Energy – 11.4%
       
 
6,314
 
Baker Hughes Company
   
161,828
 
 
2,398
 
Hess Corporation
   
160,210
 
 
2,992
 
HollyFrontier Corporation
   
151,724
 
 
11,770
 
Marathon Oil Corporation
   
159,837
 
 
2,552
 
Marathon Petroleum Corporation
   
153,758
 
 
5,962
 
Murphy Oil Corporation
   
159,782
 
 
6,688
 
Noble Energy, Inc.
   
166,130
 
 
1,078
 
Pioneer Natural Resources Company
   
163,177
 
 
3,850
 
Schlumberger, Ltd.
   
154,770
 
 
4,026
 
Targa Resources Corporation
   
164,381
 
 
24,574
 
Transocean, Ltd. (a)
   
169,069
 
           
1,764,666
 

The accompanying notes are an integral part of these financial statements.
10

Salt High truBeta US Market ETF
SCHEDULE OF INVESTMENTS
December 31, 2019 (Continued)
Shares
 
Security Description
 
Value
 
           
   
COMMON STOCKS – 99.4% (Continued)
     
           
   
Financials – 22.1%
     
 
4,752
 
Ally Financial, Inc.
 
$
145,221
 
 
3,564
 
Brighthouse Financial, Inc. (a)
   
139,816
 
 
1,430
 
Capital One Financial Corporation
   
147,161
 
 
2,552
 
CBRE Group, Inc. – Class A (a)
   
156,412
 
 
3,014
 
Charles Schwab Corporation
   
143,346
 
 
3,278
 
CIT Group, Inc.
   
149,575
 
 
1,958
 
Citigroup, Inc.
   
156,425
 
 
2,068
 
Comerica, Inc.
   
148,379
 
 
1,738
 
Discover Financial Services
   
147,417
 
 
3,322
 
E*TRADE Financial Corporation
   
150,719
 
 
5,786
 
Franklin Resources, Inc.
   
150,320
 
 
660
 
Goldman Sachs Group, Inc.
   
151,754
 
 
8,492
 
Invesco, Ltd.
   
152,686
 
 
2,486
 
Lincoln National Corporation
   
146,699
 
 
10,626
 
Navient Corporation
   
145,364
 
 
1,408
 
PayPal Holdings, Inc. (a)
   
152,303
 
 
1,606
 
Prudential Financial, Inc.
   
150,547
 
 
8,734
 
Regions Financial Corporation
   
149,875
 
 
16,808
 
SLM Corporation
   
149,759
 
 
2,310
 
Square, Inc. – Class A (a)
   
144,514
 
 
2,882
 
TD Ameritrade Holding Corporation
   
143,235
 
 
8,536
 
Umpqua Holdings Corporation
   
151,087
 
 
4,928
 
Unum Group
   
143,701
 
           
3,416,315
 
     
Health Care – 2.1%
       
 
4,554
 
Horizon Therapeutics PLC (a)
   
164,855
 
 
7,810
 
Mylan NV (a)
   
156,981
 
           
321,836
 
     
Industrials – 4.8%
       
 
1,034
 
Caterpillar, Inc.
   
152,701
 
 
902
 
FedEx Corporation
   
136,392
 
 
1,408
 
Keysight Technologies, Inc. (a)
   
144,503
 
 
3,454
 
Textron, Inc.
   
154,048
 
 
1,980
 
Westinghouse Air Brake Technologies Corporation
   
154,044
 
           
741,688
 

The accompanying notes are an integral part of these financial statements.
11

Salt High truBeta US Market ETF
SCHEDULE OF INVESTMENTS
December 31, 2019 (Continued)
Shares
 
Security Description
 
Value
 
           
   
COMMON STOCKS – 99.4% (Continued)
     
           
   
Materials – 12.0%
     
 
902
 
3M Company
 
$
159,131
 
 
7,260
 
Alcoa Corporation (a)
   
156,163
 
 
2,816
 
Dow, Inc.
   
154,120
 
 
2,310
 
DuPont de Nemours, Inc.
   
148,302
 
 
11,660
 
Freeport-McMoRan, Inc.
   
152,979
 
 
6,248
 
Huntsman Corporation
   
150,952
 
 
1,606
 
LyondellBasell Industries NV – Class A
   
151,735
 
 
8,052
 
Mosaic Company
   
174,245
 
 
2,662
 
Nucor Corporation
   
149,817
 
 
8,756
 
Olin Corporation
   
151,041
 
 
4,312
 
Steel Dynamics, Inc.
   
146,780
 
 
3,674
 
Westrock Company
   
157,651
 
           
1,852,916
 
     
Technology – 30.0%
       
 
3,652
 
Advanced Micro Devices, Inc. (a)
   
167,481
 
 
1,254
 
Analog Devices, Inc.
   
149,025
 
 
2,486
 
Applied Materials, Inc.
   
151,745
 
 
814
 
Autodesk, Inc. (a)
   
149,336
 
 
484
 
Broadcom, Inc.
   
152,954
 
 
2,200
 
Cadence Design Systems, Inc. (a)
   
152,592
 
 
3,630
 
Ciena Corporation (a)
   
154,965
 
 
2,046
 
DocuSign, Inc. (a)
   
151,629
 
 
3,982
 
DXC Technology Company
   
149,683
 
 
880
 
KLA Corporation
   
156,790
 
 
528
 
Lam Research Corporation
   
154,387
 
 
2,002
 
Lumentum Holdings, Inc. (a)
   
158,759
 
 
5,830
 
Marvell Technology Groups Ltd.
   
154,845
 
 
2,508
 
Maxim Integrated Products, Inc.
   
154,267
 
 
1,452
 
Microchip Technology, Inc.
   
152,053
 
 
2,948
 
Micron Technology, Inc. (a)
   
158,543
 
 
2,376
 
NetApp, Inc.
   
147,906
 
 
660
 
NVIDIA Corporation
   
155,298
 
 
6,490
 
ON Semiconductor Corporation (a)
   
158,226
 
 
9,130
 
Pure Storage, Inc. – Class A (a)
   
156,214
 
 
1,320
 
Qorvo, Inc. (a)
   
153,424
 
 
1,694
 
QUALCOMM, Inc.
   
149,462
 

The accompanying notes are an integral part of these financial statements.
12

Salt High truBeta US Market ETF
SCHEDULE OF INVESTMENTS
December 31, 2019 (Continued)
Shares
 
Security Description
 
Value
 
           
   
COMMON STOCKS – 99.4% (Continued)
     
           
   
Technology – 30.0% (Continued)
     
 
1,342
 
Skyworks Solutions, Inc.
 
$
162,221
 
 
1,056
 
Splunk, Inc. (a)
   
158,157
 
 
5,654
 
Teradata Corporation (a)
   
151,358
 
 
2,244
 
Teradyne, Inc.
   
153,018
 
 
1,518
 
Twilio, Inc. – Class A (a)
   
149,189
 
 
990
 
VMware, Inc. – Class A (a)
   
150,272
 
 
2,772
 
Western Digital Corporation
   
175,939
 
 
1,540
 
Xilinx, Inc.
   
150,566
 
           
4,640,304
 
     
TOTAL COMMON STOCKS
       
     
  (Cost $14,289,869)
   
15,367,687
 
               
     
SHORT-TERM INVESTMENTS – 0.5%
       
 
78,173
 
First American Government
       
     
  Obligations Fund, Class X, 1.51%*
   
78,173
 
     
TOTAL SHORT-TERM INVESTMENTS – 0.5%
       
     
  (Cost $78,173)
   
78,173
 
     
TOTAL INVESTMENTS – 99.9%
       
     
  (Cost $14,368,042)
   
15,445,860
 
     
Other Assets in Excess of Liabilities – 0.1%
   
17,167
 
     
NET ASSETS – 100.0%
 
$
15,463,027
 

Percentages are stated as a percent of net assets.
 
(a)
Non-income producing security.
To the extent that the Fund invests more heavily in particular sectors of the economy, its performance will be especially sensitive to developments that significantly affect those sectors. See Note 7 in Notes to Financial Statements.
*
Rate shown is the annualized seven-day effective yield as of December 31, 2019.

The accompanying notes are an integral part of these financial statements.
13

Salt Low truBeta US Market ETF
SCHEDULE OF INVESTMENTS
December 31, 2019
Shares
 
Security Description
 
Value
 
           
   
COMMON STOCKS – 99.3%
     
           
   
Communications – 4.9%
     
 
2,366
 
AT&T, Inc.
 
$
92,463
 
 
1,105
 
Omnicom Group, Inc.
   
89,527
 
 
1,209
 
T-Mobile US, Inc. (a)
   
94,810
 
 
1,482
 
Verizon Communications, Inc.
   
90,995
 
 
611
 
Walt Disney Company
   
88,369
 
           
456,164
 
     
Consumer Discretionary – 6.9%
       
 
780
 
Darden Restaurants, Inc.
   
85,028
 
 
1,222
 
Dunkin’ Brands Group, Inc.
   
92,310
 
 
468
 
McDonald’s Corporation
   
92,481
 
 
2,353
 
Nordstrom, Inc.
   
96,308
 
 
1,989
 
Service Corporation International
   
91,554
 
 
2,015
 
Six Flags Entertainment Corporation
   
90,896
 
 
897
 
Yum! Brands, Inc.
   
90,355
 
           
638,932
 
     
Consumer Staples – 25.9%
       
 
1,794
 
Altria Group, Inc.
   
89,539
 
 
2,002
 
Archer-Daniels-Midland Company
   
92,793
 
 
1,417
 
Brown-Forman Corporation – Class B
   
95,789
 
 
1,898
 
Campbell Soup Company
   
93,799
 
 
1,287
 
Church & Dwight Company, Inc.
   
90,528
 
 
598
 
Clorox Company
   
91,817
 
 
1,651
 
Coca-Cola Company
   
91,383
 
 
1,313
 
Colgate-Palmolive Company
   
90,387
 
 
3,172
 
Conagra Brands, Inc.
   
108,609
 
 
312
 
Costco Wholesale Corporation
   
91,703
 
 
585
 
Dollar General Corporation
   
91,248
 
 
442
 
Estee Lauder Companies, Inc. – Class A
   
91,291
 
 
1,742
 
General Mills, Inc.
   
93,301
 
 
624
 
Hershey Company
   
91,715
 
 
2,015
 
Hormel Foods Corporation
   
90,897
 
 
1,352
 
Kellogg Company
   
93,504
 
 
3,159
 
Keurig Dr Pepper, Inc.
   
91,453
 
 
663
 
Kimberly-Clark Corporation
   
91,196
 
 
3,198
 
Kroger Company
   
92,710
 

The accompanying notes are an integral part of these financial statements.
14

Salt Low truBeta US Market ETF
SCHEDULE OF INVESTMENTS
December 31, 2019 (Continued)
Shares
 
Security Description
 
Value
 
           
   
COMMON STOCKS – 99.3% (Continued)
     
           
   
Consumer Staples – 25.9% (Continued)
     
 
1,794
 
Molson Coors Brewing Company – Class B
 
$
96,697
 
 
1,690
 
Mondelez International, Inc. – Class A
   
93,085
 
 
650
 
PepsiCo, Inc.
   
88,835
 
 
1,079
 
Philip Morris International, Inc.
   
91,812
 
 
715
 
Procter & Gamble Company
   
89,303
 
 
1,079
 
Sysco Corporation
   
92,298
 
 
1,040
 
Tyson Foods, Inc. – Class A
   
94,682
 
           
2,410,374
 
     
Energy – 1.0%
       
 
1,300
 
Exxon Mobil Corporation
   
90,714
 
               
     
Financials – 22.8%
       
 
1,703
 
Aflac, Inc.
   
90,089
 
 
5,122
 
AGNC Investment Corporation – REIT
   
90,557
 
 
819
 
Allstate Corporation
   
92,097
 
 
3,549
 
American Homes 4 Rent – Class A – REIT
   
93,019
 
 
5,720
 
Apple Hospitality REIT, Inc. – REIT
   
92,950
 
 
2,314
 
Brown & Brown, Inc.
   
91,357
 
 
442
 
CME Group, Inc.
   
88,718
 
 
2,288
 
Cousins Properties, Inc. – REIT
   
94,266
 
 
689
 
Crown Castle International Corporation – REIT
   
97,941
 
 
3,003
 
CubeSmart – REIT
   
94,534
 
 
806
 
Digital Realty Trust, Inc. – REIT
   
96,510
 
 
2,639
 
Duke Realty Corporation – REIT
   
91,494
 
 
1,937
 
Fidelity National Financial, Inc.
   
87,843
 
 
663
 
Fidelity National Information Services, Inc.
   
92,217
 
 
1,053
 
Lamar Advertising Company – Class A – REIT
   
93,991
 
 
819
 
Marsh & McLennan Companies, Inc.
   
91,245
 
 
11,609
 
MFA Financial, Inc. – REIT
   
88,809
 
 
1,248
 
Progressive Corporation
   
90,343
 
 
1,235
 
Realty Income Corporation – REIT
   
90,933
 
 
3,653
 
Starwood Property Trust, Inc. – REIT
   
90,814
 
 
1,391
 
Vornado Realty Trust – REIT
   
92,501
 
 
1,157
 
Welltower, Inc. – REIT
   
94,619
 
 
3,354
 
Western Union Company
   
89,820
 
           
2,116,667
 

The accompanying notes are an integral part of these financial statements.
15

Salt Low truBeta US Market ETF
SCHEDULE OF INVESTMENTS
December 31, 2019 (Continued)
Shares
 
Security Description
 
Value
 
           
   
COMMON STOCKS – 99.3% (Continued)
     
           
   
Health Care – 12.9%
     
 
1,079
 
Baxter International, Inc.
 
$
90,226
 
 
1,404
 
Bristol-Myers Squibb Company
   
90,123
 
 
1,222
 
CVS Health Corporation
   
90,782
 
 
754
 
Eli Lilly & Company
   
99,098
 
 
1,664
 
Hologic, Inc. (a)
   
86,877
 
 
637
 
Johnson & Johnson
   
92,919
 
 
806
 
Medtronic Plc
   
91,441
 
 
1,027
 
Merck & Company Inc.
   
93,406
 
 
2,366
 
Pfizer, Inc.
   
92,700
 
 
858
 
Quest Diagnostics, Inc.
   
91,626
 
 
598
 
ResMed, Inc.
   
92,672
 
 
312
 
UnitedHealth Group, Inc.
   
91,722
 
 
728
 
Zoetis, Inc.
   
96,351
 
           
1,199,943
 
     
Industrials – 2.0%
       
 
1,027
 
Republic Services, Inc.
   
92,050
 
 
806
 
Waste Management, Inc.
   
91,852
 
           
183,902
 
     
Materials – 3.0%
       
 
390
 
Air Products & Chemicals, Inc.
   
91,646
 
 
494
 
Ecolab, Inc.
   
95,337
 
 
2,379
 
Sealed Air Corporation
   
94,756
 
           
281,739
 
     
Technology – 3.9%
       
 
1,430
 
Black Knight, Inc. (a)
   
92,207
 
 
819
 
Citrix Systems, Inc.
   
90,827
 
 
559
 
Motorola Solutions, Inc.
   
90,077
 
 
4,030
 
Sabre Corporation
   
90,433
 
           
363,544
 
     
Utilities – 16.0%
       
 
1,703
 
Alliant Energy Corporation
   
93,188
 
 
975
 
American Electric Power Company, Inc.
   
92,147
 
 
3,471
 
CenterPoint Energy, Inc.
   
94,654
 
 
1,482
 
CMS Energy Corporation
   
93,129
 

The accompanying notes are an integral part of these financial statements.
16

Salt Low truBeta US Market ETF
SCHEDULE OF INVESTMENTS
December 31, 2019 (Continued)
Shares
 
Security Description
 
Value
 
           
   
COMMON STOCKS – 99.3% (Continued)
     
           
   
Utilities – 16.0% (Continued)
     
 
1,027
 
Consolidated Edison, Inc.
 
$
92,913
 
 
1,131
 
Dominion Energy, Inc.
   
93,670
 
 
1,001
 
Duke Energy Corporation
   
91,301
 
 
1,248
 
Edison International
   
94,112
 
 
1,105
 
Eversource Energy
   
94,002
 
 
2,054
 
Exelon Corporation
   
93,642
 
 
1,885
 
FirstEnergy Corporation
   
91,611
 
 
2,535
 
PPL Corporation
   
90,956
 
 
1,534
 
Public Service Enterprise Group, Inc.
   
90,583
 
 
1,482
 
Southern Company
   
94,403
 
 
1,027
 
WEC Energy Group, Inc.
   
94,720
 
 
1,443
 
Xcel Energy, Inc.
   
91,616
 
           
1,486,647
 
     
TOTAL COMMON STOCKS
       
     
  (Cost $8,565,572)
   
9,228,626
 
               
     
SHORT-TERM INVESTMENTS – 0.4%
       
 
41,134
 
First American Government
       
     
Obligations Fund, Class X, 1.51%*
   
41,134
 
     
TOTAL SHORT-TERM INVESTMENTS – 0.4%
       
     
  (Cost $41,134)
   
41,134
 
     
TOTAL INVESTMENTS – 99.7%
       
     
  (Cost $8,606,706)
   
9,269,760
 
     
Other Assets in Excess of Liabilities – 0.3%
   
23,570
 
     
NET ASSETS – 100.0%
 
$
9,293,330
 

Percentages are stated as a percent of net assets.
 
REIT – Real Estate Investment Trust
(a)
Non-income producing security.
To the extent that the fund invests more heavily in particular sectors of the economy, it’s performance will be especially sensitive to developments that significantly affect those sectors. See Note 7 in Notes to Financial Statements.
*
Rate shown is the annualized  seven-day effective yield as of December 31, 2019.

The accompanying notes are an integral part of these financial statements.
17

Salt ETFs
STATEMENTS OF ASSETS AND LIABILITIES
December 31, 2019
   
Salt High
   
Salt Low
 
   
truBeta US
   
truBeta US
 
   
Market ETF
   
Market ETF
 
ASSETS:
           
Investments in securities, at value (Cost
           
  $14,368,042 and $8,606,706, respectively)
 
$
15,445,860
   
$
9,269,760
 
Receivable for Fund shares sold
   
698,820
     
 
Dividends and interest receivable
   
16,424
     
23,178
 
Due from Adviser
   
     
392
 
Total assets
   
16,161,104
     
9,293,330
 
                 
LIABILITIES:
               
Payable for investment securities purchased
   
694,482
     
 
Management fees payable
   
3,595
     
 
Total liabilities
   
698,077
     
 
                 
NET ASSETS
 
$
15,463,027
   
$
9,293,330
 
                 
Net assets consist of:
               
Paid-in capital
 
$
15,048,327
   
$
8,610,788
 
Total distributable earnings
               
  (accumulated deficit)
   
414,700
     
682,542
 
Net assets
 
$
15,463,027
   
$
9,293,330
 
                 
Net asset value:
               
Net assets
 
$
15,463,027
   
$
9,293,330
 
Shares outstanding^
   
550,000
     
325,000
 
Net asset value, offering and
               
  redemption price per share
 
$
28.11
   
$
28.59
 

^
No par value, unlimited number of shares authorized.

The accompanying notes are an integral part of these financial statements.
18

Salt ETFs
STATEMENTS OF OPERATIONS
For the Year/Period Ended December 31, 2019
   
Salt High
   
Salt Low
 
   
truBeta US
   
truBeta US
 
   
Market ETF
   
Market ETF*
 
INCOME
           
Dividends
 
$
190,020
   
$
135,270
 
Interest
   
950
     
410
 
Adviser contributions
   
     
2,167
 
Total investment income
   
190,970
     
137,847
 
                 
EXPENSES
               
Management fees
   
35,882
     
14,101
 
Total expenses
   
35,882
     
14,101
 
Less: fees waived
   
     
(12,572
)
Net expenses
   
35,882
     
1,529
 
Net investment income (loss)
   
155,088
     
136,318
 
                 
REALIZED & UNREALIZED
               
  GAIN (LOSS) ON INVESTMENTS
               
Net realized gain (loss) on investments
   
1,995,803
     
21,452
 
Change in unrealized appreciation
               
  (depreciation) on investments
   
1,458,045
     
663,054
 
Net realized and unrealized
               
  gain (loss) on investments
   
3,453,848
     
684,506
 
Net increase (decrease) in net assets
               
  resulting from operations
 
$
3,608,936
   
$
820,824
 

*
The Fund commenced operations on March 12, 2019. The information presented is for the period from March 12, 2019 to December 31, 2019.  Shares of the Predecessor Fund converted to shares of the Fund at the close of business December 13, 2019 (See Note 1).

The accompanying notes are an integral part of these financial statements.
19

Salt High truBeta US Market ETF


STATEMENTS OF CHANGES IN NET ASSETS
   
Year Ended
   
Period Ended
 
   
December 31, 2019
   
December 31, 2018*
 
OPERATIONS
           
Net investment income (loss)
 
$
155,088
   
$
26,398
 
Net realized gain (loss) on investments
   
1,995,803
     
(769,325
)
Change in unrealized appreciation
               
  (depreciation) on investments
   
1,458,045
     
(380,227
)
Net increase (decrease) in net assets
               
  resulting from operations
   
3,608,936
     
(1,123,154
)
                 
DISTRIBUTIONS TO SHAREHOLDERS
               
Net distributions to shareholders
   
(155,507
)
   
(49,240
)
Total distributions to shareholders
   
(155,507
)
   
(49,240
)
                 
CAPITAL SHARE TRANSACTIONS
               
Proceeds from shares sold
   
11,643,208
     
10,077,645
 
Payments for shares redeemed
   
(7,909,050
)
   
(629,817
)
Transaction fees (See Note 6)
   
     
6
 
Net increase (decrease) in net
               
  assets derived from capital
               
  share transactions (a)
   
3,734,158
     
9,447,834
 
Net increase (decrease) in net assets
 
$
7,187,587
   
$
8,275,440
 
                 
NET ASSETS
               
Beginning of year/period
 
$
8,275,440
   
$
 
End of year
 
$
15,463,027
   
$
8,275,440
 

(a)
A summary of share transactions is as follows:

     
Year Ended
   
Period Ended
 
     
December 31, 2019
   
December 31, 2018*
 
     
Shares
   
Shares
 
 
Subscriptions
   
450,000
     
425,000
 
 
Redemptions
   
(300,000
)
   
(25,000
)
 
Net increase (decrease)
   
150,000
     
400,000
 

*
The Fund commenced operations on May 15, 2018. The information presented is for the period from May 15, 2018 to December 31, 2018.

The accompanying notes are an integral part of these financial statements.
20

Salt Low truBeta US Market ETF


STATEMENT OF CHANGES IN NET ASSETS
   
Period Ended
 
   
December 31, 2019*
 
OPERATIONS
     
Net investment income (loss)
 
$
136,318
 
Net realized gain (loss) on investments
   
21,452
 
Change in unrealized appreciation
       
  (depreciation) on investments
   
663,054
 
Net increase (decrease) in net assets
       
  resulting from operations
   
820,824
 
         
DISTRIBUTIONS TO SHAREHOLDERS
       
Net income distributions
   
(138,282
)
Total distributions to shareholders
   
(138,282
)
         
CAPITAL SHARE TRANSACTIONS
       
Proceeds from shares sold
   
8,610,788
 
Net increase (decrease) in net assets derived
       
  from capital share transactions (a)
   
8,610,788
 
Net increase (decrease) in net assets
 
$
9,293,330
 
         
NET ASSETS
       
Beginning of period
 
$
 
End of period
 
$
9,293,330
 

(a)
A summary of share transactions is as follows:

     
Period Ended
 
     
December 31, 2019*
 
     
Shares
 
 
Subscriptions
   
325,000
 
 
Net increase (decrease)
   
325,000
 

*
The Fund commenced operations on March 12, 2019. The information presented is for the period from March 12, 2019 to December 31, 2019.  Shares of the Predecessor Fund converted to shares of the Fund at the close of business December 13, 2019 (See Note 1).

The accompanying notes are an integral part of these financial statements.
21

Salt High truBeta US Market ETF
FINANCIAL HIGHLIGHTS
For a capital share outstanding throughout each year/period
   
Year Ended
   
Period Ended
 
   
December 31, 2019
   
December 31, 2018 1
 
Net asset value, beginning
           
  of year/period
 
$
20.69
   
$
25.00
 
                 
INCOME (LOSS) FROM
               
  INVESTMENT OPERATIONS:
               
Net investment income (loss) 2
   
0.32
     
0.14
 
Net realized and unrealized
               
  gain (loss) on investments
   
7.40
     
(4.32
)
Total from investment operations
   
7.72
     
(4.18
)
                 
DISTRIBUTIONS TO SHAREHOLDERS:
               
From net investment income
   
(0.30
)
   
(0.07
)
From net realized gains
   
     
(0.06
)
Total distributions
   
(0.30
)
   
(0.13
)
                 
CAPITAL SHARE TRANSACTIONS:
               
Transaction fees (See Note 6)
   
     
0.00
3 
                 
Net asset value, end of year/period
 
$
28.11
   
$
20.69
 
                 
Total return
   
37.32
%
   
-16.76
%4
                 
SUPPLEMENTAL DATA:
               
Net assets, end of year/period (000’s)
 
$
15,463
   
$
8,275
 
                 
RATIOS TO AVERAGE NET ASSETS
               
Expenses to average net assets
   
0.30
%7
   
0.50
%5
Net investment income (loss)
               
  to average net assets
   
1.28
%
   
0.97
%5
Portfolio turnover rate 6
   
202
%
   
145
%4

1
The Fund commenced operations on May 15, 2018. The information presented is for the period from May 15, 2018 to December 31, 2018.
2
Calculated based on average shares outstanding during the period.
3
Represents less than $0.005 per share.
4
Not annualized.
5
Annualized.
6
Excludes the impact of in-kind transactions.
7
Effective January 14, 2019, the Adviser reduced its management fee from 0.50% to 0.29%. See Note 3 in Notes to Financial Statements.

The accompanying notes are an integral part of these financial statements.
22

Salt Low truBeta US Market ETF
FINANCIAL HIGHLIGHTS
For a capital share outstanding throughout the period
   
Period Ended
 
   
December 31, 2019 1
 
Net asset value, beginning of period
 
$
25.00
 
         
INCOME (LOSS) FROM INVESTMENT OPERATIONS:
       
Net investment income (loss) 2
   
0.62
 
Net realized and unrealized gain (loss) on investments
   
3.40
 
Total from investment operations
   
4.02
 
         
DISTRIBUTIONS TO SHAREHOLDERS:
       
From net investment income
   
(0.43
)
From net realized gains
   
 
Total distributions
   
(0.43
)
         
Net asset value, end of period
 
$
28.59
 
         
Total return
   
16.09
%3,7
         
SUPPLEMENTAL DATA:
       
Net assets, end of period (000’s)
 
$
9,293
 
         
RATIOS TO AVERAGE NET ASSETS
       
Expenses to average net assets before fees waived
   
0.29
%4
Expenses to average net assets after fees waived
   
0.03
%4,6
Net investment income (loss) to average
       
  net assets before fees waived
   
2.54
%4
Net investment income (loss) to average
       
  net assets after fees waived
   
2.79
%4
Portfolio turnover rate 5
   
31
%3

1
The Fund commenced operations on March 12, 2019. The information presented is for the period from March 12, 2019 to December 31, 2019. Shares of the Predecessor Fund converted to shares of the Fund at the close of business December 13, 2019 (See Note 1).
2
Calculated based on average shares outstanding during the period.
3
Not annualized.
4
Annualized.
5
Excludes the impact of in-kind transactions.
6
Effective May 13, 2019, the Adviser agreed to waive the Fund’s full unitary management fee of 0.29% on the first $100 million in net assets (See Note 3).
7
Net increase from contributions contributed 0.04% to this return (See Note 3).

The accompanying notes are an integral part of these financial statements.
23

Salt ETFs
NOTES TO FINANCIAL STATEMENTS
December 31, 2019
NOTE 1 – ORGANIZATION
 
Salt High truBeta US Market ETF (the “Fund” or “High truBeta Fund”) and Salt Low truBeta US Market ETF (the “Fund” or “Low truBeta Fund”) are non-diversified series of ETF Series Solutions (“ESS” or the “Trust”), an open-end management investment company consisting of multiple investment series, organized as a Delaware statutory trust on February 9, 2012. The Trust is registered with the Securities and Exchange Commission (“SEC”) under the Investment Company Act of 1940, as amended (the “1940 Act”), as an open-end management investment company and the offering of the Funds’ shares is registered under the Securities Act of 1933, as amended (the “Securities Act”). The investment objective of the High truBeta Fund is to track the performance, before expenses and fees, of the Salt High truBeta US Market Index (the “High truBeta Index”). The High truBeta Fund commenced operations on May 15, 2018.  The investment objective of the Low truBeta Fund is to track the performance, before expenses and fees, of the Salt Low truBeta US Market Index (the “Low truBeta Index”).
 
The Low truBeta Fund is the successor in interest to the Predecessor Low truBeta Fund (the “Predecessor Fund”) having the same investment objective that was included as a series of another investment company, Salt Funds Trust, and that was also advised by Low truBeta Fund’s investment adviser, Salt Financial LLC (the “Adviser”). On December 11, 2019, the shareholders of the Predecessor Fund approved the tax-free reorganization of the Predecessor Fund with and into the Trust, and effective on December 16, 2019, the assets and liabilities of the Predecessor Fund were transferred to the Trust in exchange for shares of Low truBeta Fund. For financial reporting purposes, assets received and shares issued by Low truBeta Fund were recorded at fair value; however, the cost basis of the investments received from the Predecessor Fund was carried forward to align ongoing reporting of Low truBeta Fund’s realized and unrealized gains and losses with amounts distributable to shareholders for tax purposes. Costs incurred by Salt Funds Trust in connection with the reorganization were paid by the Adviser. The fiscal year end of the Predecessor Fund was December 31. The reporting period covered by this annual report for Low truBeta Fund is March 12, 2019 through December 31, 2019. Operations prior to December 16, 2019 were for the Predecessor Fund. The net assets were $9,227,500, including $531,991 of net unrealized appreciation, $127,400 of undistributed (accumulated) net investment income, and $42,678 of undistributed (accumulated) net realized loss and shares outstanding were 325,000, all of which were transferred into the Trust at NAV at the close of business on December 13, 2019.
 
The primary purpose of the reorganization was to move the existing Fund from its existing trust to the Trust, which the Adviser believed would allow the Fund to become part of a series of a stable fund family. Shareholders are expected to benefit accordingly and to enjoy an improvement in the level and quality of services provided to them and the Fund.
 
24

Salt ETFs
NOTES TO FINANCIAL STATEMENTS
December 31, 2019 (Continued)
The end of the reporting period for the Funds is December 31, 2019, and the period covered by these Notes to Financial Statements is the fiscal period from January 1, 2019 through December 31, 2019 for High truBeta Fund and the period from March 12, 2019 through December 31, 2019 for the Low truBeta Fund (each, respectively, the “current fiscal period”).
 
NOTE 2 – SIGNIFICANT ACCOUNTING POLICIES
 
The Funds are investment companies and accordingly follow the investment company accounting and reporting guidance of the Financial Accounting Standards Board (“FASB”) Accounting Standards Codification (“ASC”) Topic 946 Financial Services – Investment Companies.
 
The following is a summary of significant accounting policies consistently followed by the Funds. These policies are in conformity with accounting principles generally accepted in the United States of America (“U.S. GAAP”).
 
 
A.
Security Valuation. All equity securities, including domestic and foreign common stocks, preferred stocks and exchange-traded funds, that are traded on a national securities exchange, except those listed on the Nasdaq Global Market®, Nasdaq Global Select Market® and the Nasdaq Capital Market® exchanges (collectively, “Nasdaq”) are valued at the last reported sale price on the exchange on which the security is principally traded. Securities traded on Nasdaq will be valued at the Nasdaq Official Closing Price (“NOCP”). If, on a particular day, an exchange-traded or Nasdaq security does not trade, then the mean between the most recent quoted bid and asked prices will be used. All equity securities that are not traded on a listed exchange are valued at the last sale price in the over-the counter market. If a non-exchange traded security does not trade on a particular day, then the mean between the last quoted closing bid and asked price will be used. Prices denominated in foreign currencies are converted to U.S. dollar equivalents at the current exchange rate, which approximates fair value.

   
Investments in mutual funds, including money market funds, are valued at their net asset value (“NAV”) per share.

   
Securities for which quotations are not readily available are valued at their respective fair values in accordance with pricing procedures adopted by the Funds’ Board of Trustees (the “Board”). When a security is “fair valued,” consideration is given to the facts and circumstances relevant to the particular situation, including a review of various factors set forth in the pricing procedures adopted by the Board. The use of fair value pricing by the Funds may cause the NAV of their shares to differ significantly from the NAV that would be calculated without regard to such considerations.

25

Salt ETFs
NOTES TO FINANCIAL STATEMENTS
December 31, 2019 (Continued)
 
As described above, the Funds utilize various methods to measure the fair value of their investments on a recurring basis. U.S. GAAP establishes a hierarchy that prioritizes inputs to valuations methods. The three levels of inputs are:

 
Level 1 –
Unadjusted quoted prices in active markets for identical assets or liabilities that the Funds have the ability to access.

 
Level 2 –
Observable inputs other than quoted prices included in Level 1 that are observable for the asset or liability, either directly or indirectly. These inputs may include quoted prices for the identical instrument on an inactive market, prices for similar instruments, interest rates, prepayment speeds, credit risk, yield curves, default rates and similar data.

 
Level 3 –
Unobservable inputs for the asset or liability, to the extent relevant observable inputs are not available; representing the Funds’ own assumptions about the assumptions a market participant would use in valuing the asset or liability and would be based on the best information available.

 
The availability of observable inputs can vary from security to security and is affected by a wide variety of factors, including, for example, the type of security, whether the security is new and not yet established in the marketplace, the liquidity of markets, and other characteristics particular to the security. To the extent that valuation is based on models or inputs that are less observable or unobservable in the market, the determination of fair value requires more judgment. Accordingly, the degree of judgment exercised in determining fair value is greatest for instruments categorized in Level 3.

 
The inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such cases, for disclosure purposes, the level in the fair value hierarchy within which the fair value measurement falls in its entirety, is determined based on the lowest level input that is significant to the fair value measurement in its entirety.

 
The following is a summary of the inputs used to value the Funds’ investments as of the end of the current fiscal period:

 
High truBeta Fund
                       
 
Assets1
 
Level 1
   
Level 2
   
Level 3
   
Total
 
 
Common Stocks
 
$
15,367,687
   
$
   
$
   
$
15,367,687
 
 
Short-Term Investments
   
78,173
     
     
     
78,173
 
 
Total Investments
 
$
15,445,860
   
$
   
$
   
$
15,445,860
 

26

Salt ETFs
NOTES TO FINANCIAL STATEMENTS
December 31, 2019 (Continued)
 
Low truBeta Fund
                       
 
Assets1
 
Level 1
   
Level 2
   
Level 3
   
Total
 
 
Common Stocks
 
$
9,228,626
   
$
   
$
   
$
9,228,626
 
 
Short-Term Investments
   
41,134
     
     
     
41,134
 
 
Total Investments
 
$
9,269,760
   
$
   
$
   
$
9,269,760
 

   
1  See Schedule of Investments for breakout of investments by sector classification.

 
B.
Federal Income Taxes. The Funds’ policy is to comply with the provisions of Subchapter M of the Internal Revenue Code of 1986, as amended, applicable to regulated investment companies and to distribute substantially all net taxable investment income and net capital gains to shareholders. Therefore, no federal income tax provision is required. The Funds plan to file U.S. Federal and various state and local tax returns.

   
The Funds recognize the tax benefits of uncertain tax positions only when the position is more likely than not to be sustained. Management has analyzed the Funds’ uncertain tax positions and concluded that no liability for unrecognized tax benefits should be recorded related to uncertain tax positions. Management is not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will change materially in the next 12 months. Income and capital gain distributions are determined in accordance with federal income tax regulations, which may differ from U.S. GAAP. The Funds recognize interest and penalties, if any, related to unrecognized tax benefits on uncertain tax positions as income tax expense in the Statements of Operations. During the current fiscal period, the Funds did not incur any interest or penalties.

 
C.
Security Transactions and Investment Income. Investment securities transactions are accounted for on the trade date. Gains and losses realized on sales of securities are determined on a specific identification basis. Dividend income is recorded on the ex-dividend date. Interest income is recorded on an accrual basis. Withholding taxes on foreign dividends have been provided for in accordance with the Funds’ understanding of the applicable tax rules and regulations.

 
D.
Distributions to Shareholders. Distributions to shareholders from net investment income and net realized gains on securities are declared and paid by the Funds at least annually. Distributions are recorded on the ex-dividend date.

 
E.
Use of Estimates. The preparation of financial statements in conformity with U.S. GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements, as

27

Salt ETFs
NOTES TO FINANCIAL STATEMENTS
December 31, 2019 (Continued)
   
well as the reported amounts of revenues and expenses during the current fiscal period. Actual results could differ from those estimates.

 
F.
Share Valuation. The NAV per share of the Funds are calculated by dividing the sum of the value of the securities held by each Fund, plus cash and other assets, minus all liabilities (including estimated accrued expenses) by the total number of shares outstanding for the Funds, rounded to the nearest cent. The Funds’ shares will not be priced on the days on which the New York Stock Exchange (“NYSE”) is closed for trading. The offering and redemption price per share for creation units for each of the Funds is equal to the Funds’ NAV per share.

 
G.
Guarantees and Indemnifications. In the normal course of business, the Funds enter into contracts with service providers that contain general indemnification clauses. The Funds’ maximum exposure under these arrangements is unknown as this would involve future claims that may be against the Funds that have not yet occurred. However, based on experience, the Funds expect the risk of loss to be remote.

 
H.
Reclassification of Capital Accounts. U.S. GAAP requires that certain components of net assets relating to permanent differences be reclassified between financial and tax reporting. These reclassifications have no effect on net assets or NAV per share.

   
The permanent differences primarily relate to differing book and tax treatments for in-kind transactions. The following table shows the reclassifications made during the current fiscal period:

   
Distributable Earnings
       
   
(Accumulated Deficit)
 
Paid-In Capital
 
High truBeta Fund
 
$
(1,838,987
)
   
$
1,838,987
 
 
Low truBeta Fund
 
$
     
$
 

   
During the current fiscal period, the High truBeta Fund realized $1,839,406 in net capital gains resulting from in-kind redemptions, in which shareholders exchanged Fund shares for securities held by the Fund rather than for cash. Because such gains are not taxable to the Fund, and are not distributed to shareholders, they have been reclassified from distributable earnings to paid-in capital.

 
I.
Shareholder Meeting (Unaudited). At a special meeting held December 11, 2019, shareholders of the Predecessor Fund voted on one proposal:

  1) 
To approve the reorganization (the “Reorganization”) of the Salt Low truBeta US Market ETF into a corresponding, newly created series of ETF Series Solutions with the same name.

 
For %
Against %
Abstain %
 
 
98.86%
0.05%
1.09%
 

28

Salt ETFs
NOTES TO FINANCIAL STATEMENTS
December 31, 2019 (Continued)
 
J.
Subsequent Events. In preparing these financial statements, management has evaluated events and transactions for potential recognition or disclosure through the date the financial statements were issued.  There were no events or transactions that occurred during the period subsequent to the end of the current fiscal period that materially impacted the amounts or disclosures in the Funds’ financial statements.

 
K.
New Accounting Pronouncements. In August 2018, FASB issued Accounting Standards Update 2018-13, Fair Value Measurement (Topic 820): Disclosure Framework—Changes to the Disclosure Requirements for Fair Value Measurement (“ASU 2018-13”). The primary focus of ASU 2018-13 is to improve the effectiveness of the disclosure requirements for fair value measurements. The changes affect all companies that are required to include fair value measurement disclosures. In general, the amendments in ASU 2018-13 are effective for all entities for fiscal years and interim periods within those fiscal years, beginning after December 15, 2019. An entity is permitted to early adopt the removed or modified disclosures upon the issuance of ASU 2018-13 and may delay adoption of the additional disclosures, which are required for public companies only, until their effective date. Management has evaluated ASU 2018-13 and has adopted the disclosure framework.
 
NOTE 3 – COMMITMENTS AND OTHER RELATED PARTY TRANSACTIONS
 
Salt Financial LLC (the “Adviser”), serves as the investment adviser to the Funds. Pursuant to an Investment Advisory Agreement (“Advisory Agreement”) between the Trust, on behalf of the Funds, and the Adviser, the Adviser provides investment advice to the Funds and oversees the day-to-day operations of the Funds, subject to the direction and control of the Board and the officers of the Trust. Under the Advisory Agreement, the Adviser is also responsible for arranging, in consultation with Penserra Capital Management LLC, (the “Sub-Adviser”), transfer agency, custody, fund administration and accounting, and other non-distribution related services necessary for the Funds to operate. Under the Advisory Agreement, the Adviser has agreed to pay all expenses of the Funds except for: the fee paid to the Adviser pursuant to the Investment Advisory Agreement, interest charges on any borrowings, dividends, and other expenses on securities sold short, taxes, brokerage commissions and other expenses incurred in placing orders for the purchase and sale of securities and other investment instruments, acquired fund fees and expenses, accrued deferred tax liability, extraordinary expenses, and distribution (12b-1) fees and expenses. For services provided to the Funds, the High truBeta Fund pays the Adviser 0.29% at an annual rate based on the Fund’s average daily net assets.  Prior to January 14, 2019, the High truBeta Fund paid the Adviser 0.50% at an annual rate based on the Fund’s average daily net assets.  The Low truBeta Fund pays the Adviser 0.29% at an annual rate based on the Fund’s average daily net assets.
 
29

Salt ETFs
NOTES TO FINANCIAL STATEMENTS
December 31, 2019 (Continued)
Effective May 13, 2019, the Adviser has contractually agreed to waive the Low truBeta Fund’s full unitary management fee of 0.29% of the Fund’s average daily net assets on the first $100 million in net assets until at least May 31, 2020 (the “Fee Waiver”) and to contribute to the Fund’s assets an amount equal to an annual rate of 0.05% of the Fund’s average daily net assets on the first $100 million in net assets (i.e., up to $50,000 per annum) until at least May 31, 2020 (the “Contribution”).
 
The Low truBeta Fund will accrue the Contribution amount daily, and the Adviser will pay to the Fund the accrued Contribution amount for a given month within fifteen days of the end of such month. The Adviser will not be permitted to recoup or recapture any portion of the Fee Waiver or Contribution at any time. The Fee Waiver and Contribution agreement: may be terminated at any time, and without payment of any penalty, by the Board of the Trust, on behalf of the Fund, upon sixty (60) days’ written notice to the Adviser or such shorter period as to which the parties may agree; may not be terminated by the Adviser without the consent of the Board of the Trust; and will automatically terminate if the Advisory Agreement is terminated, with such termination effective upon the effective date of the Advisory Agreement’s termination.
 
U.S. Bancorp Fund Services, LLC, doing business as U.S. Bank Global Fund Services (“Fund Services” or “Administrator”), acts as the Funds’ Administrator and, in that capacity, performs various administrative and accounting services for the Funds. The Administrator prepares various federal and state regulatory filings, reports and returns for the Funds, including regulatory compliance monitoring and financial reporting; prepares reports and materials to be supplied to the Board and monitors the activities of the Funds’ Custodian, transfer agent and fund accountant. Fund Services also serves as the transfer agent and fund accountant to the Funds. U.S. Bank N.A. (the “Custodian”), an affiliate of Fund Services, serves as the Funds’ Custodian.
 
Compass Distributors, LLC, (the “Distributor”) acts as the Funds’ principal underwriter in a continuous public offering of the Funds’ shares. Prior to February 18, 2019, Quasar Distributors, LLC, an affiliate of the Administrator, acted as the High truBeta Fund’s principal underwriter.
 
A Trustee and all officers of the Trust are affiliated with the Administrator and Custodian.
 
NOTE 4 – PURCHASES AND SALES OF SECURITIES
 
During the current fiscal period, purchases and sales of securities, excluding short-term securities and in-kind transactions, were as follows:
 
   
Purchases
Sales
 
  High truBeta Fund
$25,477,117
$24,323,922
 
  Low truBeta Fund
    1,913,956
    1,898,375

30

Salt ETFs
NOTES TO FINANCIAL STATEMENTS
December 31, 2019 (Continued)
During the current fiscal period, there were no purchases or sales of U.S. Government securities.
 
During the current fiscal period, in-kind transactions associated with creations and redemptions were:
 
   
Creations
Redemptions
 
  High truBeta Fund
$10,318,814
$7,805,223
 
  Low truBeta Fund
     8,539,711
             —

During the current fiscal period, the High truBeta Fund paid $80 in brokerage commissions on trades of securities to Penserra Securities LLC, an affiliate of the Sub-Adviser.
 
NOTE 5 – INCOME TAX INFORMATION
 
The components of distributable earnings (accumulated deficit) and cost basis of investments for federal income tax purposes at December 31, 2019 were as follows:
 
     
High
   
Low
 
     
truBeta Fund
   
truBeta Fund
 
 
Tax cost of investments
 
$
14,486,949
   
$
8,610,236
 
 
Gross tax unrealized appreciation
 
$
1,275,214
   
$
751,492
 
 
Gross tax unrealized depreciation
   
(316,303
)
   
(91,968
)
 
Total unrealized appreciation (depreciation)
   
958,911
     
659,524
 
 
Undistributed ordinary Income
   
     
16,886
 
 
Undistributed long-term capital gains
   
     
6,132
 
 
Accumulated gain (loss)
   
     
23,018
 
 
Other accumulated gain (loss)
   
(544,211
)
   
 
 
Distributable earnings (accumulated deficit)
 
$
414,700
   
$
682,542
 

The difference between the cost basis for financial statement and federal income tax purposes is due primarily to timing differences in recognizing wash sales.
 
As of December 31, 2019, the Funds had no post-October capital losses and no late-year ordinary losses.
 
As of December 31, 2019, High truBeta Fund had short-term capital loss carryforwards of $544,211 with unlimited expiration. As of December 31, 2019, Low truBeta Fund had no capital loss carryforwards.
 
The tax character of distributions paid by the Funds during the period ended December 31, 2019 was $155,507 of ordinary income for High truBeta Fund and $138,282 of ordinary income for Low truBeta Fund.
 
The tax character of distributions paid during the period ended December 31, 2018 was $49,240 of ordinary income for High truBeta Fund. The Low truBeta Fund was not open as of December 31, 2018.
 
31

Salt ETFs
NOTES TO FINANCIAL STATEMENTS
December 31, 2019 (Continued)
NOTE 6 – SHARE TRANSACTIONS
 
Shares of the Funds are listed and trade on the Cboe BZX Exchange, Inc. (the “Exchange”). Market prices for the shares may be different from their NAV. The Funds issue and redeem shares on a continuous basis at NAV generally in blocks of 25,000 shares, called “Creation Units.” Creation Units are issued and redeemed principally in-kind for securities included in a specified universe. Once created, shares generally trade in the secondary market at market prices that change throughout the day. Except when aggregated in Creation Units, shares are not redeemable securities of the Funds. Creation Units may only be purchased or redeemed by certain financial institutions (“Authorized Participants”). An Authorized Participant is either (i) a broker-dealer or other participant in the clearing process through the Continuous Net Settlement System of the National Securities Clearing Corporation or (ii) a Depository Trust Company participant and, in each case, must have executed a Participant Agreement with the Distributor. Most retail investors do not qualify as Authorized Participants nor have the resources to buy and sell whole Creation Units. Therefore, they are unable to purchase or redeem the shares directly from the Funds. Rather, most retail investors may purchase shares in the secondary market with the assistance of a broker and are subject to customary brokerage commissions or fees.
 
The Funds currently offer one class of shares, which has no front-end sales load, no deferred sales charge, and no redemption fee. A fixed transaction fee is imposed for the transfer and other transaction costs associated with the purchase or sale of Creation Units. The standard fixed transaction fee for the Funds is $250, payable to the Custodian. The fixed transaction fee may be waived on certain orders if the Funds’ Custodian has determined to waive some or all the costs associated with the order or another party, such as the Adviser, has agreed to pay such fee. In addition,  a variable fee may be charged on all cash transactions or substitutes for Creation Units of up to a maximum of 2% of the value of the Creation Units subject to the transaction. Variable fees are imposed to compensate the Funds for transaction costs associated with the cash transactions. Variable fees received by the Funds, if any, are displayed in the capital shares transactions section of the Statements of Changes in Net Assets. The Funds may issue an unlimited number of shares of beneficial interest, with no par value. All shares of the Funds have equal rights and privileges.
 
NOTE 7 – PRINCIPAL RISK
 
Sector Risk. To the extent the Funds invest more heavily in particular sectors of the economy, their performance will be especially sensitive to developments that significantly affect those sectors.
 
32

Salt ETFs

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM



To the Shareholders of Salt ETFs and
Board of Trustees of ETF Series Solutions
 
Opinion on the Financial Statements
 
We have audited the accompanying statements of assets and liabilities, including the schedules of investments, of Salt ETFs comprising the funds listed below (the “Funds”), each a series of ETF Series Solutions, as of December 31, 2019, the related statements of operations, the statements of changes in net assets, and the financial highlights for each of the periods indicated below, including the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of each of the Funds as of December 31, 2019, the results of their operations, the changes in their net assets, and the financial highlights for each of the periods indicated below in conformity with accounting principles generally accepted in the United States of America.
 
   
Statement(s) of
 
 
Statements
Changes in
Financial
Fund Name
of Operations
Net Assets
Highlights
Salt High truBeta
For the year ended
For the year ended December 31, 2019
US Market ETF
December 31, 2019
and for the period from May 15, 2018 (commencement of operations) through December 31, 2018
Salt Low truBeta
For the period from March 12, 2019 (commencement of
US Market ETF
operations) through December 31, 2019

Basis for Opinion
 
These financial statements are the responsibility of the Funds’ management. Our responsibility is to express an opinion on the Funds’ financial statements based on our audits.  We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to the Funds in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.
 
We conducted our audits in accordance with the standards of the PCAOB.  Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement whether due to error or fraud.
 
Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the
 
33

Salt ETFs

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
(Continued)
financial statements.  Our procedures included confirmation of securities owned as of December 31, 2019, by correspondence with the custodian and brokers. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements.  We believe that our audits provide a reasonable basis for our opinion.
 
We have served as the Funds’ auditor since 2018.
 
 
COHEN & COMPANY, LTD.
Milwaukee, Wisconsin
February 28, 2020
 
34

Salt ETFs
TRUSTEES AND OFFICERS
(Unaudited)
Additional information about each Trustee of the Trust is set forth below. The address of each Trustee of the Trust is c/o U.S. Bank Global Fund Services, 615 E. Michigan Street, Milwaukee, WI 53202.
 
       
Number of
Other
   
Term of
 
Portfolios
Directorships
   
Office and
 
in Fund
Held by
Name
Position
Length of
 
Complex
Trustee
and Year
Held with
Time
Principal Occupation(s)
Overseen
During Past
of Birth
the Trust
Served
During Past 5 Years
by Trustee
5 Years
Independent Trustees
         
Leonard M. Rush, CPA
Lead
Indefinite
Retired; formerly Chief
49
Independent
Born: 1946
Indepen-
term;
Financial Officer,
 
Trustee,
 
dent
since
Robert W. Baird & Co.
 
Managed
 
Trustee
2012
Incorporated (wealth
 
Portfolio
 
and
 
management firm)
 
Series
 
Audit
 
(2000–2011).
 
(39 portfolios)
 
Committee
     
(since 2011).
 
Chairman
       
           
David A. Massart
Trustee
Indefinite
Co-Founder, President,
49
Independent
Born: 1967
 
term;
and Chief Investment
 
Trustee,
   
since
Strategist, Next Generation
 
Managed
   
2012
Wealth Management, Inc.
 
Portfolio
     
(since 2005).
 
Series
         
(39 portfolios)
         
(since 2011).
           
Janet D. Olsen
Trustee
Indefinite
Retired; formerly Managing
49
Independent
Born: 1956
 
term;
Director and General Counsel,
 
Trustee, PPM
   
since
Artisan Partners Limited
 
Funds
   
2018
Partnership (investment
 
(9 portfolios)
     
adviser) (2000–2013);
 
(since 2018).
     
Executive Vice President
   
     
and General Counsel,
   
     
Artisan Partners Asset
   
     
Management Inc.
   
     
(2012–2013); Vice President
   
     
and General Counsel, Artisan
   
     
Funds, Inc. (investment
   
     
company) (2001–2012).
   
Interested Trustee
         
Michael A. Castino
Trustee
Indefinite
Senior Vice President,
49
None
Born: 1967
and
term;
U.S. Bancorp Fund Services,
   
 
Chairman
Trustee
LLC (since 2013); Managing
   
   
since
Director of Index Services,
   
   
2014;
Zacks Investment
   
   
Chairman
Management (2011–2013).
   
   
since
     
   
2013
     

35

Salt ETFs
TRUSTEES AND OFFICERS
(Unaudited) (Continued)
The officers of the Trust conduct and supervise its daily business. The address of each officer of the Trust is c/o U.S. Bank Global Fund Services, 615 E. Michigan Street, Milwaukee, WI 53202. Additional information about the Trust’s officers is as follows:
 
   
Term of
 
   
Office and
 
Name
Position(s)
Length of
 
and Year
Held with
Time
 
of Birth
the Trust
Served
Principal Occupation(s) During Past 5 Years
Principal Officers of the Trust
     
Kristina R. Nelson
President
Indefinite
Senior Vice President, U.S. Bancorp Fund Services,
Born: 1982
 
term;
LLC (since 2020); Vice President, U.S. Bancorp Fund
   
since 2019
Services, LLC (2014–2020); Assistant Vice President,
     
U.S. Bancorp Fund Services, LLC (2013–2014).
       
Michael D. Barolsky
Vice
Indefinite
Senior Vice President, U.S. Bancorp Fund Services, LLC
Born: 1981
President
term;
(since 2019); Vice President, U.S. Bancorp Fund
 
and
since 2014
Services, LLC (2012-2019); Associate, Thompson Hine
 
Secretary
(other roles
LLP (law firm) (2008–2012).
   
since 2013)
 
       
James R. Butz
Chief
Indefinite
Senior Vice President, U.S. Bancorp Fund Services, LLC
Born: 1982
Compliance
term;
(since 2015); Vice President, U.S. Bancorp Fund
 
Officer
since 2015
Services, LLC (2014–2015); Assistant Vice President,
     
U.S. Bancorp Fund Services, LLC (2011–2014).
       
Kristen M. Weitzel, CPA
Treasurer
Indefinite
Vice President, U.S. Bancorp Fund Services, LLC
Born: 1977
 
term;
(since 2015); Assistant Vice President, U.S. Bancorp
   
since 2014
Fund Services, LLC (2011–2015); Manager,
   
(other roles
PricewaterhouseCoopers LLP (accounting firm)
   
since 2013)
(2005–2011).
       
Brett M. Wickmann
Assistant
Indefinite
Vice President, U.S. Bancorp Fund Services, LLC
Born: 1982
Treasurer
term;
(since 2017); Assistant Vice President, U.S. Bancorp
   
since 2017
Fund Services, LLC (2012–2017).
       
Elizabeth A. Winske
Assistant
Indefinite
Assistant Vice President, U.S. Bancorp Fund Services,
Born: 1983
Treasurer
term;
LLC (since 2016); Officer, U.S. Bancorp Fund Services,
   
since 2017
LLC (2012–2016).
       
Jason E. Shlensky
Assistant
Indefinite
Assistant Vice President, U.S. Bancorp Fund Services,
Born: 1987
Treasurer
term;
LLC (since 2019); Officer, U.S. Bancorp Fund Services,
   
since 2019
LLC (2014–2019).
       
Isabella K. Gentile
Assistant
Indefinite
Regulatory Administration Attorney, U.S. Bancorp
Born: 1994
Secretary
term;
Fund Services, LLC (since 2019), Regulatory
   
since 2020
Administration Intern, U.S. Bancorp Fund Services,
     
LLC (2018–2019) and Law Student (2016–2019).

The Statement of Additional Information (“SAI”) includes additional information about the Trustees and is available without charge, upon request, by calling toll free (800) 617-0004, by accessing the SEC’s website at www.sec.gov, or by accessing the Fund’s website at www.salt-funds.com.
 
36

Salt ETFs
EXPENSE EXAMPLES
For the Six-Months Ended December 31, 2019 (Unaudited)
As a shareholder of the Funds you incur two types of costs: (1) transaction costs, including brokerage commissions on purchases and sales of Fund shares, and (2) ongoing costs, including management fees and other Fund expenses. This example is intended to help you understand your ongoing costs (in dollars) of investing in the Funds and to compare these costs with the ongoing costs of investing in other funds. The example is based on an investment of $1,000 invested at the beginning of the period and held for the entire period (July 1, 2019 – December 31, 2019).
 
Actual Expenses
 
The first line of the table provides information about actual account values based on actual returns and actual expenses. You may use the information in this line, together with the amount you invested, to estimate the expenses that you paid over the period.  Simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then, multiply the result by the number in the first line under the heading entitled “Expenses Paid During the Period’’ to estimate the expenses you paid on your account during this period.
 
Hypothetical Example for Comparison Purposes
 
The second line of the table provides information about hypothetical account values based on a hypothetical return and hypothetical expenses based on the Funds’ actual expense ratios and an assumed rate of return of 5% per year before expenses, which is not the Funds’ actual return. The hypothetical account values and expenses may not be used to estimate the actual ending account balance or expenses you paid for the period. You may use this information to compare the ongoing costs of investing in the Funds and other funds. To do so, compare this 5% hypothetical example with the 5% hypothetical examples that appear in the shareholder reports of the other funds. Please note that the expenses shown in the table are meant to highlight your ongoing costs only and do not reflect any transactional costs, such as brokerage commissions paid on purchases and sales of Fund shares. Therefore, the second line of the table is useful in comparing ongoing costs only and will not help you determine the relative total costs of owning different funds. If these transactional costs were included, your costs would have been higher.
 
37

Salt ETFs
EXPENSE EXAMPLES
For the Six-Months Ended December 31, 2019 (Unaudited) (Continued)
High truBeta Fund
 
 
Beginning
Ending
 
 
Account Value
Account Value
Expenses Paid
 
July 1, 2019
December 31, 2019
During the Period 1
Actual
$1,000.00
$1,112.40
$1.54
Hypothetical (5% annual
     
  return before expenses)
  1,000.00
  1,023.74
  1.48

1
The dollar amounts shown as expenses paid during the period are equal to the annualized six-month expense ratio, 0.29%, multiplied by the average account value during the period, multiplied by the number of days in the current period, 184 days, and divided by the number of days in the most recent twelve-month period, 365 days.
 
Low truBeta Fund
 
 
Beginning
Ending
 
 
Account Value
Account Value
Expenses Paid
 
July 1, 2019
December 31, 2019
During the Period 2
Actual
$1,000.00
$1,081.30
$0.00
Hypothetical (5% annual
     
  return before expenses)
  1,000.00
  1,025.21
  0.00

2
The dollar amounts shown as expenses paid during the period are equal to the annualized six-month expense ratio, 0.00% (fee waivers in effect), multiplied by the average account value during the period, multiplied by the number of days in the period since inception, 184 days, and divided by the number of days in the most recent twelve-month period, 365 days.

38

Salt ETFs

APPROVAL OF ADVISORY AGREEMENT & BOARD CONSIDERATION
(Unaudited)
Pursuant to Section 15(c) of the Investment Company Act of 1940 (the “1940 Act”), at a meeting held on October 2-3, 2019 (the “Meeting”), in connection with Salt Financial LLC’s (“Salt” or the “Adviser”) request to reorganize the Salt Low truBeta US Market ETF, a series of Salt Funds Trust (the “Predecessor LSLT”) into a newly-formed series of the Trust with the same name (the “ESS LSLT” or the “Fund”), the Board of Trustees (the “Board”) of ETF Series Solutions (the “Trust”) considered the approval of the Investment Advisory Agreement (the “Advisory Agreement”) between Salt and the Trust, on behalf of the Fund, and the approval of the Investment Sub-Advisory Agreement (the “Sub-Advisory Agreement”) (together, the “Agreements”) between the Adviser, the Trust, on behalf of the Fund, and Penserra Capital Management LLC (“Penserra” or the “Sub-Adviser”).
 
Prior to the Meeting, the Board, including the Trustees who are not parties to the Agreements or “interested persons” of any party thereto, as defined in the 1940 Act (the “Independent Trustees”), reviewed written materials from the Adviser and Sub-Adviser (the “Materials”) regarding, among other things: (i) the nature, extent, and quality of the services to be provided by the Adviser and Sub-Adviser; (ii) the historical performance of the Fund; (iii) the cost of the services to be provided and the profits expected to be realized by the Adviser and the Sub-Adviser and their affiliates from services rendered to the Fund; (iv) comparative fee and expense data for the Fund and other investment companies with similar investment objectives; (v) the extent to which economies of scale are expected to be realized as the Fund grows and whether the advisory fee for the Fund reflects these economies of scale for the benefit of the Fund; and (vi) any other financial benefits to the Adviser and the Sub-Adviser and their affiliates resulting from services rendered to the Fund.
 
The Board also considered that the Adviser and the Sub-Adviser, along with other service providers of the Fund, had provided written updates on each firm over the course of the year with respect to their role as Adviser or Sub-Adviser to other series in the Trust, and the Board considered that information alongside the Materials in its evaluation of each firm’s fees and other aspects of the Agreements. The Board then discussed the Materials, the Adviser’s oral presentation, and any other information that the Board received at the Meeting, and deliberated on the approval of the Agreements in light of this information. In its deliberations, the Board did not identify any single piece of information discussed below that was all-important or controlling.
 
Approval of the Advisory Agreement with the Adviser
 
Nature, Extent, and Quality of Services to be Provided. The Trustees considered the scope of services to be provided under the Advisory Agreement, noting that the Adviser will be providing investment management services to the ESS LSLT. In considering the nature, extent, and quality of the services to be provided by the
 
39

Salt ETFs

APPROVAL OF ADVISORY AGREEMENT & BOARD CONSIDERATION
(Unaudited) (Continued)
Adviser, the Board considered the quality of the Adviser’s compliance program and past reports from the Trust’s CCO regarding his review of the Adviser’s compliance program, as well as their experience with the Adviser as the investment adviser to another series of the Trust. The Board noted that it had received a copy of the Adviser’s registration form (“Form ADV”), as well as the response of the Adviser to a detailed series of questions that included, among other things, information about the background and experience of the firm’s key personnel, the services to be provided by the Adviser, the firm’s financial resources, and the ownership structure of the firm.
 
The Board also considered other services to be provided to the ESS LSLT, such as monitoring adherence to the Fund’s investment restrictions, oversight of the sub-adviser, monitoring compliance with various Fund policies and with applicable securities regulations, and monitoring the extent to which the Fund achieves its investment objective as a passively-managed fund.
 
Historical Performance. The Board noted that the ESS LSLT had not yet commenced operations and concluded that the performance of the ESS LSLT, thus, was not a relevant factor in their deliberations. The Board then noted that it had received information regarding the Predecessor LSLT’s performance for the three-month period ended June 30, 2019 and compared it to the universe of US Large Blend ETFs as reported by Morningstar (the “Category Peer Group”). Additionally, because the fund is designed to track the performance of an index, the Board considered the extent to which the Predecessor LSLT tracked its index before fees and expenses.
 
The Board noted that, for the three-month period ended June 30, 2019, the Predecessor LSLT performed roughly in line with the performance of its underlying index and had outperformed the median return for the Category Peer Group. However, the Board noted that the fund had only been operational for less than one year, which was too short a time by which to judge how the fund would perform over a full market cycle.
 
Cost of Services to be Provided and Economies of Scale. The Board then reviewed the proposed expense ratio for the ESS LSLT, excluding the proposed fee waiver, and compared it to the Category Peer Group and a group of direct competitors identified by the Adviser (the “Selected Peer Group”). The Board noted that the proposed expense ratio for the ESS LSLT was above the median of the US Large Blend ETFs, but significantly less than the highest expense ratios in such peer group. The Board further noted that the peer group contained a number of low-cost funds that are part of large fund families and may not allow for an apt comparison because such funds may be launched for reasons not related to the adviser generating a profit from the particular peer fund, such as to protect the market share of the overall fund family. The Board also noted that such funds may benefit
 
40

Salt ETFs

APPROVAL OF ADVISORY AGREEMENT & BOARD CONSIDERATION
(Unaudited) (Continued)
from an unusually low cost structure based on the scale of their fund family. The Board also considered that the ESS LSLT’s proposed expense ratio was within the range of expense ratios for the Selected Peer Group and noted that such peer group only contained four funds.
 
The Board took into consideration that the advisory fee for the ESS LSLT was a “unified fee,” meaning the ESS LSLT would pay no expenses other than the advisory fee and certain other costs such as interest, brokerage, acquired fund and expenses, extraordinary expenses and, to the extent it is implemented, fees pursuant to a Distribution and/or Shareholder Servicing (12b-1) Plan. The Board noted that the Adviser would be responsible for compensating the Trust’s other service providers and paying the Fund’s other expenses out of its own fee and resources. The Board also evaluated the compensation and benefits expected to be received by the Adviser from its relationship with the Fund, taking into account an analysis of the Adviser’s anticipated profitability with respect to the Fund and the financial resources the Adviser had committed and proposed to commit to its business. The Board determined such analyses were not a significant factor given that the ESS LSLT had not yet commenced operations and the Predecessor LSLT had been operating for less than a year and consequently, the future size of the Fund and the Adviser’s future profitability were generally unpredictable. The Board expressed the view that it currently appeared that the Adviser might realize economies of scale in managing the Fund as assets grow in size. The Board further determined that, based on the amount and structure of the fund’s unitary fee, such economies of scale would be shared with fund shareholders, although the Board intends to monitor fees as the Fund grows in size and assess whether fee breakpoints may be warranted.  The Board also took into consideration the Adviser’s commitment to continue its waiver of the entire management fee through May 2020.
 
Conclusion.  No single factor was determinative of the Board’s decision to approve the Advisory Agreement; rather, the Board based its determination on the total mix of information available to it. Based on a consideration of all the factors in their totality, the Board, including a majority of the Independent Trustees, determined that the Advisory Agreement, including the compensation payable under the agreement, was fair and reasonable to the Fund. The Board, including a majority of the Independent Trustees, therefore determined that the approval of the Advisory Agreement was in the best interests of the Fund and its shareholders.
 
Approval of the Sub-Advisory Agreement with the Sub-Adviser
 
Nature, Extent, and Quality of Services to be Provided. The Board considered the scope of services to be provided to the ESS LSLT under the Sub-Advisory Agreement, noting that Penserra would provide investment management services to the Fund. The Board noted the responsibilities that Penserra would have as the ESS LSLT’s
 
41

Salt ETFs

APPROVAL OF ADVISORY AGREEMENT & BOARD CONSIDERATION
(Unaudited) (Continued)
investment sub-adviser, including: responsibility for the general management of the day-to-day investment and reinvestment of the assets of the Fund; determining the daily baskets of deposit securities and cash components; executing portfolio security trades for purchases and redemptions of the Fund’s shares conducted on a cash-in-lieu basis; oversight of general portfolio compliance with relevant law; responsibility for daily monitoring of tracking error and quarterly reporting to the Board; and implementation of Board directives as they relate to the Fund.
 
In considering the nature, extent, and quality of the services to be provided by Penserra, the Board considered reports of the Trust’s CCO with respect to Penserra’s compliance program and Penserra’s experience providing investment management services to other ETFs, including other series of the Trust. The Trustees further noted that they had received and reviewed the Materials with regard to Penserra and they had reviewed additional detailed information about Penserra at previous Board meetings. The Board also considered Penserra’s resources and capacity with respect to portfolio management, compliance, and operations given the number of funds for which it would be sub-advising.
 
Historical Performance. The Board noted that the ESS LSLT had not yet commenced operations and concluded that the performance of the ESS LSLT, thus, was not a relevant factor in their deliberations. Because the fund is designed to track the performance of an index, the Board considered the extent to which the Predecessor LSLT tracked its index before fees and expenses. The Board noted that, for the three-month period ended June 30, 2019, the Predecessor LSLT performed roughly in line with the performance of its underlying index. However, the Board noted that the fund had only been operational for less than one year, which was too short a time by which to judge how the fund would perform over a full market cycle.
 
Costs of Services Provided and Economies of Scale. The Board reviewed the advisory fee to be paid by Salt to Penserra for its services to the ESS LSLT. The Board considered the fees to be paid to Penserra would be paid by Salt from the fee Salt received from the Fund and noted that the fee reflected an arm’s-length negotiation between Salt and Penserra. The Board further determined the fee reflected an appropriate allocation of the advisory fee paid to each adviser given the work performed by each firm and noted that the fees were generally in line with those charged by Penserra in connection with other similar series of the Trust and other funds managed by Penserra. The Board noted that Penserra has an affiliated broker-dealer that was expected to execute some or all of the brokerage transactions for the Fund, and consequently, Penserra would indirectly benefit from commissions paid to such affiliated broker-dealer. The Board also evaluated the compensation and benefits expected to be received by Penserra from its relationship with the Fund, taking into account an analysis of Penserra’s profitability with respect to the Fund.
 
42

Salt ETFs

APPROVAL OF ADVISORY AGREEMENT & BOARD CONSIDERATION
(Unaudited) (Continued)
The Board expressed the view that it currently appeared that the Sub-Adviser might realize economies of scale in managing the Fund as assets grow in size and noted that the proposed fee schedule includes breakpoints as assets grow in size. The Board further noted that because the ESS LSLT pays the Adviser a unified fee, any benefits from the breakpoints in the sub-advisory fee schedule would accrue to the Adviser, rather than the Fund’s shareholders. Consequently, the Board determined that it would monitor fees as the Fund’s assets grow to determine whether economies of scale were being effectively shared with the Fund and its shareholders.
 
Conclusion.  No single factor was determinative of the Board’s decision to approve the Sub-Advisory Agreement; rather, the Board based its determination on the total mix of information available to it. Based on a consideration of all the factors in their totality, the Board, including a majority of the Independent Trustees, determined that the Sub-Advisory Agreement, including the compensation payable under the agreement, was fair and reasonable to the Fund. The Board, including a majority of the Independent Trustees, therefore determined that the approval of the Sub-Advisory Agreement was in the best interests of the Fund and its shareholders.
 
43

Salt ETFs
FEDERAL TAX INFORMATION
(Unaudited)
For the fiscal year ended December 31, 2019, certain dividends paid by the Fund may be subject to a maximum rate of 23.8%, as provided for by the Jobs and Growth Tax Relief Reconciliation Act of 2003.
 
The percentage of dividends declared from ordinary income designated as qualified dividend income was:

 
  High truBeta Fund
100.00%
 
  Low truBeta Fund
  66.98%
 
For corporate shareholders, the percent of ordinary income distributions qualifying for the corporate dividend received deduction for the fiscal year ended December 31, 2019 was:

 
  High truBeta Fund
100.00%
 
  Low truBeta Fund
  65.94%
 
The percentage of taxable ordinary income distributions that are designated as short-term capital gain distributions under Internal Revenue Section 871(k)(2)(C) for the Fund was:
 
 
  High truBeta Fund
  0.00%
 
  Low truBeta Fund
  1.42%

INFORMATION ABOUT PORTFOLIO HOLDINGS
(Unaudited)
The Fund files its complete schedules of portfolio holdings for its first and third fiscal quarters with the SEC on Form N-Q or Part F of Form N-PORT. The Funds’ Form N-Q or Part F of Form N-PORT is available without charge, upon request, by calling toll-free at (800) 617-0004. Furthermore, you may obtain the Form N-Q or Part F of Form N-PORT on the SEC’s website at www.sec.gov. The Funds’ portfolio holdings are posted on its website at www.salt-funds.com daily.
 
INFORMATION ABOUT PROXY VOTING
(Unaudited)
A description of the policies and procedures the Funds uses to determine how to vote proxies relating to portfolio securities is provided in the SAI. The SAI is available without charge, upon request, by calling toll-free at (800) 617-0004, by accessing the SEC’s website at www.sec.gov, or by accessing the Funds’ website at www.salt-funds.com.
 
Information regarding how the Funds voted proxies relating to portfolio securities during the period ending June 30 is available by calling toll-free at (800) 617-0004 or by accessing the SEC’s website at www.sec.gov.
 
44

Salt ETFs

FREQUENCY DISTRIBUTION OF PREMIUMS AND DISCOUNTS
(Unaudited)
Information regarding how often shares of each Fund trade on an exchange at a price above (i.e., at a premium) or below (i.e., at a discount) the NAV of each Fund is available, without charge, on the Funds’ website at www.salt-funds.com.
 
45

Adviser
Salt Financial LLC
20 West 22nd Street, Suite 511
New York, New York 10010

Sub-Adviser
Penserra Capital Management LLC
4 Orinda Way, Suite 100-A
Orinda, California 94563

Index Provider
Salt Financial Indices, LLC
20 West 22nd Street, Suite 511
New York, New York 10010

Distributor
Compass Distributors, LLC
Three Canal Plaza, Suite 100
Portland, Maine 04101

Custodian
U.S. Bank National Association
1555 North Rivercenter Drive, Suite 302
Milwaukee, Wisconsin 53212

Transfer Agent
U.S. Bancorp Fund Services, LLC
615 East Michigan Street
Milwaukee, Wisconsin 53202

Independent Registered Public Accounting Firm
Cohen & Company, Ltd.
342 North Water Street, Suite 830
Milwaukee, Wisconsin 53202

Legal Counsel
Morgan, Lewis & Bockius, LLP
1111 Pennsylvania Avenue, NW
Washington, DC 20004

Salt High truBeta US Market ETF
Symbol – SLT
CUSIP – 26922A479

Salt Low truBeta US Market ETF
Symbol – LSLT
CUSIP – 26922A164



Item 2. Code of Ethics.

The registrant has adopted a code of ethics that applies to the registrant’s principal executive officer and principal financial officer. The registrant has not made any amendments to its code of ethics during the period covered by this report. The registrant has not granted any waivers from any provisions of the code of ethics during the period covered by this report.
A copy of the registrant’s Code of Ethics is filed herewith.

Item 3. Audit Committee Financial Expert.

The registrant’s board of trustees has determined that there is at least one audit committee financial expert serving on its audit committee.  Mr. Leonard Rush is the “audit committee financial expert” and is considered to be “independent” as each term is defined in Item 3 of Form N‑CSR.

Item 4. Principal Accountant Fees and Services.

The registrant has engaged its principal accountant to perform audit services, audit-related services, tax services and other services during the past fiscal year.  “Audit services” refer to performing an audit of the registrant's annual financial statements or services that are normally provided by the accountant in connection with statutory and regulatory filings or engagements for those fiscal years.  “Audit-related services” refer to the assurance and related services by the principal accountant that are reasonably related to the performance of the audit.  “Tax services” refer to professional services rendered by the principal accountant for tax compliance, tax advice, and tax planning. There were no “Other services” provided by the principal accountant.  The following table details the aggregate fees billed or expected to be billed for the last fiscal year for audit fees, audit-related fees, tax fees and other fees by the principal accountant.

Salt High truBeta US Market ETF
 
FYE  12/31/2019
FYE  12/31/2018
Audit Fees
$14,000
$14,000
Audit-Related Fees
N/A
N/A
Tax Fees
$3,000
$3,000
All Other Fees
N/A
N/A

Salt Low truBeta US Market ETF
 
FYE  12/31/2019
FYE  12/31/2018
Audit Fees
$14,000
N/A
Audit-Related Fees
N/A
N/A
Tax Fees
$3,000
N/A
All Other Fees
N/A
N/A

The audit committee has adopted pre-approval policies and procedures that require the audit committee to pre‑approve all audit and non‑audit services of the registrant, including services provided to any entity affiliated with the registrant.

The percentage of fees billed by Cohen & Company, Ltd. applicable to non-audit services pursuant to waiver of pre-approval requirement were as follows:

Salt High truBeta US Market ETF
 
FYE  12/31/2019
FYE  12/31/2018
Audit-Related Fees
0%
0%
Tax Fees
0%
0%
All Other Fees
0%
0%

Salt Low truBeta US Market ETF
 
FYE  12/31/2019
FYE  12/31/2018
Audit-Related Fees
0%
N/A
Tax Fees
0%
N/A
All Other Fees
0%
N/A

All of the principal accountant’s hours spent on auditing the registrant’s financial statements were attributed to work performed by full‑time permanent employees of the principal accountant.

The following table indicates the non-audit fees billed or expected to be billed by the registrant’s accountant for services to the registrant and to the registrant’s investment adviser (and any other controlling entity, etc.—not sub-adviser) for the last year.  The audit committee of the board of trustees/directors has considered whether the provision of non-audit services that were rendered to the registrant's investment adviser is compatible with maintaining the principal accountant's independence and has concluded that the provision of such non-audit services by the accountant has not compromised the accountant’s independence.

Salt High truBeta US Market ETF
Non-Audit Related Fees
FYE  12/31/2019
FYE  12/31/2018
Audit-Related Fees
N/A
            N/A
Tax Fees
N/A
N/A

Salt Low truBeta US Market ETF
Non-Audit Related Fees
FYE  12/31/2019
FYE  12/31/2018
Audit-Related Fees
N/A
            N/A
Tax Fees
N/A
N/A

Item 5. Audit Committee of Listed Registrants.

The registrant is an issuer as defined in Rule 10A-3 under the Securities Exchange Act of 1934, (the “Act”) and has a separately-designated standing audit committee established in accordance with Section 3(a)(58)(A) of the Act.  The independent members of the committee are as follows: Leonard M. Rush, David A. Massart, and Janet D. Olsen.

Item 6. Investments.

Schedule of Investments is included as part of the report to shareholders filed under Item 1 of this Form.

Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.

Not applicable to open-end investment companies.

Item 8. Portfolio Managers of Closed-End Management Investment Companies.

Not applicable to open-end investment companies.

Item 9. Purchases of Equity Securities by Closed‑End Management Investment Company and Affiliated Purchasers.

Not applicable to open-end investment companies.

Item 10. Submission of Matters to a Vote of Security Holders.

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

Item 11. Controls and Procedures.

(a)
The Registrant’s President (principal executive officer) and Treasurer (principal financial officer) have reviewed the Registrant's disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940 (the “Act”)) as of a date within 90 days of the filing of this report, as required by Rule 30a-3(b) under the Act and Rules 13a-15(b) or 15d‑15(b) under the Securities Exchange Act of 1934.  Based on their review, such officers have concluded that the disclosure controls and procedures are effective in ensuring that information required to be disclosed in this report is appropriately recorded, processed, summarized and reported and made known to them by others within the Registrant and by the Registrant’s service provider.

(b)
There were no changes in the Registrant's internal control over financial reporting (as defined in Rule 30a-3(d) under the Act) that occurred during the second fiscal half-year of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Registrant's internal control over financial reporting.

Item 12. Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.

Not applicable to open-end investment companies.

Item 13. Exhibits.

(a)
(1) Any code of ethics or amendment thereto, that is the subject of the disclosure required by Item 2, to the extent that the registrant intends to satisfy Item 2 requirements through filing an exhibit. Filed herewith.

(2) A separate certification for each principal executive officer and principal financial officer pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.  Filed herewith.

(3) Any written solicitation to purchase securities under Rule 23c‑1 under the Act sent or given during the period covered by the report by or on behalf of the registrant to 10 or more persons.  Not applicable to open-end investment companies.

(4) Change in registrant’s independent public accountant. There was no change in the registrant’s public accountant for the period covered by this report.

(b)
Certifications pursuant to Section 906 of the Sarbanes‑Oxley Act of 2002.  Furnished herewith.

SIGNATURES

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


(Registrant)                          ETF Series Solutions

By (Signature and Title          /s/ Kristina R. Nelson
  Kristina R. Nelson, President (principal executive officer)

Date     March 9, 2020



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

By (Signature and Title)*      /s/ Kristina R. Nelson
  Kristina R. Nelson, President (principal executive officer)

Date     March 9, 2020

By (Signature and Title)*      /s/ Kristen M. Weitzel
  Kristen M. Weitzel, Treasurer (principal financial officer)

Date     March 9, 2020

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