Introduction and Overview
This brochure contains important information. We encourage you to read it carefully and ask questions if there is any
information that you do not understand.
In this brochure, references to “we,” “us,” “our,” or “our firm” refer to Simplicity Wealth. Individuals who serve as our
managers, officers, employees, and investment adviser representatives may also be referred to as our “advisors.” Our firm’s
clients and prospective clients are referred to as “you,” “your,” or “our clients.”
Simplicity Wealth is an investment adviser registered with the SEC since 2019. Simplicity Wealth is owned by Simplicity
Financial Marketing Holdings, Inc. Clients of Simplicity Solutions, LLC, an affiliated registered investment adviser, are now
clients of Simplicity Wealth. Simplicity Solutions, LLC is no longer a registered investment adviser.
Directly Held Mutual Fund Services
We offer a series of portfolios on directly held mutual fund platforms. Versions of our portfolios are offered and constructed
using the mutual funds made available by the platforms. This can provide efficient diversification for specific account types,
ease of making account contributions, and simple access to certain mutual fund managers. The platforms have varying
fees, the selected mutual funds are subject to various internal expenses, and we charge a management fee.
Retirement Plan Services
In conjunction with the advisory services offered, we provide qualified retirement plan sponsors with a flexible, yet easy
solution that includes several investment options. We provide investment advisory services to retirement plan sponsors under
either Section 3(38) or Section 3(21) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA).
We also provide advice to the individual participants of retirement plans such as 401(k), 403(b), etc. The individual
participants are ultimately required to exercise their discretion to act upon the investment advice recommended by us.
Discretionary Retirement Plan Services
We offer full discretionary investment management services to retirement plan sponsors under Section 3(38) of ERISA. In
the capacity as an investment manager under Section 3(38) of ERISA, you give us discretionary authority to manage your
plan’s assets. In such capacity, we perform the following services on behalf of the retirement plan: (i) provide portfolio model
allocations for retirement plans utilizing the available investment options under the plan; (ii) develop, manage, monitor and
rebalance the portfolio model allocations in accordance with our investment methodology; and (iii) provide general
enrollment and investment education to plan participants, but do not provide specific investment advice to plan participants.
We provide services only to the plan sponsor with respect to the plan sponsor’s responsibilities to the retirement plan and
not to any of the plan participants.
Non-Discretionary Retirement Plan Services
We also provide non-discretionary investment consulting services to retirement plan sponsors under Section 3(21) of ERISA.
As a Section 3(21) investment adviser, we provide the plan sponsor with non-binding investment recommendations, but it
is ultimately up to the plan sponsor to decide whether and how to act upon such investment recommendations. In providing
these services, we do not (i) exercise investment discretion, management, or authority over the plan assets, (ii) maintain
custody or control over client assets, or (iii) undertake responsibility for execution of trades or administration of the plan.
The plan sponsors are ultimately required to exercise their discretion to act upon the investment options recommended by
us, with participants being responsible for any individual investment selections made under the plan.
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Financial Planning
We offer a broad range of financial planning services which may include tax-related and other non-investment-related
matters. These engagements may be for one-time, initial planning and/ or ongoing planning services. Financial plans and
financial planning may include but are not limited to: investment planning; tax concerns; retirement planning; college
planning, private placements, real estate transactions; and, for 401(k) plans, investment due diligence. These services are
based on fixed or hourly fees and the final fee structure is documented in the advisory agreement with our clients.
Services Limited to Specific Types of Investments
We generally limit investment advice and/or money management to exchange traded funds (ETFs), mutual funds and
common stock. However, we may use other securities/investments/assets, (e.g., closed-end mutual funds, bonds, REITs,
ETNs, preferred stock, structured products, LPs, cash equivalents/money market and individual securities) to help diversify
a portfolio when applicable.
Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all of our clients. However, your specific financial goals and their implementation
depend on your client profile which outlines your current situation (risk tolerance, income, tax level etc.). This is used in
conjunction with gathered investment objective information to help select and construct a portfolio that matches your
restrictions, goals, and targets.
You may impose restrictions on investing in certain securities or types of securities in accordance with your values or beliefs.
If you choose to impose restrictions on our portfolio management, you should be aware that it could cause your account to
underperform compared to similar portfolios that do not apply such restrictions. Accordingly, you may forego opportunities
for us to buy certain securities when it might otherwise be advantageous to do so, or you may request us to sell securities
when it might otherwise be disadvantageous to do so.
Additionally, if your restrictions prevent us from properly servicing your account or require us to deviate significantly from
our standard suite of services, we reserve the right to end our relationship with you.
Tax Overlay Services
Simplicity Wealth offers optional Tax Optimization Services and Tax Transition Services (collectively “Tax Overlay Services”)
to assist in mitigating the impact of income taxes on certain Client accounts. The primary source of taxes in Client portfolios
is from realized short-term capital gains. Simplicity Wealth’s Tax Optimization Service seeks to minimize or, if possible,
eliminate realization of short-term capital gains. When rebalancing Client accounts, Simplicity Wealth weighs the tax impact
of transactions against the risk of not complying with the Model Manager’s sell recommendations. If selling a security based
on a Model Manager’s recommended model portfolio change will result in a substantial short-term capital gain, Simplicity
Wealth will typically seek to offset that gain with existing realized short-term losses, harvest new short-term losses, or
potentially defer the sale of the security until it either reaches long-term capital gains status or until an offsetting short-term
capital loss can be harvested.
Simplicity Wealth may provide Tax Transition Services to minimize the impact of income taxes on certain Client accounts
as an existing Client portfolio is transitioned into the Program. Simplicity Wealth offers customizable solutions to manage
potential realization of large, unrealized capital gains that may be embedded in a Client’s portfolio in addition to customizable
strategies that provide for tax-efficient diversification of Client portfolios with asset concentration.
Socially Responsible Investing Services
Simplicity Wealth offers an optional Socially Responsible Investing (“SRI”) screening service designed for Clients who wish
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to integrate Environmental, Social and Governance factors into their investments. SRI overlay screens can be applied to an
existing account and has the ability to be customized to exclude investments within certain segments. We maintain discretion
for this service in the selection of investments, timing and execution of transactions.
Index Replication Service
Simplicity Wealth offers a replicated index solution, which can give Clients direct, index-like exposure through
recommendation of a sub-set of securities that are representative of a particular index with similar risk characteristics. We
maintain discretion for this service in the selection of investments, timing and execution of transactions.
Independent Managers
To address a client’s designated investment objectives, investment adviser representatives of Simplicity Wealth will at times
recommend that the client allocate a portion or all of his or her investment assets to one or more unaffiliated independent
registered investment advisers (“Independent Manager(s)”. Factors that are considered before recommending an
Independent Manager include but are not limited to: the client’s investment objectives, the Independent Manager’s
management style, investment team, performance history, reputation, financial strength, pricing, and investment process.
Simplicity Wealth has discretion to choose Independent Managers to manage all or a portion of the client's assets. The
Independent Manager shall have day‐ to‐day responsibility for the discretionary management of the allocated assets, and
Simplicity Wealth will continue to render investment advisory services regarding the assets placed with the Independent
Manager, including the ongoing monitoring and review of account performance and compliance with the client’s investment
objectives. Your agreement with us gives us the authority to hire or fire these Independent Managers on your behalf. Clients
typically will incur a separate fee from the Independent Manager for those services in addition to the fees assessed by
Simplicity Wealth.
Managed Account Program
We offer a Turnkey Asset Management Program (“TAMP”) to independent third-party investment advisers, broker/dealers,
insurance companies, banks, and trust companies (individually, an
“Adviser” and collectively, the “Advisers”). The investment
management and investment advisory services provided by Simplicity Wealth as described herein are primarily offered
through its Managed Account Program (the “Program” or “TAMP”). Through the Program, Simplicity Wealth provides Advisers
with access to the model portfolios of a wide variety of third party investment managers (the “Model Managers”) selected by
Simplicity Wealth as well as access to supporting operational services.
Each model portfolio is designed to meet a particular investment goal. Under a written agreement between the Model
Manager and Simplicity Wealth (the “Model Manager Agreement”), the Model Manager constructs a model portfolio based
on an asset allocation risk profile and selects the underlying investments for each portfolio that is based upon a particular
investment strategy and/or philosophy. The Model Manager will provide the buy and sell recommendations to Simplicity
Wealth for the Model Portfolios.
Simplicity Wealth provides ongoing due diligence and review of the Model Managers available through its Program. We may
at any time hire or terminate a Model Manager at its complete discretion. In the event a Model Manager is terminated or
departs from our Program, in coordination with the Client’s Adviser, an appropriate replacement may be recommended for a
Client’s account. We cannot guarantee the availability of a particular model portfolio or particular Model Manager.
Simplicity Wealth's model portfolio offerings are not limited to any specific product or service offered by a broker-dealer or
insurance company and will generally include advice regarding exchange-listed securities, like stocks and ETFs, foreign
issuers, corporate debt securities (other than commercial paper), certificates of deposit, municipal securities, mutual funds,
United States governmental securities, option contracts on securities and the model portfolios of a variety of Model Managers.
Based on the individual needs and circumstances of the Client, the Client’s Adviser will determine the allocation of assets in
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the Client’s account among the various investment options and model portfolios available, as deemed appropriate.
Simplicity Wealth will provide advice regarding specific investments for a Program account, and will manage or effect
purchases, sales, or other transactions for an account. In addition, Simplicity Wealth will have the authority and discretion to
manage the account in the event a Model Manager ceases to act as manager for the account, in which event Simplicity
Wealth will manage account investments not allocated to an existing Model Manager until a new Model Manager is retained
or manage account investments in their entirety in the event no new Model Manager is recommended. In managing the
account assets, Simplicity Wealth is specifically permitted to retain all or part of the existing investments or to liquidate such
investments, at our discretion. However, the decision regarding the selection of investment options, including model portfolios,
to be held in a Client’s account is made by the Client’s Adviser based, in part, on our evaluation of the investment styles,
strategies, risks, and potential benefits of each investment option and each Model Manager. At or before entering into the
Investment Management Agreement, the Client’s Adviser will be available to discuss the Model Manager’s Disclosure
Documents and answer any questions the Client may have regarding the Program and the Model Managers. Because the
Model Managers may change from time to time, Clients and prospective Clients should consult directly with their Adviser to
discuss the currently available selection of Model Managers. Certain Model Managers may not be available to all Clients.
Simplicity Wealth also provides an overlay management service for the model portfolios selected by an Adviser for a Client’s
account, which includes executing instructed trades and rebalancing the account at the Adviser’s request or as necessary to
conform to the recommended asset allocation for the model portfolio as directed by the Model Manager.
The suitability of a transaction for the Client is assessed and determined as of the date the transaction was executed for the
Client’s account by the Client’s Adviser. All transactions effected for the Client’s account will be deemed to be suitable based
on and in reliance on the Client’s Adviser’s assessment of the Client’s financial situation, investment objectives, risk tolerance,
and investment time horizon, unless written notice to the contrary is received by the Simplicity Wealth team within 10 business
days following the Client’s receipt of the custodian’s statement reflecting such transactions. Although the Client’s Adviser
maintains discretion over the Client’s account, Simplicity Wealth maintains discretion for timing of transactions as well as the
holdings of model portfolios when a specific security may not be available or advantageous to a Client.
Sub-Advisory and Operational Services
Simplicity Wealth also provides sub-advisory and operational services to Clients through sub-advisory relationships with other
third-party Advisers. In these arrangements, an Adviser executes a Sub-advisory Agreement or an Operations Service
Agreement (collectively “Service Agreements”) with Simplicity Wealth, in which we agree to provide the Adviser with
investment management, investment advisory and/or operational services on behalf of such Adviser’s Clients. As per the
terms of the Service Agreements, the Client will enter into a written agreement with the Adviser pursuant to which the Client
will authorize the Adviser to utilize the services of a third-party sub-advisor such as Simplicity Wealth. When servicing a
Client’s account in coordination with a third-party Adviser, the Service Agreements will specify those services to be provided
by Simplicity Wealth internally versus those services to be provided by the third-party Adviser as well as any fees to be
charged and collected for the specified services. In general, Simplicity Wealth provides these services through the TAMP.
As described above, these sub-advised clients will enter into an advisory agreement directly with the third-party Adviser, and
we will have no direct client relationship with the Adviser’s Clients. The third-party Adviser is responsible for providing Clients
with a copy of the Firm’s brochure and establishing the fee that Clients pay, which will be specified in the signed advisory
agreement. The Firm receives a portion of the total advisory fees for its advisory services, as agreed upon in the Service
Agreement we have with the third-party Adviser. An investment adviser representative affiliated with the third-party Adviser
will assist Clients in selecting from the Firm’s managed portfolio and specialty solution offerings that align with the Client’s
investment objectives, risk tolerance, and time horizon. This investment adviser representative will also provide Clients with
initial and ongoing information and education concerning the investments selected. As a subadvisor, we generally maintain
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discretionary authority to determine the timing of transactions as well as the holdings of model portfolios when a specific
security may not advantageous to a Client. The third-party Adviser should meet with Clients periodically to discuss these
allocation changes and, at all times, maintains discretion in the selection of Client’s investments or model portfolios.
Data Aggregation
Simplicity Wealth offers optional Data Aggregation Services which enables Clients to monitor accounts that are not managed
by Simplicity Wealth. Using Data Aggregation Services, Clients can examine their holdings, allocation of assets and portfolio
performance across the full spectrum of a specific Client’s in-house and held away accounts. Through use of a data
aggregation system, Simplicity Wealth has the ability to generate performance reporting which is calculated according to
industry standards and can be applied to each account or combination of several related accounts on a household or family
level.
Software Tools
Simplicity Wealth provides a customizable asset management software program through a web-enabled platform ("Software
Program") primarily to other Advisers, who in turn, provide the Software Program to their investment adviser representatives.
Simplicity Wealth may also license the Software Program to certain Advisers. The Software Program is typically customized
and may be private labeled in the name of the applicable Adviser. Advisers can provide the Software Program to investment
adviser representatives, who can use it to manage the accounts of their respective Clients, which typically includes
individuals and their related trusts or estates. The Software Program provides Advisers the ability to offer their Clients a
separate accounts program, various asset allocation programs and account reporting services. Simplicity Wealth also allows
Advisers to combine these programs to suit the needs of their Clients.
Back-Office Processing/Billing Services
Simplicity Wealth provides back-office functions on behalf of Advisers including daily account reconciliation and asset
transfers. Simplicity Wealth uses electronic data feeds from trading/clearing/custodial firms to streamline the account
reconciliation process. Simplicity Wealth uses billing software to automate billing for Advisers, which can accommodate a
billing structure to include house-holding of accounts to capture scaling rates, several layers of combined accounts and
assets, flat fee billing, credits, advance or arrear billing, daily weighted average billing and event triggered billing.
Assets Under Management (AUM) and Assets Under Advisement (AUA)
On January 31, 2024, Simplicity Wealth’s total assets under management (“AUM”) are $3,166,555,578. Discretionary assets
under management are $3,094,668,425 and non- discretionary assets under management are $71,887,153. Assets under
advisement as of January 31, 2024, are $2,883,626,037.