Brinsmere Fund Growth ETF

Brinsmere Fund Growth ETF (TBFG) is an actively managed fund of funds. It owns about two dozen other ETFs covering U.S. and foreign stocks, bonds and other assets. The adviser, The Milwaukee Company, shifts the mix using three in-house, rules-based models that aim to reduce risk when markets look stressed. Its 0.46% expense ratio is well below the 0.79% to 0.95% charged by the buffer ETFs in our comparison set, though those funds use a different strategy.

• Over the year to Oct 27, 2026, TBFG returned +10.1%, 7th of 8 among similar funds.
• Its worst full calendar year was 2025 (+14.6%); its best was 2025 (+14.6%).
• The deepest fall in its price history was 13.4% (Feb 19, 2025 to Apr 8, 2025), recovered by Jun 26, 2025.

As of Jun 30, 2026, the fund held 24 securities; the ten largest made up 62.28% of assets.

• Over the three months to Jun 30, 2026, investors withdrew a net $4.7M (creations minus redemptions, per the N-PORT report).
• Monthly total returns reported for that quarter: +6.33%, +3.49%, +0.21%.

TBFG does not track an index. The Milwaukee Company, with Penserra Capital Management as sub-adviser, splits the portfolio among three proprietary strategies. Two are growth versions of its Systematic Market Beta (SMB-G) and Classic Asset Allocation Revisited (CAAR-G) strategies. The third is its Structured International Strategy (SIS). The adviser decides how much goes to each, based on portfolio risk, market moves and relative value.

SMB-G seeks "market beta," meaning the return of the broad market. It also tries to hedge against a long bear market in stocks, bonds or both, using signals such as trend, volatility, valuation, interest rates and economic data. CAAR-G uses quantitative models of expected risk, return and diversification. It also watches the VIX, an index of how much investors expect large U.S. stocks to swing over the next 30 days. SIS covers foreign stocks of all sizes and can shift into short-term Treasuries and cash. The adviser may override any model when it believes the data no longer reflect market conditions.

Because TBFG owns funds rather than individual stocks and bonds, its holdings are other ETFs. As of June 30, 2026, the largest were State Street SPDR Portfolio S&P 500 ETF (11.5%), Invesco S&P 500 Momentum ETF (8.0%) and Invesco RAFI US 1000 ETF (6.7%). Some funds it may own use futures or options, or give exposure to inverse bonds, gold or managed futures. Portfolio turnover of 195% means holdings change often.

• TBFG charges 0.46% a year, versus an average of 0.86% for the similar funds below (1st of 8, cheapest first).
• Of that, 0.35% is the management fee; the rest covers other fund expenses.
• Using the prospectus's standard example, $10,000 invested would cost about $47 in the first year and $579 over 10 years (assuming a 5% annual return).

It combines U.S. and foreign stocks with Treasury and corporate bond funds in one actively adjusted, growth-oriented portfolio at a moderate cost.

TBFG offers a growth-tilted stock and bond mix in a single fund. As of June 30, 2026, its ten largest holdings made up about 62% of assets. Its one-year beta was 0.79, meaning it moved about 79% as much as the broad market. It launched on January 16, 2024, so it has no record from the 2008, 2020 or 2022 sell-offs. Its deepest drop was 13.4%, from February 19 to April 8, 2025. It recovered by June 26, 2025, about 2.6 months later. Its only full calendar year, 2025, returned 14.44%. Anyone who might need to sell in a bad year would be relying on models that have not yet faced a long bear market. The fund paid 2.41% over the 12 months to October 27, 2026, in quarterly distributions. In the SEC's $10,000 example, costs come to $47 after one year and $579 after ten. Past results don't predict future returns, and a plan should look at the whole portfolio, not one fund.

Matched by other buffer (defined-outcome) funds, largest first.