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 811-23089
M3Sixty Funds Trust
(Exact name of registrant as specified in charter)
4300 Shawnee Mission Parkway, Suite 100 , Fairway, KS | 66205 |
(Address of principal executive offices) | (Zip code) |
The Corporation Trust Company
Corporation Trust Center
1209 Orange St.
Wilmington, DE 19801
(Name and address of agent for service)
With Copies To:
John H. Lively
Practus, LLP
11300 Tomahawk Creek Parkway, Suite 310
Leawood, KS 66211
Registrant's telephone number, including area code: 888-553-4233
Date of fiscal year end: 06/30/2018
Date of reporting period: 06/30/2018
ITEM 1. | REPORTS TO SHAREHOLDERS |
The Annual report to Shareholders of the Cognios Large Cap Value Fund, Cognios Large Cap Growth Fund and Cognios Market Neutral Fund, each a series of the M3Sixty Funds Trust (the “registrant”), for the period ended June 30, 2018 pursuant to Rule 30e-1 under the Investment Company Act of 1940 (the “1940 Act”), as amended (17 CFR 270.30e-1) is filed herewith.
ITEM 1. | REPORTS TO SHAREHOLDERS. |
The Annual Report to Shareholders of the Cognios Large Cap Value Fund (the “Value Fund), Cognios Large Cap Growth Fund (the “Growth Fund”) and Cognios Market Neutral Fund (the “Market Neutral Fund”, together with the Value Fund and the Growth Fund, the “Funds”), each a series of the M3Sixty Funds Trust (the “registrant”), for the period ended June 30, 2018 pursuant to Rule 30e-1 under the Investment Company Act of 1940, as amended (the “1940 Act”) (17 CFR 270.30e-1) is filed herewith.
ITEM 2. | CODE OF ETHICS. |
(a) | The registrant has, as of the end of the period covered by this report, adopted a code of ethics that applies to the registrant's principal executive officer, principal financial officer, and principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party. | |
(b) | During the period covered by this report, there were no amendments to any provision of the code of ethics. | |
(c) |
During the period covered by this report, there were no waivers or implicit waivers of a provision of the code of ethics.
| |
(d) | The registrant’s Code of Ethics is filed herewith. |
ITEM 3. | AUDIT COMMITTEE FINANCIAL EXPERT. |
The registrant's Board of Trustees has determined that Kelley J. Brennan serves on its audit committee as the "audit committee financial expert" as defined in Item 3 of Form N-CSR. |
ITEM 4. | PRINCIPAL ACCOUNTANT FEES AND SERVICES. |
(a)
|
Audit Fees. The aggregate fees billed for professional services rendered by the principal accountant for the audit of the registrant’s annual financial statements or for services that are normally provided by the accountant in connection with statutory and regulatory filings or engagements were $33,000 with respect to each of the Funds’ fiscal year ended June 30, 2018, $22,000 with respect to Value Fund’s and the Growth Fund’s fiscal year ended June 30, 2017, $14,000 with respect to the Market Neutral Fund’s fiscal year ended September 30, 2017 and $15,650 with respect to the Market Neutral Fund’s fiscal year ended September 30, 2016. The June 30, 2018 fees were paid to BBD, LLP. The June 30, 2017 and September 30, 2017 fees were paid to Cohen & Co. Ltd. The September 30, 2016 fees were paid to KPMG LLP. | |
(b) | Audit-Related Fees. There were no fees billed in each of the last two fiscal years for assurances and related services by the principal accountant that are reasonably related to the performance of the audit of the registrant’s financial statements and are not reported under paragraph (a) of this item. | |
(c) | Tax Fees. The aggregate fees billed in each of the last two fiscal years for professional services rendered by the principal accountant for tax compliance, tax advice and tax planning were $6,500 with respect to each of the Funds’ fiscal year ended June 30, 2018, $5,000 with respect to the Value Fund’s and Growth Fund’s fiscal year ended June 30, 2017, $3,000 with respect to the Market Neutral Fund’s fiscal year ended September 30, 2017 and $3,675 with respect to the Market Neutral Fund’s fiscal year ended September 30, 2016. The services comprising these fees are the preparation of the registrant’s federal income and excise tax returns. The June 30, 2018 fees were paid to BBD, LLP. The June 30, 2017 and September 30, 2017 fees were paid to Cohen & Co. Ltd. The September 30, 2016 fees were paid to KPMG LLP. |
(d) |
All Other Fees. The aggregate fees billed in each of the last two fiscal years for products and services provided by the registrant’s principal accountant, other than the services reported in paragraphs (a) through (c) of this item were $1,500 with respect to each of the Fund’s fiscal year ended June 30, 2018, $1,950 with respect to the Value Fund’s and the Growth Fund’s fiscal year ended June 30, 2017, $1,625 with respect to the Market Neutral Fund’s fiscal year ended September 30, 2017, and $0 with respect to the Market Neutral Fund’s fiscal year ended September 30, 2016. The fees were for the review of the semi-annual report and review of prior audit firms’ tax workpapers. The June 30, 2018 and June 30, 2017 fees were paid to Cohen & Co. Ltd. The September 30, 2017 and September 30, 2016 fees were paid to KPMG LLP.
| |
(e)(1) |
The audit committee does not have pre-approval policies and procedures. Instead, the audit committee or audit committee chairman approves on a case-by-case basis each audit or non-audit service before the principal accountant is engaged by the registrant.
| |
(e)(2) |
There were no services described in each of paragraphs (b) through (d) of this Item that were approved by the audit committee pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X.
| |
(f) |
Not applicable. The percentage of hours expended on the principal accountant's engagement to audit the registrant's financial statements for the most recent fiscal year that were attributed to work performed by persons other than the principal accountant's full-time, permanent employees was zero percent (0%).
| |
(g) |
All non-audit fees billed by the registrant's principal accountant for services rendered for the fiscal year ended June 30, 2018 with respect to each of the Funds, the fiscal year ended June 30, 2017 with respect to the Value Fund and the Growth Fund, the fiscal year ended September 30, 2017 with respect to the Market Neutral Fund and the fiscal year ended September 30, 2016 with respect to the Market Neutral Fund are disclosed in (b)-(d) above. There were no audit or non-audit services performed by the registrant's principal accountant for the registrant's adviser. BBD, LLP served as principal accountant of the Funds for the fiscal year ended June 30, 2018. Cohen & Co. Ltd. served as principal accountant for the fiscal year ended June 30, 2017 with respect to the Value Fund and the Growth Fund and during the fiscal year ended September 30, 2017 with respect to the Market Neutral Fund. KPMG, LLP served as principal accountant for the fiscal year ended September 30, 2016 with respect to the Market Neutral Fund.
| |
(h) | The registrant’s audit committee has considered whether the provision of non-audit services that were rendered to the registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the registrant that were not pre-approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X, is compatible with maintaining the principal accountant’s independence and has determined that the provision of such non-audit services is compatible with maintaining the principal accountant’s independence. |
ITEM 5. | AUDIT COMMITTEE OF LISTED REGISTRANTS. |
Not applicable to the registrant.
ITEM 6. | SCHEDULES OF INVESTMENTS. |
Included in Annual Report to shareholders filed under Item 1 of this Form N-CSR.
ITEM 7. | DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES. |
Not applicable as the Funds are open-end management investment companies.
ITEM 8. | PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES. |
Not applicable as the Funds are open-end management investment companies.
ITEM 9. | PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS. |
Not applicable as the Funds are open-end management investment companies.
ITEM 10. | SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS. |
Not applicable at this time.
ITEM 11. | CONTROLS AND PROCEDURES. |
(a) | The registrant's principal executive and principal financial officers, or persons performing similar functions, have concluded that the registrant's disclosure controls and procedures (as defined in Rule 30a-3(c) under the 1940 Act, are effective, as of a date within 90 days of the filing date of this report, based on the evaluation of these controls and procedures required by Rule 30a-3(b) under the 1940 Act and Rule 15d-15(b) under the Securities Exchange Act of 1934, as amended. | |
(b) | There were no changes in the registrant's internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act) that occurred during the period covered by this report that have materially affected, or are 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 as the Funds are open-end management investment companies.
ITEM 13. | EXHIBITS. |
Code of Ethics for Principal Executive and Senior Financial Officers is attached hereto.
Certifications pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 are filed herewith.
Certifications pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 are filed 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.
M3Sixty Funds Trust
/s/ Randy Linscott | |
By: Randy Linscott | |
Principal Executive Officer, | |
Date: September 10, 2018 |
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 person on behalf of the registrant and in the capacities and on the date indicated.
/s/ Randy Linscott | |
By: Randy Linscott | |
Principal Executive Officer, | |
Date: September 10, 2018 |
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 person on behalf of the registrant and in the capacities and on the date indicated.
/s/ Justin Thompson | |
By: Justin Thompson | |
Principal Financial Officer | |
Date: September 10, 2018 |
Exhibit 99.COE
360 FUNDS / M3Sixty Funds Trust
SUPPLEMENTAL
CODE OF ETHICS FOR
PRINCIPAL EXECUTIVE AND PRINCIPAL FINANCIAL OFFICERS
A.
Covered Officers/Purpose of the Code
This Code of Ethics for Principal Executive and Principal Financial Officers (the “Code”) for each Trust (each, a “Company”) applies to the Trust’s Principal Executive Officer, Principal Financial Officer and Principal Accounting Officer(s) (the “Covered Officers” each of whom are set forth in Exhibit A) for the purpose of promoting:
●
honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
●
full, fair, accurate, timely and understandable disclosure in reports and documents that a registrant files with, or submits to, the Securities and Exchange Commission (“SEC”) and in other public communications made by the Company;
●
compliance with applicable laws and governmental rules and regulations;
●
the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and
●
accountability for adherence to the Code.
B.
Covered Officers Should Handle Ethically Actual and Apparent Conflicts of Interest
Overview. A “conflict of interest” occurs when a Covered Officer’s private interest in any material respect interferes with the interests of, or his service to, the Company. For example, a conflict of interest would arise if a Covered Officer, or a member of his family, receives improper personal benefits as a result of his position with the Company.
Certain conflicts of interest arise out of the relationships between Covered Officers and the Company and already are subject to conflict of interest provisions in the Investment Company Act of 1940 (“Investment Company Act”) and the Investment Advisers Act of 1940 (“Investment Advisers Act”). For example, Covered Officers may not individually engage in certain transactions (such as the purchase or sale of securities or other property, other than shares of beneficial interest of the Company) with the Company because of their status as “affiliated persons” of the Company. The Company’s and the investment adviser’s compliance programs and procedures are designed to prevent, or identify and correct, violations of these provisions. This Code does not, and is not intended to, repeat or replace these programs and procedures, and such conflicts fall outside of the parameters of this Code.
Although typically not presenting an opportunity for improper personal benefit, conflicts arise from, or as a result of, the contractual relationship between the Company and the investment adviser/administrator of which the Covered Officers are also officers or employees. As a result, this Code recognizes that the Covered Officers will, in the normal course of their duties (whether formally for the Company or for the adviser/administrator, or for both), be involved in establishing policies and implementing decisions that may have different effects on the adviser/administrator and the Company. The participation of the Covered Officers in such activities is inherent in the contractual relationship between the Company and the adviser/administrator and is consistent with the performance by the Covered Officers of their duties as officers of the Company. Thus, if performed in conformity with the provisions of the Investment Company Act and the Investment Advisers Act, such activities will be deemed to have been handled ethically. In addition, it is recognized by the Company’s Board of Directors (“Board”) that the Covered Officers may also be officers or employees of one or more investment companies covered by other codes.
Other conflicts of interest are covered by the Code, even if such conflicts of interest are not subject to provisions in the Investment Company Act and the Investment Advisers Act. The following list provides examples of conflicts of interest under the Code, but Covered Officers should keep in mind that these examples are not exhaustive. The overarching principle is that the personal interest of a Covered Officer should not be placed improperly before the interest of the Company.
Each Covered Officer must:
●
not use his personal influence or personal relationships improperly to influence investment decisions or financial reporting by the Company whereby the Covered Officer would benefit personally to the detriment of the Company;
●
not cause the Company to take action, or fail to take action, for the individual personal benefit of the Covered Officer to the detriment of the Company;
●
not use material non-public knowledge of portfolio transactions made or contemplated for the Company to trade personally or cause others to trade personally in contemplation of the market effect of such transactions;
●
report at least annually any affiliations or other relationships related to conflicts of interest that the Company’s Directors and Officers Questionnaire covers.
There are some conflict of interest situations that should always be discussed with the Audit Committee of the Company if such situations might have a material adverse effect on the Company. Examples of these include:
●
service as a director on the board of any public company;
●
the receipt of non-nominal gifts;
●
the receipt of entertainment from any company with which the Company has current or prospective business dealings, including investments in such companies, unless such entertainment is business-related, reasonable in cost, appropriate as to time and place, and not so frequent as to raise any questions of impropriety;
●
any ownership interest in, or any consulting or employment relationship with, any of the Company’s service providers, other than its investment adviser, principal underwriter, administrator or any affiliated person thereof;
●
a direct or indirect financial interest in commissions, transaction charges or spreads paid by the Company for effecting portfolio transactions, including but not limited to certain soft dollar arrangements, or for selling or redeeming shares other than an interest arising from the Covered Officer’s employment, such as compensation or equity ownership.
C.
Disclosure and Compliance
●
each Covered Officer should familiarize himself with the disclosure requirements generally applicable to the Company;
●
each Covered Officer should not knowingly misrepresent, or cause others to misrepresent, facts about the Company to others, whether within or outside the Company, including to the Company’s directors and auditors, and to governmental regulators and self-regulatory organizations;
●
each Covered Officer should, to the extent appropriate within his area of responsibility, consult with other officers and employees of the Company and the adviser/administrator with the goal of promoting full, fair, accurate, timely and understandable disclosure in the reports and documents the Company files with, or submits to, the SEC and in other public communications made by the Company; and
●
it is the responsibility of each Covered Officer to promote compliance with the standards and restrictions imposed by applicable laws, rules and regulations.
D.
Reporting and Accountability
Each Covered Officer must:
●
upon adoption of the Code (or thereafter as applicable, upon becoming a Covered Officer), affirm in writing to the Board that he has received, read, and understands the Code;
●
annually thereafter affirm to the Board that he has complied with the requirements of the Code;
●
not retaliate against any other Covered Officer or any employee of the Company or their affiliated persons for reports of potential violations that are made in good faith; and
●
notify the Audit Committee for the Company promptly if he knows of any material violation of this Code.
The Audit Committee is responsible for applying this Code to specific situations in which questions are presented under it and has the authority to interpret this Code in any particular situation. However, any approvals or waivers sought by a Covered Officer will be considered by the Audit Committee.
The Company will follow these procedures in investigating and enforcing this Code:
●
the Chief Compliance Officer of the Company (or such other Company officer or other investigator as the Audit Committee may from time to time designate) (the “Investigator”), shall take appropriate action to investigate any potential violations reported to him; if, after such investigation, the Investigator believes that no violation has occurred, the Investigator is not required to take any further action;
●
any matter that the Investigator believes is a violation will be reported to the Audit Committee;
●
if the Audit Committee concurs that a violation has occurred, it will inform and make a recommendation to the Board, which will consider appropriate action, which may include review of, and appropriate modifications to, applicable policies and procedures; notification to appropriate personnel of the investment adviser/administrator or its board; or a recommendation to dismiss the Covered Officer;
●
the Board will be responsible for granting waivers, as appropriate; and
●
any changes to or waivers of this Code will, to the extent required, be disclosed as provided by SEC rules.
Any potential violation of this Code by the Investigator shall be reported to the Audit Committee and the Audit Committee shall appoint an alternative Company officer or other investigator to investigate the matter.
E.
Other Policies and Procedures
This Code shall be the sole code of ethics adopted by the Company for purposes of Section 406 of the Sarbanes-Oxley Act and the rules and forms applicable to registered investment companies thereunder. Insofar as other policies or procedures of the Company, the Company’s adviser, principal underwriter, or other service providers govern or purport to govern the behavior or activities of the Covered Officers who are subject to this Code, they are superseded by this Code to the extent that they overlap or conflict with the provisions of this Code. The Company’s and its investment adviser’s and principal underwriter’s codes of ethics under Rule 17j-1 under the Investment Company Act are separate requirements applying to the Covered Officers and others, and are not part of this Code.
F.
Amendments
Any amendments to this Code, other than amendments to Exhibit A, must be approved or ratified by a majority vote of the Board, including a majority of independent directors.
G.
Confidentiality
All reports and records prepared or maintained pursuant to this Code will be considered confidential and shall be maintained and protected accordingly. Except as otherwise required by law or regulation or this Code, such matters shall not be disclosed to anyone other than the Board and the Audit Committee.
H.
Internal Use
The Code is intended solely for the internal use by the Company and does not constitute an admission, by or on behalf of the Company, as to any fact, circumstance, or legal conclusion.
Exhibit A
Persons Covered by this Code of Ethics
Randy Linscott, Principal Executive Officer, M3Sixty Funds Trust and 360 Funds
Justin Thompson, Principal Financial Officer, M3Sixty Funds Trust and 360 Funds
Exhibit B
Covered Officer Affirmation of Understanding
In accordance with Section D of the Code of Ethics for Principal Executive and Senior Financial Officers (the “Code”), the undersigned Covered Officer of the Company (as defined in the Code) hereby affirms to the Board that the Covered Officer has received, read, and understands the Code.
Date: 10/25/2017 | |||
Covered Officer – Randy Linscott, Principal Executive Officer | |||
Date: 10/25/2017 | |||
Covered Officer – Justin Thompson, Principal Financial Officer |
Exhibit 99.CERT
Certification Pursuant to Section 302 of the Sarbanes-Oxley Act
I, Randy Linscott, certify that:
1. | I have reviewed this report on Form N-CSR of the Cognios Large Cap Value Fund, the Cognios Large Cap Growth Fund and the Cognios Market Neutral Large Cap Fund, each a series of the M3Sixty Funds Trust (the “registrant”); |
2. | Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report; |
3. | Based on my knowledge, the financial statements, and other financial information included in this report fairly present in all material respects the investments of the registrant as of the end of the fiscal period for which the report is filed; |
4. | The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3 (d) under the Investment Company Act of 1940) for the registrant and have: |
(a) | Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared; |
(b) | Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles; |
(c) | Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and |
(d) | Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during 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; and |
5. | The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of Directors (or persons performing the equivalent functions): |
(a) | All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and |
(b) | Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting. |
Date: September 10, 2018 | /s/ Randy Linscott | |
Randy Linscott | ||
Principal Executive Officer |
Certification Pursuant to Section 302 of the Sarbanes-Oxley Act
I, Justin Thompson certify that:
1. | I have reviewed this report on Form N-CSR of the Cognios Large Cap Value Fund, the Cognios Large Cap Growth Fund and the Cognios Market Neutral Large Cap Fund, each a series of the M3Sixty Funds Trust (the “registrant”); |
2. | Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report; |
3. | Based on my knowledge, the financial statements, and other financial information included in this report fairly present in all material respects the investments of the registrant as of the end of the fiscal period for which the report is filed; |
4. | The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3 (d) under the Investment Company Act of 1940) for the registrant and have: |
(a) | Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared; |
(b) | Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles; |
(c) | Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and |
(d) | Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during 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; and |
5. | The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of Directors (or persons performing the equivalent functions): |
(a) | All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and | |
(b) | Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting. |
Date: September 10, 2018 | /s/ Justin Thompson | |
Justin Thompson | ||
Principal Financial Officer |
Exhibit 99.906CERT
CERTIFICATION PURSUANT TO SECTION 906 OF THE SARBANES-OXLEY ACT
I, Randy Linscott, Principal Executive Officer of the M3Sixy Funds Trust (the “Trust”), certify that:
1. | The N-CSR of the Cognios Large Cap Value Fund, the Cognios Large Cap Growth Fund and the Cognios Market Neutral Large Cap Fund, each a series of the Trust, for the fiscal year ended June 30, 2018 (the "Report") fully complies with the requirements of Section 15(d) of the Securities Exchange Act of 1934; and |
2. | The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the registrant. |
By: | /s/ Randy Linscott | |
Randy Linscott | ||
Principal Executive Officer | ||
Date: | September 10, 2018 |
A SIGNED ORIGINAL OF THIS WRITTEN STATEMENT REQUIRED BY SECTION 906, OR OTHER DOCUMENT AUTHENTICATING, ACKNOWLEDGING, OR OTHERWISE ADOPTING THE SIGNATURE THAT APPEARS IN TYPED FORM WITHIN THE ELECTRONIC VERSION OF THIS WRITTEN STATEMENT REQUIRED BY SECTION 906, HAS BEEN PROVIDED TO M3SIXTY ADMINISTRATION, LLC AND WILL BE RETAINED BY M3SIXTY ADMINISTRATION, LLC. AND FURNISHED TO THE SECURITIES AND EXCHANGE COMMISSION OR ITS STAFF UPON REQUEST.
CERTIFICATION PURSUANT TO SECTION 906 OF THE SARBANES-OXLEY ACT
I, Justin Thompson, Principal Financial Officer of the M3Sixty Funds Trust, (the “Trust”), certify that:
1. | The N-CSR of the Cognios Large Cap Value Fund, the Cognios Large Cap Growth Fund and the Cognios Market Neutral Large Cap Fund, each a series of the Trust, for the fiscal year ended June 30, 2018 (the "Report") fully complies with the requirements of Section 15(d) of the Securities Exchange Act of 1934; and |
2. | The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the registrant. |
By: | /s/ Justin Thompson | |
Justin Thompson | ||
Principal Financial Officer | ||
Date: | September 10, 2018 |
A SIGNED ORIGINAL OF THIS WRITTEN STATEMENT REQUIRED BY SECTION 906, OR OTHER DOCUMENT AUTHENTICATING, ACKNOWLEDGING, OR OTHERWISE ADOPTING THE SIGNATURE THAT APPEARS IN TYPED FORM WITHIN THE ELECTRONIC VERSION OF THIS WRITTEN STATEMENT REQUIRED BY SECTION 906, HAS BEEN PROVIDED TO M3SIXTY ADMINISTRATION, LLC. AND WILL BE RETAINED BY M3SIXTY ADMINISTRATION, LLC AND FURNISHED TO THE SECURITIES AND EXCHANGE COMMISSION OR ITS STAFF UPON REQUEST.
*@BAR6P< .)$\98C1$WF)#ABCBNR( )-UAB@XTY
M!NEA"3<8(>.1RQC^8<,$0C:)8XA&-J)D"4Y6V>$$-D2)Y); W$"EE6 .V6,B
M-V 0YID;\LCEFKJP\ ":<&[( M:*F$$"S?&B>:<;/8I"YYZ!JHA"D88<8*@
M@?+IYZ*I (KHHY FR@*CE(KB0XI@,M!B@C :,N")F$8JYZ8^=%K(IQ?F624$
M/53JZB9F5AEBD940&*J>$XA8B1$.,BGKJ\!2TH.J.3[ @JF9W(#"K4XR@,*8
MF]S)+(X,0!OLM8H<*N2 , 4-I48O$DIYL@FT>W#&'QEK?ZJ:_DU4
M+U4_561P/Y49'T%:Y( -KA)+")$\30)DQ52 ,*(_C"5R"&=C"8=T[]58F1-\
MH+%P725K<,)-(RB"R6(E%45D.%-@&B=FTF<[UX(M ^
M?=NV;MVT:O/FG=MW[EKE?-)[^=:B!I1"@B@C&"0_ZCG_XXR!YO#>]5MQL0]3K
MA.7^=XH9JI \(O30\#J1PP^"PH0;DI\I>L@A(=YP.PFD8=5&%PH(:DB)I6#A
MA@YXQ.JLS8BE6!L(-:$_!KCB85ZLHG><9\!6D#&&H&C? 6Y7B@2R48S4D>(!
MPCA!%;U1$V3<("L>!D4X3D=4@*3C*/@&R#CY43MD+&2<@N8O13Z*BH=
YXS[O>]\[WOOO^_>^
M#[S@!T_XPAO^\(A/O.(7S_C&._[QD(^\Y"=/^A'3_K2F_[TJ$^]ZE?/^M:[_O6PC[WL9T_[VMO^]KC/O>YWS_O>^YY2"C
M 0B @!_\_C<_($ $+" !"@_ B'^(U3$^]8W?BW$'PD$!. ([B> #0? "HG_$Q[\ <#__@. :@ />'
M"D*P ,+G?_XW $H!+%P!,$W C8?P% ? M@?IWP?Q9H"2V !S8@1XX?I.P
M@1XX@@@ @J(0 PB@?!$( ) D ?JN @@3^L(+_AP PJ @ H !*D(*", %
MH 0"@ "+UP(&L'\T&($#H 9* I"D 0>(1(B !+> I-^(10B( %H(.;P'\#
M,("3@ !0*(1?>(5B^ E$& !7Z'\!8 F2 H+,(-IR():> @M8'\[6'T+L'P[
M2 ")]P,&$(6# .2\; 5]M%LDO0A2B
P;DXA[$+=<%-880,U"$I3?T'[7ZSH8-N=4V )5L]9"H'?K
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ML7959&"C-^K>^LED8IB)#@!KMAB,L]9!QAZK,7(W'(P+K6:>O%X
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M#277>;BB6Q1X6YIWZGXEH;L;M '+#"K4+U[784!'6=+IE)QE=BGN"P6W*]>
MEJ5EQ*[*Y>.$L+EC7W_7A#?OB&7RN<]M5\)S+#1?^62CLNU:MZ'&RG%Z6')I
MIB4SS9,*C NU0"MX($28)0>4B7*^ZV2W_K=+D./O@9K1TSEI>?]\5F9&X6
MZ@4O3.G6%)ZZ[WCL*L,Y^AS=L&K[1J2H^7U9K' 8RP<6P_O:2"*9K*%-K',;
MIPIAO"_9=ZB@B
I*N2N.%BB$ZY(=&AC9,!L6,5-V7)%,DR>H"R%
MR$]6TQZ$BF7UE$UXL\^JE3=&I!-I]XZ#1_&ZH["<#));(5YD+/!HBTDQ^STT&<@""=
MD+[]E=7/UVMT"\9Q5]+[26L*%HG$VI$L78GW^=#EZX&VA;J4?;1#, 0-?+1&
MP(_=S*&=2*@^#<[^&GRH2NA6)=Q0DF2O#G6$C)Q['AO)_G;/QU)I;RO*D8,D
M)R')H#JJL2VV7/W)76.3"^M[-P6XBGE2&S@R?(