The fund seeks to achieve its investment objective by investing in a portfolio of exchange-traded funds (“ETFs”) that seek to provide investors with returns (before fees and expenses) based on the price return of the SPDR® S&P 500® ETF Trust (“SPY”), up to a predetermined cap, while providing a defined buffer against losses of SPY over a defined one-year period (the underlying ETFs). Under normal market conditions, it will invest substantially all of its assets in underlying ETFs. The fund is non-diversified.