Form N-CSRS Trust for Advised Portfo For: Sep 30

December 8, 2021 11:38 AM EST

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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 811-21422



Trust for Advised Portfolios
(Exact name of registrant as specified in charter)



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



Christopher E. Kashmerick
Trust for Advised Portfolios
777 East Wisconsin Avenue, 10th Floor
Milwaukee, Wisconsin 53202
(Name and address of agent for service)



(626) 914-7385
Registrant's telephone number, including area code



Date of fiscal year end: March 31


Date of reporting period:  September 30, 2021

Item 1. Reports to Stockholders.

(a)


 

 

BRAMSHILL INCOME
PERFORMANCE FUND

INSTITUTIONAL CLASS (BRMSX)

 

 

SEMI-ANNUAL REPORT TO SHAREHOLDERS

SEPTEMBER 30, 2021

 

 

 

TABLE OF CONTENTS

 

EXPENSE EXAMPLE 1
ALLOCATION OF PORTFOLIO HOLDINGS 2
SCHEDULE OF INVESTMENTS 3
STATEMENT OF ASSETS AND LIABILITIES 7
STATEMENT OF OPERATIONS 8
STATEMENTS OF CHANGES IN NET ASSETS 9
FINANCIAL HIGHLIGHTS 10
NOTES TO FINANCIAL STATEMENTS 11
ADDITIONAL INFORMATION 20
PRIVACY NOTICE 23

 

 

 

 

Bramshill Income Performance Fund

Expense Example (Unaudited)

September 30, 2021

 

 

As a shareholder of the Fund, you may incur two types of costs: (1) transaction costs; and (2) ongoing costs, including management fees, shareholder servicing fees, and other Fund expenses. This Example is intended to help you understand your ongoing costs (in dollars) of investing in the Fund and to compare these costs with the ongoing costs of investing in other mutual funds.

 

The Example is based on an investment of $1,000 invested at the beginning of the period and held for the entire period from April 1, 2021 to September 30, 2021 (the “period”).

 

Actual Expenses

 

The first line of the table below provides information about actual account values and actual expenses. You may use the information in this line, together with the amount you invested, to estimate the expenses you paid over the period. Simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 equals 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 the period.

 

Hypothetical Example for Comparison Purposes

 

The second line of the table below provides information about hypothetical account values and hypothetical expenses based on the Fund’s actual expense ratio and an assumed rate of return of 5% per year before expenses, which is not the Fund’s 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 Fund and other funds. To do so, compare this 5% hypothetical example with the 5% hypothetical examples that appear in the shareholder reports of 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 sales charges (loads). Therefore, the second line of the table is useful in comparing the ongoing costs only, and will not help you determine the relative total costs of owning different funds. In addition, if these transactional costs were included, your costs could have been higher.

 

Expenses Paid During the Period

 

    Beginning
Account Value
 

Ending

Account Value

  Expenses
Paid
During the
Period(1)
Institutional Class                        
Actual Fund Return   $ 1,000.00     $ 1,026.80     $ 5.13  
Hypothetical 5% Return     1,000.00       1,020.00       5.11  

 


(1) Expenses are equal to the Fund’s annualized expense ratio of 1.01%, multiplied by the average account value over the period, multiplied by 183/365. The expense ratios reflect an expense waiver. Assumes all dividends and distributions were reinvested.

 

1 

 

 

Bramshill Income Performance Fund

Allocation of Portfolio Holdings (Unaudited)

(Calculated as a percentage of Total Investments)

September 30, 2021

 

 

 

 

2 

 

Bramshill Income Performance Fund

Schedule of Investments (Unaudited)

September 30, 2021

 

 

Principal

Amount

      Value
        CORPORATE BONDS ― 18.0%        
        ENERGY ― 5.9%        
  24,581,000     BP Capital Markets PLC
4.875% (effective 6/22/2030, 5 Year TNCMR + 4.398%) (1), 3/22/2030 (2)
  $ 27,082,366  
  16,105,000     Edison International
5.375% (effective 3/15/2026, 5 Year TNCMR + 4.698%) (1), 3/15/2026 (2)
    16,673,506  
  7,298,000     Valero Energy Corp.
2.700%, 4/15/2023
    7,534,704  
              51,290,576  
        FINANCIALS ― 6.0%        
        Ally Financial, Inc.        
  9,344,000     4.700% (effective 5/15/2026, 5 Year TNCMR + 3.868%) (1), 5/15/2026 (2)     9,754,902  
  15,212,000     4.700% (effective 5/15/2028, 7 Year TNCMR + 3.481%) (1), 5/15/2028 (2)     15,934,570  
  6,440,000     Capital One Financial Corp.
2.600%, 5/11/2023
    6,656,859  
  8,643,000     Coinbase Global, Inc. (3)
3.375%, 10/1/2028
    8,329,691  
  8,115,000     FS KKR Capital Corp.
2.625%, 1/15/2027
    8,136,260  
  3,574,000     Oaktree Specialty Lending Corp.
3.500%, 2/25/2025
    3,744,275  
              52,556,557  
        LODGING ― 1.2%        
  9,624,000     Marriott Ownership Resorts, Inc. (3)
6.125%, 9/15/2025
    10,177,380  
                 
        MANUFACTURING ― 2.5%        
  20,469,000     Boeing Co. (The)
4.508%, 5/1/2023
    21,628,651  
                 
        PIPELINES ― 2.4%        
        Energy Transfer LP        
  9,845,000     6.500% (effective 11/15/2026, 5 Year TNCMR + 5.694%) (1), 11/15/2026 (2)     10,276,900  
  5,688,000     7.125% (effective 5/15/2030, 5 Year TNCMR + 5.306%) (1), 5/15/2030 (2)     5,936,850  
  5,100,000     3.143% (3 month U.S. LIBOR + 3.018%) (4), 11/1/2066     4,213,620  
              20,427,370  
        TOTAL CORPORATE BONDS        
        (Cost $150,295,735)     156,080,534  
                 
        U.S. GOVERNMENT NOTES ― 27.3%        
        United States Treasury Note/Bond        
  124,483,000     2.500%, 1/15/2022     125,363,805  
  110,000,000     1.750%, 6/15/2022     111,284,385  
              236,648,190  
        TOTAL U.S. GOVERNMENT NOTES        
        (Cost $236,663,138)     236,648,190  

 

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

 

3 

 

Bramshill Income Performance Fund

Schedule of Investments (Unaudited)

September 30, 2021

 

 

Principal
Amount
      Value
        CLOSED-END FUNDS ― 14.0%        
        BANK LOAN ― 1.4%        
  130,041     BlackRock Debt Strategies Fund, Inc.   $ 1,500,673  
  1,224,619     Invesco Senior Income Trust     5,449,555  
  718,193     Nuveen Credit Strategies Income Fund     4,711,346  
              11,661,574  
        CORPORATE BOND ― 0.2%        
  122,598     BlackRock Credit Allocation Income Trust     1,857,360  
                 
        HIGH YIELD BOND ― 3.3%        
  930,467     BlackRock Corporate High Yield Fund, Inc.     11,351,697  
  97,122     BlackRock Limited Duration Income Trust     1,659,815  
  132,023     First Trust High Income Long/Short Fund     2,097,845  
  532,564     Wells Fargo Income Opportunities Fund     4,686,563  
  869,259     Western Asset High Income Opportunity Fund, Inc.     4,511,454  
  276,749     Western Asset High Yield Defined Opportunity Fund Inc.     4,408,612  
              28,715,986  
        MULTISECTOR BOND ― 0.0%        
  4,482     Eaton Vance Limited Duration Income Fund     59,073  
                 
        MUNI NATIONAL LONG ― 8.3%        
  118,458     BlackRock MuniHoldings Fund, Inc.     1,939,158  
  689,513     BlackRock MuniVest Fund, Inc.     6,529,688  
  243,258     BlackRock MuniYield Quality Fund III, Inc.     3,571,027  
  408,116     Eaton Vance Municipal Bond Fund     5,460,592  
  719,887     Invesco Municipal Opportunity Trust     9,855,253  
  388,908     Invesco Municipal Trust     5,211,367  
  485,080     Invesco Trust for Investment Grade Municipals     6,640,745  
  1,067,135     Nuveen AMT-Free Quality Municipal Income Fund     16,209,781  
  1,039,754     Nuveen Quality Municipal Income Fund     16,240,958  
              71,658,569  
        PREFERRED STOCK ― 0.8%        
  32,394     Cohen & Steers Limited Duration Preferred and Income Fund, Inc.     883,708  
  39,038     First Trust Intermediate Duration Preferred & Income Fund     976,731  
  362,890     Nuveen Preferred Income Opportunities Fund     3,592,611  
  187,404     Nuveen Preferred Securities Income Fund     1,836,559  
              7,289,609  
        TOTAL CLOSED-END FUNDS        
        (Cost $112,747,757)     121,242,171  
                 
        EXCHANGE TRADED FUNDS ― 9.2%        
  1,097,124     Invesco CEF Income Composite ETF     26,276,120  
  798,842     iShares 0-5 Year High Yield Corporate Bond ETF     36,507,079  
  171,266     iShares Short Maturity Bond ETF     8,587,277  
  290,000     VanEck CEF Muni Income ETF     8,517,300  
        TOTAL EXCHANGE TRADED FUNDS        
        (Cost $76,303,264)     79,887,776  

 

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

 

4 

 

Bramshill Income Performance Fund

Schedule of Investments (Unaudited)

September 30, 2021

 

 

Number of
Shares/Units
      Value
        PREFERRED STOCKS ― 28.4%        
        BANKS ― 6.3%        
  3,797     Bank of New York Mellon Corp. Depositary Shares
4.700% (effective 9/20/2025, 5 Year TNCMR + 4.358%) (1), 9/20/2025 (5)
  $ 4,176,700  
  11,620     Citizens Financial Group, Inc. Depositary Shares
5.650% (effective 10/6/2025, 5 Year TNCMR + 5.313%) (1), 10/6/2025 (5)
    13,087,606  
  6,217     Fifth Third Bancorp Depositary Shares
4.500% (effective 9/30/2025, 5 Year TNCMR + 4.215%) (1), 9/30/2025 (5)
    6,770,313  
  12,932     Regions Financial Corp. Depositary Shares
5.750% (effective 9/15/2025, 5 Year TNCMR + 5.430%) (1), 6/15/2025 (5)
    14,455,390  
  14,376     Truist Financial Corp. Depositary Shares
5.100% (effective 9/1/2030, 10 Year TNCMR + 4.349%) (1), 3/1/2030 (5)
    16,561,152  
              55,051,161  
        DIVERSIFIED BANKING INSTITUTIONAL ― 2.7%        
  117,587     Bank of America Corp., Depositary Shares 6.000%, 5/16/2023 (5)     3,172,497  
        Citigroup, Inc. Depositary Shares        
  6,180     4.700% (effective 1/30/2025, SOFR + 3.234%) (1), 1/30/2025 (5)     6,330,637  
  5,844     4.000% (effective 12/10/2025, 5 Year TNCMR + 3.597%) (1), 12/10/2025 (5)     6,070,163  
  29,076     GMAC Capital Trust I
8.125% (3 month U.S. LIBOR + 5.785%) (4), 2/15/2040
    733,878  
        Wells Fargo & Co., Depositary Shares        
  53,102     4.750%, 3/15/2025 (5)     1,390,742  
  5,348     3.900% (effective 3/15/2026, 5 Year TNCMR + 3.453%) (1), 3/15/2026 (5)     5,518,468  
              23,216,385  
        FINANCE AND INSURANCE ― 4.0%        
  18,949     Charles Schwab Corp. (The) Depositary Shares
5.375% (effective 6/1/2025, 5 Year TNCMR + 4.971%) (1), 6/1/2025 (5)
    21,104,449  
  59,657     Hartford Financial Services Group, Inc. (The)
7.875% (effective 4/15/2022, 3 month U.S. LIBOR + 5.596%) (1), 4/15/2042
    1,548,099  
  95,396     JPMorgan Chase & Co., Depositary Shares
4.625%, 6/1/2026 (5)
    2,518,454  
  16     3.650% (effective 6/1/2026, 5 Year TNCMR + 2.850%) (1), 6/1/2026 (5)     16,040  
  203,923     Reinsurance Group of America, Inc.
6.200% (effective 9/15/2022, 3 month U.S. LIBOR + 4.370%) (1), 9/15/2042
    5,352,979  
  155,130     Virtus AllianzGI Convertible & Income Fund
5.625%, 9/20/2023 (5)
    4,117,150  
              34,657,171  
        INFORMATION ― 0.4%        
        AT&T, Inc.        
  86,340     5.350%, 11/1/2066     2,262,971  
  50,167     5.625%, 8/1/2067     1,353,506  
              3,616,477  
        INVESTMENT COMPANIES ― 2.5%        
        Oaktree Capital Group LLC        
  190,236     6.625%, 6/15/2023 (5)     5,086,911  
  470,765     6.550%, 9/15/2023 (5)     12,640,040  
        Stifel Financial Corp.        
  132,889     5.200%, 10/15/2047     3,614,581  
              21,341,532  

 

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

 

5 

 

Bramshill Income Performance Fund
Schedule of Investments (Unaudited)
September 30, 2021

 

Number of
Shares/Units
      Value
        PIPELINES ― 2.7%        
        Enbridge, Inc.        
  81,837     4.000% (effective 6/1/2022, 5 Year TNCMR + 3.050%) (1), 6/1/2022 (5)   $ 1,674,794  
  72,064     4.000% (effective 9/1/2022, 5 Year TNCMR + 3.150%) (1), 9/1/2022 (5)     1,513,344  
  39,799     4.000% (effective 6/1/2023, 5 Year TNCMR + 3.140%) (1), 6/1/2023 (5)     886,523  
  103,688     4.400% (effective 3/1/2024, 5 Year TNCMR + 2.820%) (1), 3/1/2024 (5)     2,256,769  
  16,709     MPLX LP Depositary Shares
6.875% (effective 2/15/2023, 3 month U.S. LIBOR + 4.652%) (1), 2/15/2023 (5)
    17,043,180  
              23,374,610  
        REAL ESTATE INVESTMENT TRUST ― 3.1%        
  566,561     AGNC Investment Corp.
6.125% (effective 4/15/2025, 3 month U.S. LIBOR + 4.697%) (1), 4/15/2025 (5)
    14,300,000  
  462,614     Annaly Capital Management, Inc.
6.750% (effective 6/30/2024, 3 month U.S. LIBOR + 4.989%) (1), 6/30/2024 (5)
    12,324,037  
              26,624,037  
        UTILITIES ― 6.7%        
  313,793     Brookfield Renewable Partners LP
5.250%, 3/31/2025 (5)
    8,284,135  
  234,568     Duke Energy Corp.
5.750%, 6/15/2024 (5)
    6,497,534  
  141,202     Entergy Louisiana LLC
4.875%, 9/1/2066
    3,565,350  
  224,858     National Rural Utilities Cooperative Finance Corp.
5.500%, 5/15/2064
    6,163,358  
  30,814     Sempra Energy Depositary Shares
4.875% (effective 10/15/2025, 5 Year TNCMR + 4.550%) (1), 10/15/2025 (5)
    33,510,225  
              58,020,602  
        TOTAL PREFERRED STOCKS        
        (Cost $230,610,034)     245,901,975  
                 
        TOTAL INVESTMENTS ― 96.9%        
        (Cost $806,619,928)     839,760,646  
        Other Assets in Excess of Liabilities ― 3.1%     26,780,704  
        TOTAL NET ASSETS ― 100.0%   $ 866,541,350  

 

Floating Rate definitions:

LIBOR - London Inter-Bank Offered Rate

SOFR - U.S. Secured Overnight Financing Rate

TNCMR - Treasury Note Constant Maturity Rate

 

Percentages are stated as a percent of net assets.

 

(1) Fixed to floating rate. Effective date of change and formula disclosed. Rate disclosed is as of September 30, 2021.

(2) Perpetual maturity security. Date presented is the next call date.

(3) Security was purchased pursuant to Rule 144A under the Securities Act of 1933 and maybe sold in transactions exempt from registration only to qualified institutional buyers on a public offering registered under the Securities Act of 1933. The security has been deemed liquid by the advisor. At September 30, 2021, the value of these securities totaled $18,507,071 or 2.1% of net assets.

(4) Variable Rate security. Rates disclosed as of September 30, 2021.

(5) Callable at any dividend payment on or after date disclosed.

 

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

 

6 

 

 

Bramshill Income Performance Fund

Statement of Assets and Liabilities (Unaudited)

September 30, 2021

 

 

Assets:    
Investments in securities at value (cost $806,619,928)   $ 839,760,646  
Cash     24,512,389  
Deposits with broker for derivative instruments     1,306,225  
Receivables:        
Fund shares sold     4,788,534  
Dividends and interest     4,812,669  
Prepaid expenses     33,232  
Total assets     875,213,695  
         
Liabilities:        
Due to broker for securities sold short     1,603,014  
Payables:        
Investment securities purchased     5,449,189  
Fund shares redeemed     619,378  
Distributions to shareholders     239,629  
Due to Investment Adviser     601,270  
Due to trustees     207  
Accrued other expenses and other liabilities     159,658  
Total liabilities     8,672,345  
         
Net Assets   $ 866,541,350  
         
Components of Net Assets:        
Paid-in capital   $ 843,344,019  
Total accumulated earnings     23,197,331  
Net Assets   $ 866,541,350  
         
Institutional Class:        
Net Assets   $ 866,541,350  
Shares Outstanding (unlimited number of shares authorized, no par value)     82,644,985  
         
Net Asset Value, Redemption Price and Offering Price Per Share   $ 10.49  

 

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

 

7 

 

 

Bramshill Income Performance Fund

Statement of Operations (Unaudited)

For the Six Months Ended September 30, 2021

 

 

Investment Income:    
Dividend income (Net of foreign tax of $29,088)   $ 7,877,665  
Interest income     7,104,952  
Total investment income     14,982,617  
         
Expenses:        
Advisory fees (Note 3)     3,635,319  
Administration and fund accounting fees (Note 3)     279,573  
Service fees     220,763  
Transfer agent fees and expenses (Note 3)     61,940  
Registration fees     29,803  
Custody fees (Note 3)     29,130  
Shareholder reporting fees     15,241  
Legal fees     14,091  
Audit fees     10,304  
Trustees’ fees (Note 3)     7,951  
Compliance fees (Note 3)     7,741  
Miscellaneous expenses     3,980  
Investment Interest Expense     3,365  
Insurance expenses     3,171  
         
Total expenses     4,322,372  
Net investment income     10,660,245  
         
Realized and Unrealized Gain on Investments        
Net realized gain on:        
Investments     1,492,573  
Written options     1,205,503  
Swap contracts     1,961  
Net realized gain     2,700,037  
Net change in unrealized appreciation/(depreciation) on:        
Investments     8,053,437  
Net realized and unrealized gain on investments, written options, and swap contracts     10,753,474  
         
Net increase in Net Assets Resulting from Operations   $ 21,413,719  

 

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

 

8 

 

 

Bramshill Income Performance Fund

Statements of Changes in Net Assets

 

 

 

    For the Six Months Ended
September 30, 2021
(Unaudited)
  For the Year
Ended
March 31, 2021
Operations:        
Net investment income   $ 10,660,245     $ 19,814,732  
Net realized gain (loss) on investments, written options, and swap contracts     2,700,037       (3,954,405 )
Net change in unrealized appreciation/(depreciation) on investments     8,053,437       69,000,534  
Net increase in net assets resulting from operations     21,413,719       84,860,861  
                 
Distributions to shareholders:                
Net Investment Income     (10,358,694 )     (19,814,732 )
Return of Capital           (1,632,921 )
Total distributions to shareholders     (10,358,694 )     (21,447,653 )
                 
Capital Transactions:                
Proceeds from shares sold     245,692,069       328,667,226  
Reinvestment of distributions     8,963,674       18,807,934  
Cost of shares repurchased     (170,689,627 )     (148,580,948 )
Net increase in net assets from capital transactions     83,966,116       198,894,212  
Total Increase in Net Assets     95,021,141       262,307,420  
                 
Net Assets:                
Beginning of peiod     771,520,209       509,212,789  
End of period   $ 866,541,350     $ 771,520,209  
                 
Capital Share Transactions:                
Shares sold     23,390,658       32,148,979  
Shares reinvested     852,891       1,850,827  
Shares repurchased     (16,214,108 )     (14,748,109 )
Net increase in shares outstanding     8,029,441       19,251,697  

 

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

 

9 

 

 

Bramshill Income Performance Fund

Financial Highlights

Institutional Class

 

 

For a capital share outstanding throughout each period presented

 

   

For the

Six Months

Ended

September 30,

2021

(Unaudited)

 

 

For the

Year Ended

March 31,

2021

 

 

For the

Year Ended

March 31,

2020

 

 

For the

Year Ended

March 31,

2019

 

 

For the

Year Ended

March 31,

2018

 

 

For the Period

April 11,

2016*

through

March 31,

2017

 

Net Asset Value, Beginning of Period   $ 10.34     $ 9.20     $ 9.97     $ 9.75     $ 10.24     $ 10.00  
                                                 
INCOME FROM INVESTMENT OPERATIONS:                                                
Net investment income (1)     0.13       0.33       0.31       0.37       0.35       0.22  
Net realized and unrealized gain (loss) on investments     0.15       1.17       (0.76 )     0.23       (0.43 )     0.24  
Total Income (Loss) from Investment Operations     0.28       1.50       (0.45 )     0.60       (0.08 )     0.46  
                                                 
LESS DISTRIBUTIONS:                                                
Net investment income     (0.13 )     (0.34 )     (0.31 )     (0.38 )     (0.36 )     (0.17 )
Net realized gain on investments                             (0.05 )     (0.05 )
Return of capital           (0.02 )     (0.01 )                  
Total Distributions     (0.13 )     (0.36 )     (0.32 )     (0.38 )     (0.41 )     (0.22 )
                                                 
Net Asset Value, End of Period   $ 10.49     $ 10.34     $ 9.20     $ 9.97     $ 9.75     $ 10.24  
                                                 
Total Return     2.68 %(2)     16.40 %     (4.67 %)     6.24 %     (0.85 %) (4)     4.63 %(2)(4)
                                                 
SUPPLEMENTAL DATA AND RATIOS:                                                
Net assets, end of period (in thousands)   $ 866,541     $ 771,520     $ 509,213     $ 401,566     $ 191,495     $ 140,624  
Ratio of expenses to average net assets                                                
Before fees waived/recouped by the Adviser     1.01 %(3)     1.04 %     1.10 % (5)      1.10 %     1.12 %     1.26 %(3)
After fees waived/recouped by the Adviser     1.01 %(3)     1.04 %     1.13 % (5)      1.10 %     1.10 %     1.10 %(3)
Ratio of net investment income to average net assets                                                
Before fees waived/recouped by the Adviser     2.49 %(3)     3.27 %     3.14 % (6)      3.76 %     3.55 %     2.05 %(3)
After fees waived/recouped by the Adviser     2.49 %(3)     3.27 %     3.11 % (6)      3.76 %     3.57 %     2.20 %(3)
Portfolio turnover rate     20 %(2)     83 %     134 %     131 %     130 %     243 %(2)

 


* Inception date.

(1) Per share amounts have been calculated using average shares method.

(2) Not Annualized.

(3) Annualized.

(4) Includes adjustments in accordance with accounting principles generally accepted in the United States and, consequently, the net asset value for financial reporting purposes and the returns based upon those net asset values may differ from the net asset values and returns for shareholder transactions.

(5) The ratios of expenses to average net assets include interest expenses. For the year ended March 31, 2020, excluding interest expenses, the ratio of expenses to average net assets before fees waived/recouped by the Adviser was 1.05%. Excluding interest expenses, the ratio of expenses to average net assets after fees waived/recouped by the Adviser was 1.08%.

(6) The ratios of net investment income to average net assets include interest expenses. For the year ended March 31, 2020, excluding interest expenses, the ratio of net investment income to average net assets before fees waived/recouped by the Adviser was 3.19%. Excluding interest expenses, the ratio of net investment income to average net assets after fees waived/recouped by the Adviser was 3.16%.

 

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

 

10 

 

 

Bramshill Income Performance Fund

Notes to Financial Statements (Unaudited)

September 30, 2021

 

 

Note 1 – Organization

 

Bramshill Income Performance Fund (the “Fund”) is a diversified series of Trust for Advised Portfolios (the “Trust”). The Trust, a Delaware Statutory Trust, is registered under the Investment Company Act of 1940, as amended (the “1940 Act”) as an open-end investment management company. Bramshill Investments, LLC (the “Adviser”) serves as the investment manager to the Fund. The inception date of the Fund was April 11, 2016. The investment objective of the Fund is to maximize total return.

 

Note 2 – Significant Accounting Policies

 

The following is a summary of significant accounting policies consistently followed by the Fund in the preparation of its financial statements. These policies are in conformity with accounting principles generally accepted in the United States of America (“GAAP”) for investment companies. The Fund is considered an investment company under GAAP and follows the accounting and reporting guidance applicable to investment companies in the Financial Accounting Standards Board Accounting Standards Codification Topic 946. The presentation of financial statements in conformity with 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 and the reported amounts of income and expenses during the period reported. Actual results may differ from those estimates.

 

(a) Securities Valuation – Investments in securities traded on a national securities exchange are valued at the last reported sales price on the exchange on which the security is principally traded. Securities traded on the NASDAQ exchanges are valued at the NASDAQ Official Closing Price (“NOCP”). Exchange-traded securities for which no sale was reported and NASDAQ securities for which there is no NOCP are valued at the mean of the most recent quoted bid and ask prices. Unlisted securities held by the Fund are valued at the last sale price in the over-the-counter (“OTC”) market. If there is no trading on a particular day, the mean between the last quoted bid and ask price is used.

 

Fixed income securities are valued using prices provided by an independent pricing service approved by the Board of Trustees. Pricing services may use various valuation methodologies, including matrix pricing and other analytical models as well as market transactions and dealer quotations.

 

Futures contracts are valued at the settlement price on the exchange on which they are principally traded.

 

Exchange traded options are valued at the composite mean price, which calculates the mean of the highest bid price and lowest ask price across the exchanges where the option is principally traded. On the last trading day prior to expiration, expiring options may be priced at intrinsic value. For options where market quotations are not readily available, fair value shall be determined by the Adviser with oversight by the Trust’s Valuation Committee.

 

11 

 

 

Bramshill Income Performance Fund

Notes to Financial Statements (Unaudited) (Continued)

September 30, 2021

 

 

Various inputs are used in determining the value of the Fund’s investments. These inputs are summarized into three broad levels and described below:

 

Level 1 - quoted prices in active markets for identical securities. An active market for the security is a market in which transactions occur with sufficient frequency and volume to provide pricing information on an ongoing basis. A quoted price in an active market provides the most reliable evidence of fair value.

 

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 - significant unobservable inputs, including the Fund’s own assumptions in determining the fair value of investments.

 

The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities. The following is a summary of the inputs used to fair value the Fund’s investments in each category investment type as of September 30, 2021:

 

Description   Level 1   Level 2   Level 3   Total
Assets                
Corporate Bonds   $     $ 156,080,534     $     $ 156,080,534  
U.S. Government Notes           236,648,190             236,648,190  
Closed-End Funds     121,242,171                   121,242,171  
Exchange Traded Funds     79,887,776                   79,887,776  
Preferred Stocks     96,439,566       149,462,409             245,901,975  
Total   $ 297,569,513     $ 542,191,133     $     $ 839,760,646  

 

See the Schedule of Investments for further detail of investment classifications.

 

(b) Federal Income Taxes – The Fund has elected to be taxed as a Regulated Investment Company (“RIC”) under the U.S. Internal Revenue Code of 1986, as amended, and intends to maintain this qualification and to distribute substantially all net taxable income to its shareholders. Therefore, no provision is made for federal income taxes. Due to the timing of dividend distributions and the differences in accounting for income and realized gains and losses for financial statement and federal income tax purpose, the fiscal year in which amounts are distributed may differ from the year in which the income and realized gains and losses is recorded by the Fund.

 

Management of the Fund is required to analyze all open tax years, as defined by IRS statute of limitations for all major jurisdictions, including federal tax authorities and certain state authorities. As of and during the period ended September 30, 2021, the Fund did not have a liability for any unrecognized tax benefits. Generally, tax authorities can examine tax returns filed for the preceding three years. The Fund is not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly change in the next twelve months.

 

12 
1

 

 

Bramshill Income Performance Fund

Notes to Financial Statements (Unaudited) (Continued)

September 30, 2021

 

 

(c) Return of capital estimates - Distributions received from the Fund’s investments in Real Estate Investment Trusts (“REITs”) are generally comprised of net investment income, capital gains, and return of capital. Certain of the Fund’s investments in Closed-End Funds (“CEFs”) also make distributions comprised of net investment income and return of capital. It is the policy of the Fund to estimate the character of distributions received from underlying REITs based on historical data provided by the REITs and distribution notices provided by CEFs. After each calendar year end, REITs and CEFs report the actual tax character of these distributions. Differences between the estimated and actual amounts reported are reflected in the Funds’ records in the year in which they are reported by adjusting related investment cost basis, capital gains and income, as necessary.

 

(d) Distributions to Shareholders – The Fund records distributions to shareholders, which are determined in accordance with income tax regulations, on the ex-dividend date. Distributions of net investment income, if any, are distributed monthly. The Fund intends to distribute all its net investment income including any cash received from its investments in CEFs and REITs, even if a portion may represent a return of capital. Net realized gains from investment transactions, if any, will be distributed to shareholders annually. The Fund may periodically make reclassifications among certain income and capital gains distributions determined in accordance with federal tax regulations, which may differ from GAAP. These reclassifications are due to differences in the recognition of income, expense and gain (loss) items for financial statement and tax purposes.

 

(e) Restricted securities – Restricted securities are securities that are not registered for sale under the Securities Act of 1933 or applicable foreign law and that may be re-sold only in transactions exempt from applicable registration. Restricted securities include Rule 144A securities which may be sold normally to qualified institutional buyers. As of September 30, 2021, the Fund had restricted securities, all of which were Rule 144A securities, with a market value of $18,507,071 or 2.1% of the Fund’s net assets.

 

(f) Cash – Concentration in Uninsured Cash – For cash management purposes the Fund may concentrate cash with the Fund’s custodian. This typically results in cash balances exceeding the Federal Deposit Insurance Corporation (“FDIC”) insurance limits. As of September 30, 2021, the Fund held $24,262,389 as cash reserves at U.S. Bank, N.A. (“U.S. Bank”) that exceeded the FDIC insurance limit.

 

(g) Restricted Cash – Deposits with Broker – At September 30, 2021, the Fund had $1,306,225 deposited at Wells Fargo Securities, LLC to utilize as collateral for futures and swaps trading. The Fund had no open futures and securities sold short positions as of September 30, 2021.

 

(h) Derivatives – The Fund invests in certain derivative instruments, as detailed below.

 

Futures contracts – The Fund invests in futures to adjust its sensitivity to interest rate changes and to gain exposure to U.S. Treasury securities. While hedging strategies involving derivatives can reduce the risk of loss, they can also reduce the opportunity for gain or even result in losses by offsetting favorable price movements in other Fund investments.

 

13 

 

 

Bramshill Income Performance Fund

Notes to Financial Statements (Unaudited) (Continued)
September 30, 2021

 

 

Options Contracts – The Fund may write call and put options on securities, derivative instruments, or currencies. When the Fund writes a call or put option, an amount equal to the premium received is recorded as a liability and subsequently marked-to-market to reflect the current value of the option written. These liabilities are reflected as written options outstanding in the Statement of Assets and Liabilities. Premiums received from writing options which expire are treated as realized gains. Written options which are closed or exercised will result in a gain if the closing price of the underlying security is lower than the premium received. The Fund, as a writer of an option, has no control over whether the underlying security may be sold (call) or purchased (put) and, as a result, bears the market risk of an unfavorable change in the price of said underlying security. The risk exists that the Fund may not be able to enter into a closing transaction because of an illiquid market.

 

The Fund purchases call and put options. The Fund pays a premium which is included in the Statement of Assets and Liabilities as an investment and subsequently marked-to-market to reflect the current value of the option. Premiums paid for purchasing options which expire are treated as realized losses. The risk associated with purchasing put and call options is limited to the premium paid. Purchasing options will result in a gain if the closing price of the transaction is higher than the premium paid. The average monthly volume of options held by the Fund during the period ended September 30, 2021 is set forth below:

 

    Number of
Contracts
    Notional
Amount
 
Purchased options     1,449     $ 443,625  
Written options     (1,449 )   $ (155,359 )

 

Swap Contracts – The Fund enters into credit default swap agreements, credit default index swap agreements and similar agreements as a protection “seller” or as a “buyer” of credit protection. The credit default swap agreement or similar instruments may have as reference obligations one or more securities that are not held by the Fund. The protection “buyer” in a credit default swap agreement is generally obligated to pay the protection “seller” a periodic stream of payments over the term of the agreement, provided generally that no credit event on a reference obligation has occurred. In addition, at the inception of the agreement, the protection “buyer” may receive or be obligated to pay an additional up-front amount depending on the current market value of the contract. If a credit event occurs, an auction process is used to determine the “recovery value” of the contract. The seller then must pay the buyer the “par value” (full notional value) of the swap contract minus the “recovery value” as determined by the auction process. For credit default index swaps, the settlement payment for a constituent’s credit event is scaled down to the weighting in the index.

 

Changes in value of swaps are recorded as unrealized appreciation (depreciation). Unrealized gains are reported as an asset and unrealized losses are reported as a liability. The change in value of swaps, including accruals of interest to be paid or received is reported as unrealized gains or losses. Gains or losses are realized upon termination of the contracts. The risk of loss on a swap contract may exceed the amount recorded as an asset or liability on the Statement of Assets and Liabilities. The notional amount of a swap contract is the reference amount pursuant to which the counterparties make payments. Risks associated with swap contracts include changes in the returns of underlying instruments, failure of the counterparties to perform under a contract’s terms and the possible lack of liquidity with respect to the contracts.

 

14 

 

 

Bramshill Income Performance Fund  

Notes to Financial Statements (Unaudited) (Continued)
September 30, 2021

 

  

Derivative Investment Holdings Categorized by Risk Exposure – The following table sets forth the Fund’s realized gain (loss), as reflected in the Statement of Operations, by primary risk exposure and by type of derivative contract for the period ended September 30, 2021:

 

Amount of Realized Gain (Loss) on Derivatives 

Risk Exposure
Category
  Investments (1)     Written Options     Swaps  
Credit   $     $     $ 1,961  
Equity     (3,011,010 )     1,205,503        
Total   $ (3,011,010 )   $ 1,205,503     $ 1,961  
                         
(1) Includes purchased options.

 

(i) Other – The Fund records security transactions based on trade date. Realized gains and losses on sales of securities are reported on the basis of identified cost of securities delivered. Dividend income and expense are recognized on the ex-dividend date, and interest income and expense are recognized on an accrual basis. Discounts and premiums on securities purchased are amortized over the lives of the respective securities using the effective yield method. Withholding taxes on foreign dividends have been provided for in accordance with the Trust’s understanding of the applicable country’s tax rules and rates. Trust-level expenses are allocated across the series of the Trust.

 

Note 3 – Investment Management Agreement and Other Related Party Transactions

 

The Trust has an agreement with the Adviser to furnish investment advisory services to the Fund. Under the terms of this agreement, the Fund will pay the Adviser a monthly fee based on the Fund’s average daily net assets at annual rate of 0.85%. Pursuant to a contractual fee waiver and reimbursement agreement, the Adviser will waive/reimburse the Fund for expenses in excess of 1.10% of average daily net assets for Institutional Class shares, excluding taxes, interest charges, litigation and other extraordinary expenses, acquired fund fees and expenses, interest and expense relating to short sales, borrowing costs, and brokers’ commissions, and other charges relating to the purchase and sale of the Fund’s portfolio securities. The Fund incurred $3,635,319 for Advisory fees during the period ended September 30, 2021.

 

The Adviser is permitted to recapture amounts waived and/or reimbursed to a Fund within three years if the Fund’s total annual operating expenses have fallen to a level below the expense limitation (“expense cap”) in effect at the time the fees were earned or the expenses incurred. In no case will the Adviser recapture any amount that would result, on any particular business day of the Fund, in the Fund’s total annual operating expenses exceeding the expense cap or any other lower limit then in effect. The Fund currently has no waiver balance subject to recapture.

 

15 

 

 

Bramshill Income Performance Fund  

Notes to Financial Statements (Unaudited) (Continued)
September 30, 2021

 

 

U.S. Bancorp Fund Services, LLC, doing business as U.S. Bank Global Fund Services (“Fund Services”), serves as the Fund’s administrator and fund accountant and transfer agent. The officers of the Trust are employees of Fund Services. U.S. Bank serves as the Fund’s custodian and provides compliance services to the Funds. Quasar Distributors, LLC (“Quasar” or the “Distributor”) acts as the Fund’s distributor and principal underwriter. For the period ended September 30, 2021, the Fund incurred the following expenses for administration and fund accounting, compliance, custody and transfer agency fees:

 

Administration and fund accounting   $ 279,573  
Compliance Service     7,741  
Custody     29,130  
Transfer Agency     61,940  

 

At September 30, 2021, the Fund had payables due to Fund Services for administration and fund accounting, compliance, custody and transfer agency fees to U.S. Bank in the following amounts:

 

Administration and fund accounting   $ 92,538  
Compliance Services     2,592  
Custody     8,623  
Transfer Agency     20,181  

 

The above payable amounts are included in Accrued other expenses and other liabilities in the Statement of Assets and Liabilities.

 

The Independent Trustees were paid $7,950 for their services and reimbursement of travel expenses during the period ended September 30, 2021. The Fund pays no compensation to the Interested Trustee or officers of the Trust.

 

Note 4 – Control Ownership

 

The beneficial ownership, either directly or indirectly, of more than 25% of the voting securities of a fund creates presumption of control of the fund under 2(a)(9) of the 1940 Act. As of September 30, 2021, UBS Financial Services, Inc. held approximately 29%, in aggregate for the benefit of others, of the outstanding shares of the Fund.

 

Note 5 – Investment Transactions

 

Purchases and sales of investment securities (excluding short-term securities and U.S. government obligations) for the period ended September 30, 2021, were as follows:

 

Purchases     $ 250,107,731  
Sales     $ 132,804,767  

 

16 

 

 

Bramshill Income Performance Fund  

Notes to Financial Statements (Unaudited) (Continued)
September 30, 2021

 

 

Note 6 – Federal Income Tax Information

 

At March 31, 2021, the components of accumulated earnings (losses) for federal income tax purposes were as follows:

 

Tax Cost of Investments   $ 661,502,879  
Unrealized Appreciation     28,655,643  
Unrealized Depreciation     (7,021,044 )
Net Unrealized Appreciation on Investments     21,634,599  
Other Accumulated Loss     (9,492,293 )
Total Accumulated Gain   $ 12,142,306  

 

The difference between book basis and tax basis unrealized appreciation/depreciation is attributable in part to the tax deferral of losses on wash sales, and basis adjustments on investments in limited partnerships.

 

The tax character of distributions paid during the six months ended September 30, 2021 and year ended March 31, 2021 were as follows:

 

    Period Ended     Year Ended  
Distributions Paid From:   September 30, 2021     March 31, 2021  
Ordinary Income   $ 10,358,694     $ 19,814,732  
Return of Capital           1,632,921  
Total Distributions Paid   $ 10,358,694     $ 21,447,653  

 

The Fund is required, in order to meet certain excise tax requirements, to measure and distribute annually, net capital gains realized during the twelve month period ending October 31. In connection with this requirement, the Fund is permitted, for tax purposes, to defer into its next fiscal year any net capital losses incurred from November 1 through the end of the fiscal year. Late year losses incurred after December 31 within the fiscal year are deemed to arise on the first business day of the following fiscal year for tax purposes. As of March 31, 2021, the Fund had no late-year or post-October losses.

 

At March 31, 2021, the Fund had capital loss carryforwards, which reduce the Fund’s taxable income arising from future net realized gains on investments, if any, to the extent permitted by the Internal Revenue Code, and thus will reduce the amount of distributions to shareholders which would otherwise be necessary to relieve the Fund of any liability for federal tax. Pursuant to the Internal Revenue Code, the character of such capital loss carryforwards is as follows:

 

Not Subject to Expiration

Short-Term Long-Term Total
$ 1,902,386 $ 7,589,907 $ 9,492,293

 

17 

 

 

Bramshill Income Performance Fund  

Notes to Financial Statements (Unaudited) (Continued)

September 30, 2021

 

 

Note 7 – Commitments and Contingencies

 

In the normal course of business, the Fund enters into contracts that provide general indemnifications by the Fund to the counterparty to the contract. The Fund’s maximum exposure under these arrangements is dependent on future claims that may be made against the Fund and, therefore, cannot be estimated; however, based on experience, the risk of loss from such claims is considered remote.

 

Note 8 – Line of Credit

 

The Fund has access to a $25 million unsecured line of credit through an agreement with U.S. Bank. The Fund may temporarily draw on the line of credit to satisfy redemption requests or to settle investment transactions. Interest is charged to the Fund based on its borrowings at a rate per annum equal to the Prime Rate, to be paid monthly. During the period ended September 30, 2021, the Fund did not draw on this line of credit.

 

Note 9 – Securities Lending

 

The Fund may lend up to 33 1/3% of the securities in its portfolios to brokers, dealers, and other financial organizations that meet capital and other credit requirements under terms of participation in a securities lending program administered by U.S. Bank N.A. The securities lending agreement requires that loans are collateralized at all times in an amount equal to at least 102% of the market value of the securities loaned. The Fund has the right under the terms of the lending agreement to recall the securities from the borrower on demand.

 

The borrower of any securities will pay the Fund any accrued income while the securities are on loan. The cash collateral received is invested in a money market fund which is redeemable on demand.

 

There are certain risks associated with securities lending, including the risk that the borrower may fail to return the securities on a timely basis or even the loss of rights in the collateral deposited by the borrower, if the borrower should fail financially. As a result the Fund may lose money.

 

The Fund manages credit exposure arising from these lending transactions by, in appropriate circumstances, entering into master netting agreements and collateral agreements with third party borrowers that provide the Fund, in the event of default (such as bankruptcy or a borrower’s failure to pay or perform), the right to net a third party borrower’s rights and obligations under such agreement and liquidate and set off collateral against the net amount owed by the counterparty.

 

The Fund did not participate the securities lending program during the six months ended September 30, 2021.

 

18 

 

 

Bramshill Income Performance Fund  

Notes to Financial Statements (Unaudited) (Continued)
September 30, 2021

 

 

Note 10 – Subsequent Events

 

In preparing these financial statements, the Fund has evaluated events and transactions for potential recognition or disclosure through the date the financial statements were available to be issued. Subsequent to the year end, the Fund has made the following distributions per share:

 

Record Date Payable Date Distributions
10/28/2021 10/29/2021 $ 0.02010080

 

Note 11 – COVID-19 Risk

 

The global outbreak of COVID-19 (commonly referred to as “coronavirus”) has disrupted economic markets and the prolonged economic impact is uncertain. The ultimate economic fallout from the pandemic, and the long-term impact on economies, markets, industries and individual issuers, are not known. The operational and financial performance of the issuers of securities in which the Fund invest depends on future developments, including the duration and spread of the outbreak, and such uncertainty may in turn adversely affect the value and liquidity of the Fund’s investments, impair the Fund’s ability to satisfy redemption requests, and negatively impact the Fund’s performance.

 

Note 12 – New Pronouncements

 

ASU 2020-04. In March 2020, FASB issued ASU 2020-04, Reference Rate Reform: Facilitation of the Effects of Reference Rate Reform on Financial Reporting. The main objective of the new guidance is to provide relief to companies that will be impacted by the expected change in benchmark interest rates at the end of 2021, when participating banks will no longer be required to submit London Interbank Offered Rate (“LIBOR”) quotes by the UK Financial Conduct Authority. The new guidance allows companies to, provided the only change to existing contracts are a change to an approved benchmark interest rate, account for modifications as a continuance of the existing contract without additional analysis. In addition, derivative contracts that qualified for hedge accounting prior to modification, will be allowed to continue to receive such treatment, even if critical terms change due to a change in the benchmark interest rate. For new and existing contracts, the Fund may elect to apply the amendments as of March 12, 2020 through December 31, 2022. Management is currently assessing the impact of the ASU’s adoption to the Fund’s financial statements and various filings.

 

19 

 

 

Bramshill Income Performance Fund  

Additional Information (Unaudited)
September 30, 2021

 

 

Quarterly Portfolio Schedule

 

The Fund files its complete schedule of portfolio holdings for the first and third quarters of each fiscal year with the SEC on Part F of Form N-PORT. The Fund’s Form N-PORT is available without charge by visiting the SEC’s Web site at www.sec.gov and may be reviewed and copied at the SEC’s Public Reference Room in Washington D.C. You may obtain information on the operation of the Public Reference Room by calling (800) SEC-0330.

 

Proxy Voting

 

You may obtain a description of the Fund’s proxy voting policy and voting records, without charge, upon request by contacting the Fund directly at 1-877-BRAMS18 or on the EDGAR Database on the SEC’s website at www.sec.gov. The Fund files its proxy voting records annually as of June 30, with the SEC on Form N-PX. The Fund’s Form N-PX is available without charge by visiting the SEC’s website at www.sec.gov and may be reviewed and copied at the SEC’s Public Reference Room in Washington D.C. You may obtain information on the operation of the Public Reference Room by calling 1-800-SEC-0330.

 

Statement Regarding Liquidity Risk Management Program

 

The Fund has adopted a liquidity risk management program. The Fund’s Board has designated a Liquidity Risk Committee (“Committee”) of the Adviser to serve as the administrator of the program. The Committee conducts the day-to-day operation of the program pursuant to policies and procedures administered by the Committee.

 

Under the program, the Committee manages the Fund’s liquidity risk, which is the risk that the Fund could not meet shareholder redemption requests without significant dilution of remaining shareholders’ interests in the Fund. This risk is managed by monitoring the degree of liquidity of the Fund’s investments, limiting the amount of the Fund’s illiquid investments, and utilizing various risk management tools and facilities available to each Fund for meeting shareholder redemptions, among other means.

 

The Fund’s Board reviewed a report prepared by the Committee regarding the operation and effectiveness of the program for the period January 1, 2020 through December 31, 2020. No liquidity events impacting the Fund were noted in the report. In addition, the Committee provided its assessment that the program had been effective in managing each Fund’s liquidity risk.

 

Approval of Investment Advisory Agreement

 

At a meeting held on August 12 and 13, 2021, the Board of Trustees (the “Board”) of Trust for Advised Portfolios (the “Trust”), including all Trustees who are not “interested persons” of the Trust (“Independent Trustees”), as that term is defined in the Investment Company Act of 1940, considered and approved the continuance of the investment advisory agreement (“Advisory Agreement”) with Bramshill Investments, LLC (the “Adviser”), for the Bramshill Income Performance Fund (the “Fund”).

 

Ahead of the August meeting, the Board received and reviewed substantial information regarding the Fund, the Adviser and the services provided by the Adviser to the Fund under the Advisory Agreement.

 

20 

 

 

Bramshill Income Performance Fund  

Additional Information (Unaudited) (Continued)
September 30, 2021

 

 

This information formed the primary (but not exclusive) basis for the Board’s determinations. The information prepared specifically for the annual review of the Advisory Agreement supplemented the information provided to the Board and its committees throughout the year. The Board and its committees met regularly during the year and the information provided and topics discussed at such meetings were relevant to the review of the Advisory Agreement. Some of these reports and other data included, among other things, materials that outlined the investment performance of the Fund; compliance, regulatory, and risk management matters; the trading practices of the Adviser; valuation of investments; fund expenses; and overall market and regulatory developments. The Trustees considered the review of the Advisory Agreement to be an ongoing process and employed the accumulated information, knowledge, and experience they had gained during their tenure on the Board governing the Fund and working with the Adviser in their review of the Advisory Agreement. The Independent Trustees were advised by independent legal counsel during the annual review process as well as throughout the year, including meeting in executive sessions with such counsel without representatives from the Adviser present. In connection with their annual review, the Independent Trustees also received a memorandum from independent legal counsel outlining their fiduciary duties and legal standards in reviewing the Advisory Agreement.

 

In considering the continuance of the Advisory Agreement, the Board considered the following factors and made the following determinations. In its deliberations, the Board did not identify any single factor or piece of information as all important, controlling, or determinative of its decision, and each Trustee may have attributed different weights to the various factors and information.

 


In considering the nature, extent and quality of the services provided by the Adviser, the Trustees considered the Adviser’s specific responsibilities in all aspects of the day-to-day management of the Fund, as well as the qualifications, experience and responsibilities of the portfolio managers and other key personnel who are involved in the day-to-day activities of the Fund. The Board also considered the Adviser’s resources and compliance structure, including information regarding its compliance program, chief compliance officer and compliance record and its disaster recovery/business continuity plan, including how the Adviser has operated through the COVID-19 pandemic. The Board also considered the existing relationship between the Adviser and the Trust, as well as the Board’s knowledge of the Adviser’s operations, and noted that during the course of the year it met with the Adviser to discuss fund performance and investment outlook, as well as various marketing and compliance topics, including the Adviser’s risk management process. The Board concluded that the Adviser had sufficient quality and depth of personnel, resources, investment methods and compliance policies and procedures essential to performing its duties under the Advisory Agreement and that, in the Board’s view, the nature, overall quality, and extent of the management services provided were and would continue to be satisfactory and reliable.

 


In assessing the quality of the portfolio management delivered by the Adviser, the Board reviewed the performance of the Fund on both an absolute basis and in comparison to its peer group, relevant benchmark index, and a comparable composite of accounts managed by the Adviser. The Board considered that the Fund had outperformed relative to its peer median and average for the year-to-date, one-, three-, and five-year periods as of June 30, 2021. The Board also noted that the Fund had underperformed relative to the Adviser’s composite for the one-,three-, and five-year periods, but had outperformed relative to its benchmark for the same periods. The Board noted that the Fund had only slightly more than five years of performance results.

 

21 

 

 

Bramshill Income Performance Fund  

Additional Information (Unaudited) (Continued)
September 30, 2021

 

  


The Trustees also reviewed the cost of the Adviser’s services, and the structure and level of advisory fee payable by the Fund, including a comparison of the fee to fees payable by a peer group of funds. The Board noted that the Adviser had contractually agreed to maintain an annual expense cap for each of the Fund’s classes and that the Fund was currently operating below the expense caps. The Board noted that, although the Fund’s advisory fee and net expense ratio were higher than the peer group median and average, both were within the peer group range. After reviewing the materials that were provided, the Trustees noted that the fee to be received by the Adviser was within the range of advisory fees charged to comparable funds and concluded that such fee was fair and reasonable.

 


The Trustees considered whether, based on the asset size of the Fund, economies of scale had been achieved. The Board also considered the Adviser’s commitment to maintain the caps on Fund expenses and that the Fund was currently operating below the expense caps. The Board further considered the Adviser’s plans to enhance the firm’s operations and capabilities through reinvestment in its business. The Trustees concluded that they will have the opportunity to periodically reexamine whether economies of scale have been achieved as Fund assets grow.

 


The Trustees considered the profitability of the Adviser from managing the Fund. In assessing the Adviser’s profitability, the Trustees reviewed the financial information that was provided in the August meeting materials and took into account both direct and indirect benefits to the Adviser from managing the Fund. The Trustees concluded that the Adviser’s profits from managing the Fund were not excessive and, after a review of the relevant financial information, that the Adviser appeared to have adequate capitalization and/or would maintain adequate profit levels to support the Fund.

 

22 

 

PRIVACY NOTICE

 

The Fund collects non-public information about you from the following sources:

 


Information we receive about you on applications or other forms;

 


Information you give us orally; and/or

 


Information about your transactions with us or others.

 

We do not disclose any non-public personal information about our customers or former customers without the customer’s authorization, except as permitted by law or in response to inquiries from governmental authorities. We may share information with affiliated and unaffiliated third parties with whom we have contracts for servicing the Fund. We will provide unaffiliated third parties with only the information necessary to carry out their assigned responsibilities. We maintain physical, electronic and procedural safeguards to guard your non-public personal information and require third parties to treat your personal information with the same high degree of confidentiality.

 

In the event that you hold shares of the Fund through a financial intermediary, including, but not limited to, a broker-dealer, bank, or trust company, the privacy policy of your financial intermediary would govern how your non-public personal information would be shared by those entities with unaffiliated third parties.

 

23 

 

Investment Adviser
Bramshill Investments, LLC
4850 Tamiami Trail North, Suite 301
Naples, Florida 34103

 

Distributor

Quasar Distributors, LLC
111 East Kilbourn Ave. Suite 2200
Milwaukee, Wisconsin 53202

 

Custodian

U.S. Bank National Association
Custody Operations
1555 North River Center Drive, Suite 302
Milwaukee, Wisconsin 53212

 

Transfer Agent, Fund Accountant and Fund Administrator

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

 

Independent Registered Public Accounting Firm

BBD, LLP
1835 Market Street, 3rd Floor
Philadelphia, Pennsylvania 19103

 

Legal Counsel

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

 

This report has been prepared for shareholders and may be distributed to others only if preceded or accompanied by a current prospectus.



(b)
Not applicable

 

Item 2. Code of Ethics.

Not applicable for semi-annual reports

Item 3. Audit Committee Financial Expert.

Not applicable for semi-annual reports

Item 4. Principal Accountant Fees and Services.

Not applicable for semi-annual reports

Item 5. Audit Committee of Listed Registrants.

Not applicable to registrants who are not listed issuers (as defined in Rule 10A-3 under the Securities Exchange Act of 1934).

Item 6. Investments.

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

(b)
Not Applicable

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 and Treasurer 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 quarter of 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 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. Not applicable for semi-annual reports.


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


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.


Trust for Advised Portfolios                                        


By /s/ Christopher E. Kashmerick                                 
                   Christopher E. Kashmerick, President


Date                 12/07/2021                                                              


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 /s/ Christopher E. Kashmerick                                 
                   Christopher E. Kashmerick, President


Date         12/07/2021                                                                       


By /s/ Russell B. Simon                                                
                   Russell B. Simon, Treasurer


Date         12/07/2021                                                                       



EX.99.CERT

CERTIFICATIONS

I, Christopher E. Kashmerick, certify that:

1.
I have reviewed this report on Form N-CSR of Trust for Advised Portfolios;

1.
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;

2.
Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

3.
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 second fiscal quarter 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; and

4.
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:      12/07/2021                                    
 
/s/ Christopher E. Kashmerick              
Christopher E. Kashmerick, President


EX.99.CERT
CERTIFICATIONS

I, Russell B. Simon, certify that:

1.
I have reviewed this report on Form N-CSR of Trust for Advised Portfolios;

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 financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

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 second fiscal quarter 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; 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:     12/07/2021                                        
/s/ Russell B. Simon                               
Russell B. Simon, Treasurer



EX.99.906CERT

Certification Pursuant to Section 906 of the Sarbanes-Oxley Act

Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, each of the undersigned officers of the Trust for Advised Portfolios, does hereby certify, to such officer’s knowledge, that the report on Form N-CSR of the Trust for Advised Portfolios for the period ended September 30, 2021 fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as applicable, and that the information contained in the Form N-CSR fairly presents, in all material respects, the financial condition and results of operations of the Trust for Advised Portfolios for the stated period.


/s/ Christopher E. Kashmerick              
Christopher E. Kashmerick
President, Trust for Advised Portfolios
/s/ Russell B. Simon                               
Russell B. Simon
Treasurer, Trust for Advised Portfolios
 
 
Dated:        12/07/2021                                       
 
 
Dated:              12/07/2021                                 


This statement accompanies this report on Form N-CSR pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 and shall not be deemed as filed by Trust for Advised Portfolios for purposes of Section 18 of the Securities Exchange Act of 1934.




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