Section 351 ETF

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Polen 5Perspectives Growth Opportunities ETF

Actively managed ETF seeking to identify growth opportunities through a multi-perspective, high-conviction investment process.

Ticker

PCGO

Contribution Deadline

May 29, 2026

Launch Date

Jun 30, 2026

* This ETF is available for a Section 351 Tax-Deferred Exchange

What Is a Section 351 Exchange?

A Section 351 exchange allows investors to contribute stocks and other securities to a new ETF in exchange for fund shares without triggering immediate capital gains taxes, deferring taxes while moving assets into a diversified exchange traded fund.

See How ExchangiFi Works

Watch a short demo video and learn the key rules for participating in a 351 tax-deferred ETF exchange.

25/50 Diversification Rule

Each investor must contribute a sufficiently diversified portfolio, with limits based on the maximum market value of their largest holding (25%) and top five holdings combined (50%).

Intraday Liquidity

Qualifying securities must be liquid and trade intra-day, which include stocks, bonds, ETF, closed end funds, and ADRs, no illiquid or restricted investments.

Fund Strategy Alignment

The basket of securities contributed must mostly align with the investment objective of the newly formed ETF as described in its prospectus to qualify for a Section 351 tax-deferred Exchange.

Polen 5Perspectives Growth Opportunities ETF

The strategy seeks to identify inflection points in a company’s earnings growth before they are recognized by the broader market, employing a differentiated, multi disciplined approach that integrates fundamental, thematic, and technical analysis. Rather than screening out companies early in the process, the team analyzes each company through five distinct perspectives, allowing the weight of evidence to guide stock selection. The objective is to reduce opportunity cost while capturing compelling growth opportunities.

ETF Snapshot

ETF Issuer

Polen Capital Management, LLC

Fund Name

Polen 5Perspectives Growth Opportunities ETF

Ticker Symbol

PCGO

Investment Strategy

Large cap growth

Investment Objective

Long-term capital appreciation

Expense Ratio

0.45%

Primary Exchange

NYSE Arca

Contribution Deadline

May 20, 2026

Estimated Launch Date

Jun 30, 2026

Objectives

Multi-Discipline Analysis

Applies fundamental, thematic, and technical analysis to seek to identify potential inflection points in a company’s earnings power before the market recognizes them.

Five-Perspective Evaluation Framework

Uses five distinct perspectives to build a balanced view of each investment, allowing the weight of evidence to guide portfolio construction.

High-Conviction, Active Management

Managed by Polen Capital, a global active investment manager seeking to generate superior long-term returns through a differentiated growth equity process.

Why PCGO?

Five-Perspective Evaluation Framework

Broader Opportunity Set

Experienced Active Manager

Multi-Perspective Portfolio Construction

About Polen Capital

Polen Capital is a global investment management firm specializing in active equity and credit strategies. Founded in 1979, the firm manages high-conviction portfolios focused on long-term results. The firm operates through four autonomous teams, Quality Growth, 5Perspectives Growth, Global Emerging Markets, and Leveraged Credit, offering strategies across equity and credit markets.

Investment Team

OR

Andrew Cupps

Head of Team, Portfolio Manager & Analyst

Drew leads portfolio management and investment analysis for the 5Perspectives strategies.

KL

Kevin Leitner, CFA

Research Analyst

Kevin utilizes his extensive trading and research experience to bring valuable insights to the team.

CB

Chris Bush

Research Analyst

Chris is a Research Analyst on Polen Capital’s 5Perspectives Growth team.

Sample Only: Top 10 Holdings

The following represents a hypothetical sample of potential top holdings for illustrative purposes only. Actual fund constituents will be determined by the investment manager upon launch and are subject to change based on market conditions and the fund’s stated investment objective.

TICKER

NAME

WEIGHT %

NVDA

Nvidia Corp.

7.4%

AAPL

Apple Inc.

6.1%

MSFT

Microsoft Corp.

5.2%

AMZN

Amazon.com Inc.

3.6%

GOOGL

Alphabet Inc. Class A

3.1%

AVGO

Broadcom Inc.

2.7%

GOOG

Alphabet Inc. Class C

2.5%

META

Meta Platforms Inc. Class A

2.4%

TSLA

Tesla Inc.

1.9%

BRK.B

Berkshire Hathaway Inc. Class B

1.6%

Important Disclosures

Risk Warning

Investors should consider the investment objectives, risks, charges, and expenses of the Fund carefully before investing. This and other information can be found in the Fund’s prospectus or summary prospectus, which may be obtained by visiting the fund sponsor’s website or at the links above on this page. Please read the prospectus carefully before investing or sending money. This material is for informational purposes only and should not be construed as investment advice or a recommendation to buy or sell any security. Past performance is no guarantee of future results. All investments involve risk, including the possible loss of principal. The Fund is not intended to be a sole investment strategy for any investor. Please consult your investment adviser for investment advice tailored to your specific situation.

Investment Risks

Investing in the Fund involves significant risks, including the potential loss of all or a portion of your investment. Stock markets are inherently volatile, and the price of equity securities fluctuates based on changes in a company’s financial condition, historical and prospective earnings, interest rates, investor perceptions, and broader market or economic conditions. Because the Fund is actively managed, there is no guarantee that the investment adviser’s strategies or techniques will be successful or that the Fund will achieve its investment objective (Management Risk). Furthermore, the Fund may be subject to Growth Style Risk, as growth stocks can be more volatile and sensitive to investor perceptions of future earnings than the broader market. To the extent the Fund focuses on a particular sector, industry, geography, or asset class, it faces Concentration Risk and may be more susceptible to adverse developments than a more diversified portfolio. Additionally, certain holdings may be subject to Liquidity Risk, making them difficult or impossible to sell at a desired time or price, which could force the Fund to realize a loss.

ETF Risks

Shares of ETFs are bought and sold at market price rather than net asset value (NAV), which may result in shares trading at a premium or discount to the Fund’s underlying value due to supply and demand imbalances or market volatility. Unlike conventional mutual funds, ETF shares are not individually redeemable directly from the Fund; they must be bought and sold on a secondary market where an active trading environment may not always be maintained or could be subject to exchange-mandated halts. This secondary market liquidity is heavily dependent on Authorized Participants; if their number is reduced, the Fund’s shares may experience wider bid-ask spreads and increased price deviations from NAV. Furthermore, investors should be aware of Brokerage Commission Risk, as the costs of frequent trading and standard Fund expenses will reduce overall investment returns.

Section 351 & Tax Risk

Certain investors may seek to contribute appreciated securities to the Fund in exchange for Fund shares under Section 351 of the Internal Revenue Code; however, participation in such an exchange is subject to significant tax, legal, and regulatory risks, and there is no guarantee that any such transaction will qualify for tax-deferred treatment. A valid Section 351 exchange results in tax deferral—not tax elimination—as the investor’s original cost basis and holding period carry over to the ETF shares, meaning a future sale will trigger the recognition of previously deferred capital gains. To qualify for this treatment under Section 351(e), the contributed portfolio must satisfy strict diversification tests (the “25/50 rule”) and a “control requirement” where contributing investors collectively own at least 80% of the Fund immediately following the exchange; failure to meet these standards may result in the entire transaction being treated as a taxable event. Furthermore, investors face Post-Contribution Rebalancing Risk and IRS Challenge Risk, as the IRS may invoke the “substance over form” doctrine to tax the exchange if it deems the transaction a pre-arranged sale. Tax treatment is also subject to Legislative and Regulatory Risk, as future changes to the Internal Revenue Code or Treasury regulations could retroactively or prospectively eliminate the benefits of these ETF seeding strategies. Nothing herein constitutes tax advice, and because these consequences are complex and fact-specific, investors are strongly encouraged to consult with a qualified tax advisor or attorney before contributing assets in reliance on Section 351.