Form N-Q 360 Funds For: Feb 28

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM N-Q

 

QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANIES

 

Investment Company Act file number: 811-21726

 

360 Funds

(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

 

With Copies To:

John H. Lively

The Law Offices of John H. Lively & Associates, Inc.

A member firm of The 1940 Act Law Group^TM

11300 Tomahawk Creek Parkway, Suite 310

Leawood, KS 66211

 

(Name and address of agent for service)

 

Registrant's telephone number, including area code: 877-244-6235

 

Date of fiscal year end: 11/30/2018

 

Date of reporting period: 2/28/2018

 

Item 1.

Schedule of Investments (Unaudited)

 

The Trust’s schedule of investments as of the close of the reporting period prepared pursuant to Rule 12-12 of Regulation S-X is as follows:

 

HEDGEROW INCOME AND OPPORTUNITY FUND

SCHEDULE OF INVESTMENTS

February 28, 2018 (Unaudited)

 

COMMON STOCK - 87.39%			Shares				Fair Value
Airlines - 5.43%
Delta Air Lines, Inc. (b)			3,500			$	188,650
JetBlue Airways Corp. (a) (b)			6,200				130,510
							319,160
Auto Manufacturers - 3.35%
General Motors Co.			5,000				196,750
Banks - 12.35%
Bank of New York Mellon Corp. (b)			4,300				245,229
BankUnited, Inc. (b)			1,500				60,330
Deutsche Bank AG - Germany			4,000				63,760
Goldman Sachs Group, Inc.			800				210,344
KeyCorp			1,700				35,921
Zions Bancorporation			2,000				109,940
							725,524
Biotechnology - 7.46%
Amgen, Inc. (b)			1,100				202,147
Gilead Sciences, Inc. (b)			3,000				236,190
							438,337
Building Materials - 4.51%
Eagle Materials, Inc.			2,000				200,460
Summit Materials, Inc. - Class A (a)			2,043				64,620
							265,080
Computers - 3.23%
Apple, Inc.			600				106,872
VeriFone Systems, Inc. (a)			5,000				83,000
							189,872
Cosmetics & Personal Care - 1.57%
elf Beauty, Inc. (a)			5,000				92,200
Diversified Financial Services - 0.85%
Waddell & Reed Financial, Inc. - Class A			2,500				50,000
Food - 3.05%
Sysco Corp.			3,000				178,950
Healthcare - Products - 1.98%
Zimmer Biomet Holdings, Inc.			1,000				116,250
Housewares - 2.62%
Newell Brands, Inc.			6,000				154,140
Insurance - 1.68%
Axis Capital Holdings Ltd. - Bermuda			2,000				98,680
Internet - 1.48%
Palo Alto Networks, Inc. (a)			500				86,685
Media - 6.51%
CBS Corp. - Class B			4,500				238,365
Walt Disney Co.			1,400				144,424
							382,789
Mining - 1.69%
Wheaton Precious Metals Corp. - Canada			5,200				99,216

 

HEDGEROW INCOME AND OPPORTUNITY FUND

SCHEDULE OF INVESTMENTS

February 28, 2018 (Unaudited)    

 

COMMON STOCK - 87.39% (continued)			Shares				Fair Value
Miscellaneous Manufacturing - 1.20%
General Electric Co. (b)			5,000			$	70,550
Oil & Gas - 0.99%
BP PLC - ADR - Britain			1,500				58,290
Oil & Gas Services - 1.35%
Baker Hughes a GE Co. (b)			3,000				79,200
Pharmaceuticals - 5.55%
Bristol-Myers Squibb Co. (b)			3,100				205,220
Mylan NV (a)			2,000				120,960
							326,180
Retail - 6.45%
Starbucks Corp.			2,000				114,200
TJX Cos., Inc. (b)			2,200				181,896
Williams-Sonoma, Inc.			1,600				82,816
							378,912
Semiconductors - 3.73%
Broadcom Ltd.			500				123,230
Lam Research Corp.			500				95,930
							219,160
Software - 4.21%
Electronic Arts, Inc. (a) (b)			2,000				247,400
Telecommunications - 6.15%
AT&T, Inc. (b)			3,500				181,500
Finisar Corp. (a)			5,500				180,000
							361,500
TOTAL COMMON STOCK (Cost $5,251,247)							5,134,825
OPTIONS PURCHASED (Cost $706) - 0.00% (d)							210
SHORT-TERM INVESTMENTS - 7.23%
Federated Government Obligations Fund - Class I, 1.24% (c)			425,077				425,077
TOTAL SHORT-TERM INVESTMENTS (Cost $425,077)							425,077
TOTAL INVESTMENTS (Cost $5,677,030) –  94.62%						$	5,560,112
OPTIONS WRITTEN (Proceeds $173,658) - (2.37%) (d)							(139,557	)
OTHER ASSETS IN EXCESS OF LIABILITIES, NET - 7.75%							455,634
NET ASSETS - 100%						$	5,876,189

 

(a)

Non-income producing security.

(b)

All or a portion of the security is segregated as collateral for call options written.

(c)

Rate shown represents the 7-day effective yield at February 28, 2018, is subject to change and resets daily.

 

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

 

HEDGEROW INCOME AND OPPORTUNITIES FUND

SCHEDULE OF PURCHASED OPTIONS

February 28, 2018 (Unaudited)          

         

OPTIONS PURCHASED - 0.00%

 

CALL OPTIONS PURCHASED - 0.00%                    

 

		Contracts 1				Notional Amount				Exercise Price				Expiration				Fair Value
Starbucks Corp.			10			$	65,000			$	65.00				4/20/2018			$	60
TravelCenters of America LLC			10				5,000			$	5.00				6/15/2018				150
TOTAL CALL OPTIONS PURCHASED (Cost $706)																			210
TOTAL OPTIONS PURCHASED (Cost $706)																		$	210

 

1

Each option contract is equivalent to 100 shares of common stock. All options are non-income producing.

 

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

 

HEDGEROW INCOME AND OPPORTUNITIES FUND

SCHEDULE OF WRITTEN OPTIONS

February 28, 2018 (Unaudited)

 

OPTIONS WRITTEN - (2.35)%                              

 

CALL OPTIONS WRITTEN - (1.63)%			Contracts 1				Notional Amount				Exercise Price				Expiration				Fair Value
Amgen, Inc.			4			$	76,000			$	190.00				6/15/2018			$	2,800
Amgen, Inc.			7				136,500			$	195.00				9/21/2018				6,041
Apple, Inc.			4				70,000			$	175.00				4/20/2018				3,200
Apple, Inc.			2				37,000			$	185.00				4/20/2018				640
Baker Hughes a GE Co.			30				112,500			$	37.50				4/20/2018				300
Bank of New York Mellon Corp.			30				180,000			$	60.00				9/21/2018				8,190
BankUnited, Inc.			15				60,000			$	40.00				5/18/2018				3,000
Bristol-Myers Squibb Co.			20				140,000			$	70.00				6/15/2018				4,900
Broadcom Ltd.			5				135,000			$	270.00				6/15/2018				3,995
CBS Corp. - Class B			20				130,000			$	65.00				4/20/2018				340
CBS Corp. - Class B			15				93,750			$	62.50				9/21/2018				2,183
Delta Air Lines, Inc.			15				82,500			$	55.00				3/16/2018				1,335
Delta Air Lines, Inc.			10				57,500			$	57.50				6/15/2018				2,070
Delta Air Lines, Inc.			10				60,000			$	60.00				9/21/2018				2,500
Eagle Materials, Inc.			20				240,000			$	120.00				4/20/2018				350
Electronic Arts, Inc.			10				125,000			$	125.00				6/15/2018				8,030
Electronic Arts, Inc.			10				135,000			$	135.00				6/15/2018				4,400
elf Beauty, Inc.			10				22,500			$	22.50				4/20/2018				250
elf Beauty, Inc.			10				22,500			$	22.50				5/18/2018				280
Finisar Corp.			15				43,500			$	29.00				6/15/2018				188
General Electric Co.			10				20,000			$	20.00				3/16/2018				20
General Motors Co.			30				141,000			$	47.00				6/15/2018				750
Gilead Sciences, Inc.			8				68,000			$	85.00				3/16/2018				168
Gilead Sciences, Inc.			12				102,000			$	85.00				9/21/2018				4,488
Goldman Sachs Group, Inc.			8				216,000			$	270.00				7/20/2018				10,840
JetBlue Airways Corp.			30				72,000			$	24.00				6/15/2018				1,275
JetBlue Airways Corp.			20				52,000			$	26.00				9/21/2018				1,050
KeyCorp			7				14,700			$	21.00				6/15/2018				1,043
KeyCorp			10				22,000			$	22.00				9/21/2018				1,600
Lam Research Corp.			5				120,000			$	240.00				6/15/2018				1,362
Mylan NV			20				100,000			$	50.00				7/20/2018				1,720
Mylan NV			10				55,000			$	55.00				7/20/2018				330
Palo Alto Networks, Inc.			5				80,000			$	160.00				3/16/2018				6,900
Summit Materials, Inc. - Class A			10				35,000			$	35.00				5/18/2018				775
Summit Materials, Inc. - Class A			10				35,000			$	35.00				8/17/2018				1,625
Sysco Corp.			20				130,000			$	65.00				5/18/2018				1,500
Sysco Corp.			10				65,000			$	65.00				8/17/2018				1,170
TJX Cos., Inc.			16				132,000			$	82.50				4/20/2018				5,488
TJX Cos., Inc.			6				48,000			$	80.00				7/20/2018				3,972
Waddell & Reed Financial, Inc. - Class A			15				37,500			$	25.00				6/15/2018				225
Walt Disney Co.			5				55,000			$	110.00				4/20/2018				515
Walt Disney Co.			9				99,000			$	110.00				7/20/2018				2,889
Wheaton Precious Metals Corp. - Canada			25				56,250			$	22.50				6/15/2018				925
Williams-Sonoma, Inc.			16				96,000			$	60.00				4/20/2018				920
Zimmer Biomet Holdings, Inc.			5				62,500			$	125.00				6/15/2018				1,400
Zimmer Biomet Holdings, Inc.			5				65,000			$	130.00				6/15/2018				725
Zions Bancorporation			20				110,000			$	55.00				4/20/2018				5,360
TOTAL CALL OPTIONS WRITTEN (Proceeds $141,334)																			114,027

 

HEDGEROW INCOME AND OPPORTUNITY FUND SCHEDULE OF WRITTEN OPTIONS February 28, 2018 (Unaudited)

ANNUAL REPORT

 

PUT OPTIONS WRITTEN - (0.72)%			Contracts 1				Notional Amount				Exercise Price				Expiration				Fair Value
Amgen, Inc.			5			$	85,000			$	170.00				6/15/2018			$	2,325
Broadcom Ltd.			5				105,000			$	210.00				6/15/2018				1,955
Delta Air Lines, Inc.			10				55,000			$	55.00				3/16/2018				1,770
Electronic Arts,, Inc..			10				120,000			$	120.00				6/15/2018				5,500
EOG Resources, Inc.			5				47,500			$	95.00				4/20/2018				775
FedEx Corp.			10				240,000			$	240.00				4/20/2018				6,050
Mylan NV			10				40,000			$	40.00				7/20/2018				2,930
NXP Semiconductors NV			20				220,000			$	110.00				4/20/2018				1,600
Starbucks Corp.			15				86,250			$	57.50				3/16/2018				1,185
TJX Cos., Inc.			6				46,500			$	77.50				7/20/2018				1,440
TOTAL PUT OPTIONS WRITTEN (Proceeds $32,324)																			25,530
TOTAL OPTIONS WRITTEN (Proceeds $173,658)																		$	139,557

 

1

Each option contract is equivalent to 100 shares of common stock. All options are non-income producing.

 

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

 

Hedgerow Income and Opportunities Fund

NOTES TO THE SCHEDULE OF INVESTMENTS

February 28, 2018 (Unaudited)

 

The following is a summary of significant accounting policies consistently followed by the Hedgerow Income and Opportunities Fund (the “Fund”). The policies are in conformity with accounting principles generally accepted in the United States of America (“GAAP”). The Fund is an investment company that follows the accounting and reporting guidance of Accounting Standards Codification Topic 946 applicable to investment companies.

 

Processes and Structure

 

The Fund’s Board of Trustees has adopted guidelines for valuing securities and other derivative instruments including in circumstances in which market quotes are not readily available, and has delegated authority to the Adviser to apply those guidelines in determining fair value prices, subject to review by the Board of Trustees.

 

Hierarchy of Fair Value Inputs

 

The Fund utilizes various methods to measure the fair value of most of its investments on a recurring basis. GAAP establishes a hierarchy that prioritizes inputs to valuation techniques used to measure fair value. The three levels of inputs are as follows:

 

•

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

•

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

•

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

 

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

 

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

 

Fair Value Measurements

 

A description of the valuation techniques applied to the Fund's major categories of assets and liabilities measured at fair value on a recurring basis follows.

 

Equity securities (common stock) – Securities traded on a national securities exchange (or reported on the NASDAQ national market) are stated at the last reported sales price on the day of valuation. To the extent these securities are actively traded, and valuation adjustments are not applied, they are categorized in level 1 of the fair value hierarchy. Certain foreign securities may be fair valued using a pricing service that considers the correlation of the trading patterns of the foreign security to the intraday trading in the U.S. markets for investments such as American Depositary Receipts, financial futures, Exchange Traded Funds, and the movement of the certain indexes of securities based on a statistical analysis of the historical relationship and that are categorized in level 2. Preferred stock and other equities traded on inactive markets or valued by reference to similar instruments are also categorized in level 2.

 

Money market funds – Money market funds are valued at their net asset value of $1.00 per share and are categorized as Level 1.

 

Hedgerow Income and Opportunities Fund

NOTES TO THE SCHEDULE OF INVESTMENTS

February 28, 2018 (Unaudited)

 

Derivative instruments – Listed derivatives, including options, that are actively traded, are valued based on quoted prices from the exchange and categorized in level 1 of the fair value hierarchy. Options held by the Fund for which no current quotations are readily available and which are not traded on the valuation date are valued at the mean price and are categorized within level 2 of the fair value hierarchy. Over-the-counter (OTC) derivative contracts include forward, swap, and option contracts related to interest rates; foreign currencies; credit standing of reference entities; equity prices; or commodity prices, and warrants on exchange-traded securities. Depending on the product and terms of the transaction, the fair value of the OTC derivative products can be modeled taking into account the counterparties' creditworthiness and using a series of techniques, including simulation models. Many pricing models do not entail material subjectivity because the methodologies employed do not necessitate significant judgments, and the pricing inputs are observed from actively quoted markets, as is the case of interest rate swap and option contracts. OTC derivative products valued using pricing models are categorized within level 2 of the fair value hierarchy.

 

If the Adviser decides that a price provided by the pricing service does not accurately reflect the fair value of the securities, when prices are not readily available from a pricing service, or when certain restricted or illiquid securities are being valued, securities are valued at fair value as determined in good faith by the Adviser, in conformity with guidelines adopted by and subject to review of the Board and the Fair Valuation Committee. These securities will be categorized as level 3 securities.

 

The following table summarizes the inputs used to value the Fund’s assets and liabilities measured at fair value as of February 28, 2018.

Hedgerow Income and Opportunities Fund

Financial Instruments – Assets

 

Security Classification (1)		Level 1 (Quoted Prices)				Level 2 (Other Significant Observable Inputs)				Totals
Common Stock (2)		$	5,134,825			$	-			$	5,134,825
Call Options Purchased			210								210
Money Market Funds			425,077				-				425,077
Total Assets		$	5,560,112			$	-			$	5,560,112
Derivative Instruments – Liabilities
Security Classification (1)			Level 1 (Quoted Prices)			Level 2 (Other Significant Observable Inputs)					Totals
Call Options Written		$	114,027			$	-			$	114,027
Put Options Written			25,530				-				25,530
Total Liabilities		$	139,557			$	-			$	139,577

 

 

(1)

As of and during the three month period ended February 28, 2018, the Fund held no securities that were considered to be “Level 3” securities (those valued using significant unobservable inputs). Therefore, a reconciliation of assets in which significant unobservable inputs (Level 3) were used in determining fair value is not applicable.

 

(2)

All common stock held in the Fund are Level 1 securities. For a detailed break-out of common stock by industry, please refer to the Schedule of Investments.

 

There were no transfers into and out of any Level during the three month period ended February 28, 2018. It is the Fund’s policy to recognize transfers between Levels at the end of the reporting period.

 

During the three month period ended February 28, 2018, no securities were fair valued.

 

Hedgerow Income and Opportunities Fund

NOTES TO THE SCHEDULE OF INVESTMENTS

February 28, 2018 (Unaudited)

 

Options – The Fund uses an option strategy in an effort to limit market exposure and volatility. The extent of option selling will depend upon market conditions and the Adviser’s judgment of the advantages of selling call options on the Fund’s equity investments. The sale of put options generates income for the Fund, but exposes it to the risk of declines in the value of the underlying assets. The risk in purchasing options is limited to the premium paid by the Fund for the options. The sale of call options generates income for the Fund, but may limit the Fund's participation in equity market gains. The Fund’s investment advisor seeks to reduce the overall volatility of returns for the Fund by managing a portfolio of options. When the Fund writes or purchases an option, an amount equal to the premium received or paid by the Fund is recorded as a liability or an asset and is subsequently adjusted to the current market value of the option written or purchased. Premiums received or paid from writing or purchasing options which expire unexercised are treated by the Fund on the expiration date as realized gains or losses. The difference between the premium and the amount paid or received on effecting a closing purchase or sale transaction, including brokerage commissions, is also treated as a realized gain or loss. If an option is exercised, the premium paid or received is added to the cost of the purchase or proceeds from the sale in determining whether the Fund has realized a gain or a loss on investment transactions.

 

Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. The successful use of options depends in part on the ability of the Adviser to manage future price fluctuations and the degree of correlation between the options and securities markets. By writing put options on equity securities, the Fund strike prices of the written put options, but continues to bear the risk of declines in the value of its common stock portfolio. The Fund will receive a premium from writing a covered call option that it retains whether or not the option is exercised. The premium received from the written options may not be sufficient to offset any losses sustained from the volatility of the underlying equity securities over time.

 

Derivative Transactions

 

As of February 28, 2018, portfolio securities valued at $1,587,026 were held in escrow by the custodian as cover for call options written by the Fund.

 

As of February 28, 2018, the Statement of Assets and Liabilities included the following financial derivative instrument fair values:

 

Assets		Equity Contracts				Total
Call options purchased, at value		$	210			$	210
Total Assets		$	210			$	210

 

Liabilities		Equity Contracts				Total
Call options written, at value		$	114,027			$	114,027
Put options written, at value			25,530				25,530
Total Liabilities		$	139,557			$	139,557

 

For the three month period ended February 28, 2018, financial derivative instruments had the following effect on the Statement of Operations:

 

Net change in unrealized appreciation (depreciation) on:		Equity Contracts				Total
Call options purchased		$	(496	)		$	(496	)
Call options written			58,671				58,671
Put options written			9,640				9,640
		$	67,815			$	67,815

 

Hedgerow Income and Opportunities Fund

NOTES TO THE SCHEDULE OF INVESTMENTS

August 31, 2017 (Unaudited)

 

Derivative Transactions (continued)

 

Net realized gain (loss) on:		Equity Contracts				Total
Call options purchased		$	-			$	-
Put options purchased			-				-
Call options written			25,004				25,004
Put options written			48,292				48,292
		$	73,296			$	73,296

 

The following table presents the Funds’ liability derivatives available for offset under a master netting arrangement net of collateral pledged as of February 28, 2018.

 

Assets:	Gross Amounts of Asses Presented in the Statement of Assets & Liabilities
		Gross Amounts of Recognized Assets				Gross Amounts Offset in the Statement of Assets and Liabilities				Net Amounts of assets Presented in the Statement of Assets and Liabilities				Financial Instruments Pledged				Cash Collateral Pledged				Net Amount of Assets
Options Written Contracts		$	210	(1)		$	-			$	210	(1)		$	210	(2)		$	-			$	-
Total		$	210	(1)		$	-			$	210	(1)		$	210	(2)		$	-			$	-

 

Liabilities:	Gross Amounts of Liabilities Presented in the Statement of Assets & Liabilities
		Gross Amounts of Recognized Liabilities				Gross Amounts Offset in the Statement of Assets and Liabilities				Net Amounts of Liabilities Presented in the Statement of Assets and Liabilities				Financial Instruments Pledged				Cash Collateral Pledged				Net Amount of Liabilities
Options Written Contracts		$	139,557	(3)		$	-			$	139,557	(3)		$	139,557	(2)		$	-			$	-
Total		$	139,557	(3)		$	-			$	139,557	(3)		$	139,557	(2)		$	-			$	-

 

(1)

Purchased options at value as presented in the Fund’s Schedule of Purchased Options.

(2)

The amounts are limited to the derivative asset and liability balances and accordingly do not include excess collateral pledged.

(3)

Written options at value as presented in the Fund’s Schedule of Written Options.

 

TAX MATTERS

 

For U.S. Federal income tax purposes, the cost of securities owned, gross appreciation, gross depreciation, and net unrealized appreciation/(depreciation) of investments February 28, 2018 were as follows:

 

Cost	Gross Appreciation	Gross Depreciation	Net Appreciation
$ 5,678,492	$ 264,294	$ (382,674)	$ (118,380)

 

The difference between book basis and tax basis unrealized appreciation (depreciation) is primarily attributable to the tax deferral of losses on wash sales.

Item 2.

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 Investment Company Act of 1940, as amended (the “1940 Act”)) were 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 to the Registrant's internal control over financial reporting (as defined in Rule 30a-3(d) under the Act) that occurred during the Registrant's last fiscal quarter that have materially affected, or are reasonably likely to materially affect, the Registrant's internal control over financial reporting.

 

Item 3.

Exhibits.

 

(a)

A certification for the Principal Executive Officer of the registrant is attached hereto as part of EX-99.cert.

 

(b)

A certification for the Principal Financial Officer of the registrant is attached hereto as part of EX-99.cert.

 

SIGNATURES

 

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

 

(Registrant) 360 Funds

 

By:	/s/ Randy Linscott
Name:	Randy Linscott
Title:	Principal Executive Officer
Date:	April 24, 2018

 

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

indicated.

 

By:	/s/ Randy Linscott
Name:	Randy Linscott
Title:	Principal Executive Officer
Date:	April 24, 2018
By:	/s/ Justin Thompson
Name:	Justin thompson
Title:	Principal Financial Officer
Date:	April 24, 2018

 

Certification Pursuant to Section 302 of the Sarbanes-Oxley Act

 

I, Randy Linscott, certify that:

 

1.

I have reviewed this report on Form N-Q of the 360 Funds, (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 schedule of investments included in this report fairly presents in all material respects the investments of the registrant as of the fiscal quarter 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 registrant’s most recent fiscal quarter 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 trustees (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: April 24, 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-Q of the 360 Funds, (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 schedule of investments included in this report fairly presents in all material respects the investments of the registrant as of the fiscal quarter 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 registrant’s most recent fiscal quarter 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 trustees (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: April 24, 2018	/s/ Justin Thompson
	Justin Thompson, Principal Financial Officer

 

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