Overview

Assets Under Management: $240 million
Headquarters: SAN DIEGO, CA
High-Net-Worth Clients: 60
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (SIMPLIFI, INC. - FORM ADV PARTS 2A & 2B)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.25%
$1,000,001 $3,000,000 0.70%
$3,000,001 $5,000,000 0.60%
$5,000,001 $10,000,000 0.50%
$10,000,001 $20,000,000 0.40%
$20,000,001 and above 0.30%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $12,500 1.25%
$5 million $38,500 0.77%
$10 million $63,500 0.64%
$50 million $193,500 0.39%
$100 million $343,500 0.34%

Clients

Number of High-Net-Worth Clients: 60
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 48.53
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 557
Discretionary Accounts: 557

Regulatory Filings

CRD Number: 154900
Last Filing Date: 2024-03-13 00:00:00
Website: HTTPS://WWW.LINKEDIN.COM/COMPANY/SIMPLIFI-RETIREMENT-PLANNING-/

Form ADV Documents

Primary Brochure: SIMPLIFI, INC. - FORM ADV PARTS 2A & 2B (2025-03-28)

View Document Text
ITEM 1 - COVER PAGE CRD No. 3140614 FORM ADV 2, PART 2A DISCLOSURE BROCHURE SimpliFi, Inc., 9666 Businesspark Avenue, Suite #111, San Diego, CA 92131 Phone: (858) 695-6600 | Fax: (877) 692-9700 www.retiremeasap.com Part 2A of Form ADV (the “Brochure”) provides information about the qualifications and business practices of SimpliFi, Inc. If you have any questions about this brochure’s contents, please contact us at 858 -695-6600 and/or info@retiremeasap.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. SimpliFi, Inc. is a registered investment adviser with the U.S. Securities and Exchange Commission, however, such registration does not imply a certain level of skill or training and no inference to the contrary should be made. Additional information about SimpliFi is available on the SEC’s website at www.adviserinfo.sec.gov. ITEM 1: COVER PAGE ITEM 2: MATERIAL CHANGES The purpose of this page is to inform you of any material changes to this brochure. If you are receiving this brochure for the first time this section may not be relevant to you. SimpliFi, Inc. (“SimpliFi”) reviews and updates our brochure at least annually to confirm that it remains current. We made the following material changes to our brochure with the annual update, dated March 28, 2025: Item 4 – Advisory Business and Item 5 – Fees and Compensation: • We added Inherited IRA Assistance to our service offerings. Item 5 – Fees and Compensation: • We updated our fee schedule. 2 ITEM 3: TABLE OF CONTENTS Item Number Page FORM ADV 2, PART 2A DISCLOSURE BROCHURE ............................................................................................................................ 1 ITEM 1: COVER PAGE ........................................................................................................................................................................... 1 ITEM 2: MATERIAL CHANGES .............................................................................................................................................................. 2 ITEM 3: TABLE OF CONTENTS ............................................................................................................................................................ 3 ITEM 4: ADVISORY BUSINESS ............................................................................................................................................................. 4 ITEM 5: FEES AND COMPENSATION .................................................................................................................................................. 6 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .................................................................................. 9 ITEM 7: TYPES OF CLIENTS .................................................................................................................................................................. 9 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS ................................................................... 9 ITEM 9: DISCIPLINARY INFORMATION ............................................................................................................................................. 11 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................................................................... 12 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ............ 12 ITEM 12: BROKERAGE PRACTICES .................................................................................................................................................. 12 ITEM 13: REVIEW OF ACCOUNTS ...................................................................................................................................................... 16 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ...................................................................................................... 17 ITEM 15: CUSTODY ............................................................................................................................................................................. 17 ITEM 16: INVESTMENT DISCRETION ................................................................................................................................................. 17 ITEM 17: VOTING CLIENT SECURITIES ............................................................................................................................................. 17 ITEM 18: FINANCIAL INFORMATION ................................................................................................................................................. 18 FORM ADV 2, PART 2B BROCHURE SUPPLEMENT ......................................................................................................................... 19 3 ITEM 4: ADVISORY BUSINESS SimpliFi, Inc. ("SimpliFi" or the/our "Firm") is a San Diego, California-based investment advisory firm founded in 2010 (previously doing business as Sigdestad Financial under unaffiliated broker-dealers and registered investment advisers since 2005). We are registered with the Securities and Exchange Commission ("SEC") as an investment adviser and are organized under the laws of the State of California as a corporation. We offer customized investment management and financial planning services to individuals and high-net-worth individuals. Some of the investment instruments we advise our clientele on include, among other things, mutual funds, exchange-traded funds ("ETFs"), stocks, and bonds. No minimum is required to open and maintain an investment advisory account with our Firm. We periodically send newsletters, e-mails, and other correspondence of general market and retirement-related information and items of interest to our clients and prospective clients on a complimentary basis. In addition, we hold complimentary informational seminars for our clients and prospective clients geared toward retirement and investment needs. Our Firm is 100% owned by Eric A. Sigdestad. Mr. Sigdestad also serves as our CEO. We offer clients financial planning and investment management services described below. A client can engage us for financial planning services and/or investment advisory services. Investment Advisory Services At the inception of the relationship, we will conduct an initial interview with each client (either in person, by teleconference, or via a questionnaire) to determine the client's financial circumstances, goals, risk tolerance, and other relevant information. We then use this information to make investment recommendations based on the client's investment objectives. We offer investment advisory services on a discretionary basis. This means that the client grants us trading authority to buy, sell, and trade in stocks, bonds, mutual funds, index funds, ETFs, structured products and other securities and/or contracts relating to the same within the client's account. We will monitor and measure investment results for the client, which will be further discussed with the client at periodic intervals (typically, not less than annually). Before engaging us to provide investment advisory services, each client must enter into a written Investment Advisory Agreement, which will describe the management fees to be charged and the terms and conditions under which we will render our services. Upon execution of the Investment Advisory Agreement, we will work with the client to establish or transfer investment accounts so that we can manage the client's portfolio. We periodically will rebalance or adjust client accounts under its management. We will continue to provide services until terminated by the client or by our Firm in accordance with the provisions outlined within the agreement. Investment advice is based on the client's financial situation at the time the services are provided and is based on financial information disclosed by the client. If the client experiences any significant changes to his/her financial or personal circumstances, it is the client's responsibility to timely notify us so that such information can be used in managing the client's portfolio. Clients should refer to our Investment Advisory Agreement for important additional information. We will use reasonable efforts to comply with any investment guidelines, including any reasonable restrictions on investing in certain securities or types of securities requested by the client. As an accommodation to our clients, we also provide discretionary asset management services for certain non-retirement custodial accounts such as UTMA/UGMA and 529 plan portfolios (referred to herein as "custodial accounts"), typically at no charge to the client, investing solely in mutual funds held directly on a mutual fund sponsor's platform. We will allocate the custodial account assets among the mutual funds available within the platform, taking into consideration the objectives of the client. These custodial accounts will only be rebalanced, if needed, once or twice per year, following 4 limitations imposed by the mutual fund sponsor. Financial Planning Services Our Financial Planning Services are designed to provide the client with an analysis of steps the client may wish to consider within their investment accounts and financial situation to help achieve the client's financial goals and objectives. To begin this process, we generally will interview the client to gather the necessary information to assess the client's current financial situation. Based upon this initial interview, we will request that the client provide us with the necessary documentation to assess the client's current and anticipated investment positions and financial objectives. The client has the discretion to accept or reject our recommendations contained in the client's financial plan. We will rely upon the information provided by the client. The client is responsible for providing updated, accurate, and complete information. When appropriate, all clients are urged to work with his/her attorney and tax advisor to implement the financial plan's recommendations. Inherited IRA Assistance Upon the death of a SimpliFi client, the individual(s) inheriting assets held at Charles Schwab have two service options: Option A: Do-It-Yourself Inheritance • We will not provide any advisory services, account transfer support, or ongoing assistance. • The beneficiary will work directly with Charles Schwab to complete the account transition. • We will charge no fees for this option. Option B: Full-Service Inheritance We offer full assistance with the transition process, including but not limited to the following: • Coordination with Charles Schwab • Preparation and submission of transfer paperwork • Guidance on beneficiary distribution options • Up to two 30-minute consultations Note: We do not act in a fiduciary or advisory capacity under Option A. If the beneficiary wants to remain a client beyond the transition period for Option A or B, ongoing advisory fees will apply according to the terms of a separate Investment Advisory Agreement. Acknowledgment Beneficiaries will be required to sign a service selection form to confirm their chosen option and acknowledge the associated fees or limitations. We describe the fees charged for all of our services under Item 5 - Fees and Compensation, below. How We Use Artificial Intelligence Artificial Intelligence Artificial Intelligence (AI) is the simulation of human intelligence in machines designed to think and learn like humans. AI encompasses a range of technologies that enable systems to perform tasks such as recognizing speech, making decisions, and understanding complex ideas. We utilize AI in an effort to enhance our services and improve operational efficiency. By integrating AI into our processes, we aim to stay at the forefront of technological innovation while maintaining a strong commitment to ethical practices and data privacy. We have incorporated artificial intelligence (AI) into its practice to enhance service delivery and improve decision-making. Our use of AI is primarily operational - we do not use the technology to directly formulate investment recommendations or select investments for client accounts. Examples of the way we use AI include: • Automation of Administrative Tasks: AI can automate routine tasks such as data entry, compliance checks, and 5 report generation. • Regulatory Compliance: AI tools can monitor transactions and communications to assist us in complying with regulatory requirements, with the aim of reducing the risk of violations and associated penalties. • Notetaking: We use AI for real-time note-taking during many interactions to enhance accuracy, efficiency, and productivity. The AI tools we use are cable of transcribing spoken content, generating summaries, and identifying key takeaways from calls and/or meetings. • Marketing Content: We use AI tools to support the development and review of marketing materials, including newsletters, blog posts, and webinar content. These tools assist with tasks such as grammar and spell checking, content generation, and proofreading to improve clarity and consistency. While we believe that AI offers significant advantages, we maintain human oversight to confirm that AI-driven functions align with our clients’ best interests and our fiduciary requirements. Should a client have any questions or concerns, we remain available to consult further. Assets Under Management We manage client assets in discretionary accounts on a continuous and regular basis. As of December 31, 2024, the total amount of assets under our management was $251,531,387. ITEM 5: FEES AND COMPENSATION Investment Advisory Services Unless otherwise negotiated and memorialized in the client's Investment Advisory Agreement, our management fees are charged quarterly and are based on the market value of the assets under management ("AUM") in the client's account(s), including cash and cash equivalents, as of the close of business on the last business day of the previous calendar quarter based on the following tiered schedule: Assets Under Management Annual Advisory Fee First $1,000,000 1.25% $1,000,001 - $3,000,000 0.70% $3,000,001 - $5,000,000 0.60% $5,000,001 - $10,000,000 0.50% $10,000,001 - $20,000,000 0.40% $20,000,001 + 0.30% Accordingly, the first $1,000,000 in the account will have management fees charged at 1.25% per year, the next $2,000,000 in the account will be charged at 0.70% per year, and so on consistent with the table above. Effective March 28, 2025, we updated our fee schedule for new clients. However, existing clients will continue to pay fees based on the previous fee schedule agreed upon at the time of their engagement with us. As a result, some clients are charged different rates depending on when they entered an advisory agreement with us. We do not retroactively adjust client fees on an existing fee schedule unless otherwise agreed upon in writing. For details on the fee arrangement, the client should review their investment advisory agreement or contact us at (858) 695-6600. Our management fees are calculated and charged quarterly in advance. Our management fees are automatically debited from the client's account(s) held by the Custodian, as soon as practical following the last business day of each calendar quarter. If investment advisory services begin in the middle of the billing period, the prorated management fee for the initial billing period is billed in arrears at the same time as the next full billing period's fee is billed. If a deposit in excess of 6 $10,000 occurs during a billing period after the fee calculation, the fee for the billing period will be recalculated at the end of the billing period and the Firm will bill the client a second fee pro-rata, in arrears, on the additional deposits. If a withdrawal in excess of $10,000 occurs during a billing period after the fee calculation, the fee for that billing period will be recalculated at the end of the billing period and the client will be refunded the pro-rata fee that was attributable to the amount of the withdrawal. The Custodian will send client statements at least quarterly, showing all payouts from the account, including the management fee, if deducted from the account. We will household client Accounts to calculate breakpoints; we define a household as all individuals living at the same residential address. Consequently, our management fees are calculated based on the breakpoint achieved (if any) based on the combined assets of all client Accounts within a household. Each client account will typically be billed individually for its respective share of fees owed to us unless instructed otherwise. If our services are terminated mid-quarter, any paid, unearned management fees will be promptly refunded to the client. The number of days the account was managed during the quarter until termination is used to determine the percentage of the management fee earned. Custodial Account Platform Management We do not charge fees for the management of custodial account assets. However, clients should be aware that the mutual fund sponsor will charge separate fees, including, but not limited to, initial setup fees and annual maintenance fees. As the custodial accounts invest in mutual funds, clients will also pay the fund a management fee and sub-transfer agency fee. We have no control over the level of these fees and do not receive any portion of these fees or charges. To the extent the custodial account is a 529 plan account, Clients should also be aware that the tax considerations related to purchasing a 529 plan can be complex. For example, if the client’s state of residence offers any tax benefit for purchasing an in-state 529 plan, the client would be foregoing those tax benefits by purchasing an out-of-state 529 plan. Please note that California does not currently offer any state tax benefits related to 529 plans. If a client is a resident of a state other than California and realizes state tax benefits are important to the client, the client should consult with their tax advisor or the 529 plan sponsor for additional information. Financial Planning Services We charge on an hourly basis for financial planning at a rate of $400 per hour. On certain occasions, we will also consult with clients on a fixed/flat fee basis paid at a frequency and rate based on the scope and complexity of the services as mutually agreed upon by us and the client. We generally provide an estimate of the number of hours anticipated for the services requested and will remain in close consultation with the client should the number of estimated hours need to be adjusted (e.g., for additional or reduced services requested during the engagement). The entire fee is due upon the rendering of services. We consider our financial planning services to be complete, and the agreement terminated upon delivery of the agreed upon services. In the event that either the client or we wish to terminate the agreement before the completion of the services, either party may terminate the agreement at any time by providing written notice to the other party. Upon notice of termination, we will provide the client with an invoice for services provided through the date of termination. Inherited IRA Assistance We offer Inherited IRA Assistance for a fixed fee of $2,000, which we may reduce or waive at our discretion. This fee is due and payable upon completion of the service. Other Fees and Costs In addition to the management fee clients pay to us, clients will pay certain transaction charges for trade execution. These 7 transaction charges are paid to the Custodian, vary based on the type of transaction (e.g., stocks, bonds, ETFs, mutual funds, etc.), and are communicated to clients by us at the time clients establish an account. We do not receive any portion of the transaction charges, and the Custodian reserves the right to change the transaction charges. The transaction charges assessed by the Custodian are in some cases lower than the charges customarily imposed by the Custodian when processing similar transactions for similar accounts. This is because we entered into an arrangement based on the scope of business in which we engage with the Custodian, including the amount of our client assets with the Custodian. This presents an incentive for us to recommend that clients use a specific custodian and executing broker/dealer for their account so that all our clients continue to receive favorable pricing. We believe this arrangement benefits clients because the transaction charges may be lower than they would be normally. As a result, we believe that using the recommended Custodian to execute transactions for client accounts is consistent with our duty to obtain best execution. While we do not actively include mutual funds in portfolios, clients may incur certain charges or fees imposed by third parties other than us if a client chooses to invest in mutual funds. Such charges can include but are not limited to mutual fund 12b-1 fees and certain deferred sales charges on previously purchased mutual funds transferred into the account (s). Information regarding fees or charges assessed by mutual funds held in client accounts is available in the appropriate prospectus. Clients are also responsible for the fees and expenses charged by custodians, including, but not limited to, custodial fees, IRA and Qualified Retirement Plan fees, the interest charged on margin borrowing, bank service fees, the interest charged on debit balances, "spreads" imposed by brokers and dealers representing implicit transaction costs, commissions, and transfer taxes. Additional Information Concerning Fees Either party can terminate the Investment Advisory Agreement at any time by providing written notice to the other party. In accordance with the terms of the client agreement, upon termination, the client will receive a pro-rata refund of any unearned management fees. The client will incur charges for bona fide advisory services rendered to the point of termination, and such management fees will be due and payable by the client. No interest will be added to refunds under these circumstances. A client could invest in the same investments directly, without our services. In that case, the client would not receive the services we provide, which are designed, among other things, to assist the client in determining which investments are most appropriate for the client's financial situation and objectives. Accordingly, clients should review both the fees charged by the Custodian and the fees we charge to fully understand the total fees to be paid and evaluate the advisory services being provided. Clients should be aware that the receipt of compensation itself creates an inherent conflict of interest and could affect our judgment when making recommendations. Retirement Rollovers There is a conflict of interest for individuals that currently invest in an employer-sponsored retirement plan or individual retirement account that are considering a roll-out of assets from a retirement plan or account. A conflict of interest exists because we will be compensated only if the individual rolls over the proceeds into an IRA that is then managed by us. As a result, it can be construed that we have a financial incentive to recommend one option over another. Therefore, the individual should include in his/her decision-making process a thorough review of all options available; for example, (i) remain invested in the current retirement plan or account (if available), (ii) transfer assets to a new employer-sponsored retirement plan (if available), (iii) transfer assets to an IRA with a financial institution, or (iv) withdraw assets directly, which would be subject to federal and applicable state and local taxes and possibly subject to the IRS penalty of 10% 8 depending upon the age of the individual. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance-based fees (i.e., fees calculated based on a share of capital gains on or capital appreciation of the client's assets or any portion of the client's assets). ITEM 7: TYPES OF CLIENTS We provide investment advice regarding investments and planning for individuals and high net-worth individuals. No minimum amount is required to open and maintain an investment advisory account. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS Methods of Analysis, Sources of Information, and Investment Strategies When we provide investment advice, the client's current financial situation, needs, goals, objectives, and tolerance for risk are first evaluated. In addition to several in-person or telephonic interviews with a new client, the client generally completes a questionnaire to assist us in formulating the client's investment objectives. We may request copies of certain client documents to assist us in conducting a more complete evaluation of the client's objectives and to devise an investment objective. We will reasonably request some of the following documents: insurance policies, wills, tax returns, and other documents depending upon the client's circumstances, to permit a complete financial evaluation. We will not be required to verify any information obtained from the client, client's attorney, accountant, or other professionals. We design and manage investment portfolios tailored to meet the client's specific needs. We believe that asset allocation and portfolio diversification are crucial elements in seeking long-term investment success. The appropriate asset allocation strategy is derived by assessing the goals and circumstances of each client and selecting the portfolio that we believe best suits their level of risk tolerance, overall investment objective, and time horizon. Asset level and sector classifications are sourced from third-party research providers, for example, the Schwab research platform and Morningstar. The asset allocation mix of each investment strategy is based on past historical risk-adjusted asset class performance dating back to 1970 sourcing historical data. In addition to the use of ETFs (exchange-traded funds) in specific asset class categories, portfolios are tactically up-weighted or down-weighted. Weighting regarding asset classes is based on macro-economic inputs to account for the direction of interest rates, tax law changes, and/or currency fluctuations. World allocation funds may also be utilized to facilitate an element of country rotation. Third-party research is utilized to select investments in each category. Past historical performance of each fund is reviewed over a 3, 5, 10, and inception-to-date basis. Investments should historically be above the median in performance relative to their peers and must have consistently outperformed their respective benchmarks in both up and down markets. Funds with a longer track record of performance (at least 5 years) are preferred. When a 5-year track record is not available for a fund, we may review similar investments manufactured by that same Firm for guidance (e.g., If a firm that manages a Separately Managed Account were to roll out a mutual fund designed to mimic the SMA's investment philosophy, portfolio holdings, trading, etc.). Fund family, manager tenure, current fund assets and historic asset growth, portfolio holdings, asset allocation, expense ratio, portfolio turnover, risk-adjusted return, alpha, beta, standard deviation of returns, up/down performance, correlation among funds, yield, and portfolio overlap are all considered during the selection of funds for use in portfolios. Investments are periodically monitored for performance, personnel or organization change, style drift, and/or rating 9 changes. If changes have occurred with any of the underlying investment strategies, the investment will be placed under "review" for a specified period before any action is taken. However, if significant changes have occurred within the investment strategy, changes can be made immediately. This is consistent with the disciplined and unemotional approach utilized during our investment selection process. Past performance is not a guarantee of future results. Risk of Loss Our investment recommendations are subject to various markets, geographical, currency, economic, political, and business risk, and such investment decisions may not always be profitable. Clients should be aware that there may be a loss or depreciation to the value of their account, which clients should be prepared to bear. There can be no assurance that a client's investment objectives will be obtained and no inference to the contrary is being made. The primary risks involved in the securities we recommend may include, among others: • Stock market risk, which is the chance that stock prices overall, will decline. The market value of equity securities will generally fluctuate with market conditions. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend to fluctuate over the short term because of factors affecting the individual companies, industries, or the securities market as a whole. Equity securities generally have greater price volatility than fixed-income securities. • • Sector risk, which is the chance that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall stock market. Daily fluctuations in specific market sectors are often more extreme than fluctuations in the overall market. Issuer risk, which is the risk that the value of a security may decline for reasons directly related to the issuer, such as management performance, financial leverage, and reduced demand for the issuer's goods or services. • Non-diversification risk, which is the risk of focusing investments in a small number of issuers, industries or foreign currencies, including being more susceptible to risks associated with a single economic, political, or regulatory occurrence than a more diversified portfolio might be. • Value investing risk, which is the risk that value stocks may not increase in price, may not issue the anticipated stock dividends, or may decline in price, either because the market fails to recognize the stock's intrinsic value, or because the expected value was misgauged. If the market does not recognize that the securities are undervalued, the prices of those securities might not appreciate as anticipated. They also may decline in price even though in theory they are already undervalued. Value stocks are typically less volatile than growth stocks but may lag behind growth stocks in an up market. • Smaller company risk, which is the risk that the value of securities issued by a smaller company may go up or down, sometimes rapidly and unpredictably as compared to more widely held securities. Investments in smaller companies are subject to greater levels of credit, market, and issuer risk. • • Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities may result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests exclusively in securities of U.S. companies. Investments in emerging markets are generally more volatile than investments in developed foreign markets. Interest rate risk, which is the chance that bond prices overall will decline because of rising interest rates. Similarly, the income from bonds or other debt instruments may decline because of falling interest rates. • Credit risk, which is the chance that a bond issuer will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer's ability to make such payments will cause the price of that bond to decline. • Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying securities it is designed to track. ETFs are 10 also subject to secondary market trading risks. In addition, an ETF may not replicate the performance of the index it seeks to track for several reasons, including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the secondary market, or discrepancies between the ETF and the index with respect to the weighting of securities or number of securities held. • Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are the senior unsecured debt of the issuing bank and are subject to the credit risk associated with that issuer. The credit risk exists whether or not the investment held in the account offers principal protection. The credit worthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal protection. In addition, the principal guarantee relates to the nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero-coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. • Management risk, which is the risk that the investment techniques and risk analyses we apply applied may not produce the desired results and that legislative, regulatory, or tax developments, may affect the investment techniques available to our Firm. There is no guarantee that a client's investment objectives will be achieved. • Epidemics, Pandemics, Outbreaks of Disease, and Public Health Issues. Our business activities could be materially adversely affected by pandemics, epidemics, viruses, and outbreaks of disease in Asia, Europe, North America, and/or globally or regionally, such as COVID-19, Ebola, H1N1 flu, H7N9 flu, H5N1 flu, SARS, and/or other major public health issues. Any occurrence or recurrence (or continued spread) of an outbreak of any kind of epidemic, pandemic, virus, disease, or major public health issue could cause a slowdown in the levels of economic activity generally (or cause the global economy to enter into a recession or depression), which would adversely affect the business, financial condition, and our operations. Prior to entering into an agreement with us, a client should carefully consider: • committing to investment management only those assets that the client believes will not be needed for current purposes and that can be invested on a long-term basis, usually a minimum of three to five years; that volatility from investing in global capital markets can occur; and that over time the client's assets may fluctuate and at any time be worth more or less than the amount invested. • • We do not represent, guarantee, or imply that the services or methods of analysis employed can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. Past performance is no guarantee of future results. ITEM 9: DISCIPLINARY INFORMATION Registered investment advisers such as our Firm are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of our Firm or the integrity of our management. We do not have any material legal or disciplinary events to discuss. 11 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS We do not offer any other services or have any affiliates in the financial industry. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING We have adopted a Code of Ethics ("Code") in compliance with Rule 204A-1 under the Investment Advisers Act of 1940, as amended. We are a fiduciary and have a duty of utmost good faith to act solely in the best interests of clients. Clients entrust us with their investments and financial future, which in turn places a high standard of conduct and integrity. Fiduciary duty compels all employees to act with the utmost integrity in all of the dealings. Because our investment professionals and associated persons can transact in the same securities for their personal accounts as they may buy or sell for client accounts, it is important to mitigate conflicts of interest. To that end, we have adopted a standard of conduct for all of our supervised persons in the form of a Code of Ethics ("Code"), which all SimpliFi-associated persons must follow. This Code provides personnel with guidance in their ethical obligations regarding their personal securities transactions and fiduciary duties, formulating the basis of all of our client dealings. Specifically, the Code requires personnel to obtain written pre-approval of certain securities, report personal trades and holdings, and prohibit certain trades in certain circumstances (e.g., insider trading). The Code also contains procedures for reporting violations and enforcement. The Code is distributed to personnel for review initially upon hire and when amended. We will provide a copy of our current Code of Ethics to any client or prospective client upon request. Clients are advised that they are not required to affect any securities transactions we may recommend because of a Financial Planning engagement and may use any broker/dealer they choose to implement recommendations we made. Clients are also under no obligation to act upon any recommendations we may make because of a Financial Planning engagement. It is our policy not to enter into any principal transactions or agency cross transactions on behalf of client accounts. Principal transactions occur when an adviser, acting as principal for its own account, buys securities from or sells securities to any advisory client. Agency cross transactions occur where a person acts as an investment adviser in relation to a transaction in which the adviser, or an affiliate of the adviser, acts as a broker for both the advisory client and for another person on the other side of the transaction. Should we ever decide to affect cross-trades between client accounts, it will comply with the provisions of Rule 206(3) of the Advisers Act. ITEM 12: BROKERAGE PRACTICES Custodian and Brokers We Use Clients must maintain assets in an account at a "qualified custodian," generally a broker-dealer or bank. With the exception of custodial accounts, we require our clients to use Charles Schwab & Co., Inc. (Schwab), a registered broker- dealer, member SIPC, as the qualified Custodian. We are independently owned and operated and unaffiliated with Schwab. Schwab will hold client assets in a brokerage account and buy and sell securities when we instruct them to do so. Custodial account assets are held at the Custodian selected by the mutual fund sponsor and not by our Firm. While we require that our clients use Schwab as custodian/broker, the client must decide whether to do so and open accounts with Schwab by entering into account agreements directly with Schwab. We do not open accounts for clients, although it might assist them in doing so. Not all advisors require their clients to use a particular broker-dealer. How We Select Brokers/Custodians We seek to select a custodian/broker who will hold client assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, 12 including, among others: 1. Combination of transaction execution services and asset custody services (generally without a separate fee for custody) 2. Capability to execute, clear, and settle trades (buy and sell securities for client accounts) 3. Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payments, etc.) 4. Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.) 5. Availability of investment research and tools that assist us in making investment decisions 6. Quality of services 7. Competitiveness of the price of those services (commission rates, other fees, etc.) and willingness to negotiate the prices 8. Reputation, financial strength, and stability 9. Prior service to our Firm and our other clients 10. Availability of other products and services that benefit us, as discussed below (Products and Services Available to Us from Schwab) Client Brokerage and Custody Costs For our clients' accounts that Schwab maintains, Schwab generally does not charge separately for custody services. However, Schwab receives compensation by charging transaction charges or other fees on trades that it executes or that settle into clients' Schwab accounts. We have entered into an arrangement with Schwab for certain transaction charge pricing. This favorable pricing to the client remains in place as long as we meet certain conditions in terms of maintaining a certain level of activity and assets with Schwab. Please see the detailed discussion of the conditions and implications of the arrangement in Item 5, Fees and Compensation. In addition to commissions, Schwab charges a flat dollar amount as a "prime broker" or "trade away" fee for each trade that is executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into a client's Schwab account. These fees are in addition to the commissions or other compensation the client pays the executing broker-dealer. Because of this, in order to minimize trading costs, we have Schwab execute trades for client accounts. We have determined that having Schwab execute trades is consistent with our duty to seek the "best execution" of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see How We Select Brokers/Custodians). Products and Services Available to Us from Schwab Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab's business serving independent investment advisory firms like ours. They provide us and our clients with access to their institutional brokerage, trading, custody, reporting, and related services, many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients' accounts; others help us manage and grow our business. Schwab's support services are generally available on an unsolicited basis (we do not have to request them). The following is a more detailed description of Schwab's support services: Services That Benefit Our Clients Schwab's institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access, or that would require a significantly higher minimum initial investment by our clients. Schwab's services described in this paragraph generally benefit our clients and their accounts. 13 Services That May Not Directly Benefit Our Clients Schwab also makes other products and services available to us that benefit our Firm but may not directly benefit our clients or their accounts. These products and services assist us in managing and administering our clients' accounts. They include investment research, both Schwab's own and that of third parties. We may use this research to service all or a substantial number of our client's accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: 1. Provide access to client account data (such as duplicate trade confirmations and account statements) 2. Facilitate trade execution and allocate aggregated trade orders for multiple client accounts 3. Provide pricing and other market data 4. Facilitate payment of our fees from our clients' accounts 5. Assist with back-office functions, recordkeeping, and client reporting Services That Generally Benefit Only Our Firm Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: 1. Educational conferences and events 2. Consulting on technology, compliance, legal, and business needs 3. Publications and conferences on practice management and business succession 4. Access to employee benefits providers, human capital consultants, and insurance providers Schwab can provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party's fees. Schwab may also provide us with other benefits, such as occasional business entertainment of its personnel. Our Interest in Schwab's Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions. We believe the selection of Schwab as Custodian and broker is in the best interests of our clients. We primarily support our selection of Schwab by the scope, quality, and price of Schwab's services (see How We Select Brokers/Custodians, above), not just Schwab's services that benefit us. Research and Other Benefits "Bundled Services" We may receive from Schwab, without cost (or at a discount), support services and/or products that benefit us but may not directly benefit our clients' accounts. Schwab makes available products and services that might be used to service all or some substantial number of our accounts. Schwab makes available products and services that assist us in managing and administering clients' accounts, including software and other technology that: facilitate payment of our fees from our clients' accounts; and 1. provide access to client account data (such as trade confirmations and account statements); 2. facilitate trade execution and allocate aggregated trade orders for multiple client accounts; 3. provide research, pricing, and other market data; 4. 5. assist with back-office functions, recordkeeping, and client reporting. Schwab also offers other services intended to help us manage and further develop our business enterprise. These 14 services may include: 1. compliance, legal and business consulting; 2. publications and conferences on practice management and business succession; and 3. access to employee benefits providers, human capital consultants, and insurance providers. Schwab may make available, arrange, and/or pay third-party vendors for the types of services provided to us. Schwab can discount or waive fees it would otherwise charge for some of these services, reimburse us for the cost of conferences or related expenses, or pay all or a part of the fees of a third-party providing these services to us. Schwab may also provide other benefits, such as educational events or occasional business entertainment for our personnel. As part of our fiduciary duty to clients, we endeavor at all times to put the interests of our clients first. Clients should be aware, however, that the economic benefits that we receive, or that our personnel receives, in and of itself creates a conflict of interest and may indirectly influence our recommendation of Schwab for custody and brokerage services. Directed Brokerage We will not allow clients to direct us to use a specific broker-dealer to execute transactions. Clients must use the broker- dealer that we recommend. Not all investment advisers require their clients to trade through specific brokerage firms. By requiring clients to use Schwab, we believe we are able to manage the client's portfolio, achieve favorable execution of client transactions, and overall lower the costs to the portfolio more effectively. Since we require our clients to maintain their accounts with Schwab, it is also important for clients to consider and compare the significant differences between having assets custodied at another broker-dealer, bank, or another custodian prior to opening an account with us. Some of these differences include but are not limited to total account costs, trading freedom, transaction fees/commission rates, and security and technology services. Clients with 401(k) accounts are not required to use Schwab and may appoint a custodian of their choosing. Order Aggregation We generally aggregate orders for clients in the same securities in an effort to seek best execution, negotiate more favorable commission rates, and/or allocate differences in prices, commissions, and other transaction costs equitably among our clients. These are benefits of aggregating orders that we might not obtain if we placed those orders independently. Aggregating trades in like securities among client accounts as well as with accounts of our Firm and our personnel presents a potential conflict of interest as it could create an incentive to allocate more favorable executions to our own accounts or the accounts of our personnel. Our policies to address this conflict are as follows: 1. We disclose our aggregation policies in this brochure; 2. We will not aggregate transactions unless we believe that aggregation is consistent with our duty to seek best execution (which includes the duty to seek best price) for our clients. The trade also needs to be consistent with the terms of our investment advisory agreement with each client that has an account included in the aggregation; 3. We will not favor any account over any other account. This includes accounts of our Firm or any of our personnel. Each account in the aggregated order will participate at the average share price for all of our transactions in a given security on a given business day (per custodian). All accounts will pay their individual transaction costs; 4. Before entering an aggregated order, we will prepare a written statement (the “Allocation Statement”) specifying the participating accounts and how we intend to allocate the order among those accounts; 15 5. If the aggregated order is filled entirely, we will allocate shares among clients according to the Allocation Statement; if the order is partially filled, we will allocate it pro-rata according to the Allocation Statement; 6. Notwithstanding the foregoing, we may allocate the order differently than specified in the Allocation Statement if all client accounts receive fair and equitable treatment. (See also Item 12 – Brokerage Practices below.) In this case, we will explain the reasons for a different allocation in writing, which the CCO must approve no later than one hour after the opening of the markets on the trading day following the day the order was executed; 7. If an aggregated order is partially filled and we allocate it differently than the Allocation Statement specifies, no participating account may purchase or sell the security for a reasonable period following the execution of the block trade. This only applies when the participating account sells or receives more shares than it would have if the aggregated order had been completely filled; 8. Our books and records will separately reflect each aggregated order and the securities held by, bought, and sold for each client account; 9. Funds and securities of clients participating in an aggregated order will be deposited with one or more qualified custodians. Clients’ cash and securities will not be held collectively any longer than is necessary to settle the trade on a delivery versus payment basis. Following settlement, cash or securities held collectively for clients will be delivered out to the qualified custodian as soon as practical; 10. We do not receive additional compensation or remuneration of any kind as a result of aggregating orders; and 11. We will provide individual investment advice and treatment to each client’s account. While aggregating non-mutual fund trades may benefit clients by purchasing or selling in larger blocks, we do not aggregate mutual fund orders, as the daily price is the same for each investor. ITEM 13: REVIEW OF ACCOUNTS Investment Advisory Services Eric Sigdestad, our CEO, reviews all accounts on at least a quarterly basis. More frequent reviews might be necessary due to the client's individual circumstances, economic conditions, and other general factors affecting the performance of a client's portfolio. The frequency of reviews conducted with clients is determined by us based on multiple factors, which typically include but are not limited to the client's assets under management (AUM) with us and the complexity of portfolio services required. Clients will receive transaction confirmations and/or statements at least on a quarterly basis from their account custodians. We will also prepare and send its own quarterly account reports for all accounts except custodial accounts. Clients are encouraged to compare the account reports prepared by us with statements received from the qualified Custodian. Collectively, these reports will list clients' account holdings as well as interest and dividends for the reporting period. Financial Planning Typically, Financial Planning Service clients do not receive ongoing reviews, as these services tend to be performed at the request of the client under hourly and/or fixed fee arrangements, as described above in Item 5: Fees and Compensation. However, clients that wish to engage us for a review of their investments may do so upon request. The reporting Financial Planning clients receive is based on the services outlined in the planning agreement. Additional reporting may be arranged for at the request of the client and provided at our discretion. 16 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Compensation for Client Referrals We do not compensate any other party for client referrals. Schwab Support Products and Services We receive an economic benefit from Schwab in the form of the support products and services they make available to our Firm and other independent investment advisors whose clients maintain their accounts at Schwab. These products and services, how they benefit our Firm, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). We do not base particular investment advice, such as buying particular securities for our clients, on the availability of Schwab's products and services to us. ITEM 15: CUSTODY We are deemed to have custody of client funds because our Firm has the authority and ability to debit its fees directly from clients' accounts. To mitigate any conflicts of interest, all our client account assets will be maintained with an independent qualified custodian. We are also deemed to have custody of client's funds or securities when clients have standing authorizations with their Custodian to move money from a client's account to a third-party ("SLOA") and under that SLOA authorizes us to designate the amount or timing of transfers with the Custodian. The SEC has set forth a set of standards intended to protect client assets in such situations. We have established policies and procedures regarding these standards. Payment of our fees will be made by Schwab provided the client has given Schwab written authorization permitting the advisory fees to be deducted and paid directly from the client's account. We will not have access to client account assets for payment of fees without client consent in writing. Further, Schwab will deliver an account statement directly to the client, which will include all transactions that took place in the account during the period covered and reflect any investment management fees deducted and paid to us. Clients are encouraged to review their account statements for accuracy. ITEM 16: INVESTMENT DISCRETION For investment advisory account clients that have granted us discretion via the written client agreement, we will have discretionary authority over: • • the securities to be bought and sold; and the dollar amounts of the securities to be bought and sold; the broker-dealer through which transactions will be executed. However, our Firm's authority may be subject to conditions imposed by a client, an example of which may include where the client restricts or prohibits transactions in securities of a specific company or industry. ITEM 17: VOTING CLIENT SECURITIES It is our policy and practice to not vote proxies on behalf of our clients and, therefore, shall have no obligation or authority to act or render any advice with respect to the voting of proxies solicited by or with respect to issuers of securities held in a client's account. Consequently, the client retains the responsibility for receiving and voting all proxies for securities held within the client's account. We will not be deemed to have proxy authority solely because of providing advice or information about a particular proxy vote to a client. 17 We do not instruct or give advice to clients on whether to participate as a member of class action lawsuits and will not automatically file claims on the client's behalf. ITEM 18: FINANCIAL INFORMATION We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore are not required to provide, and have not provided, a balance sheet. We do not have any financial commitments that impair our ability to meet contractual and fiduciary obligations to clients and have not been the subject of a bankruptcy proceeding. 18 FORM ADV 2, PART 2B BROCHURE SUPPLEMENT March 28, 2025 ERIC SIGDESTAD, CFP® (CRD# 3140614) SimpliFi, Inc. 9666 Businesspark Avenue Suite #111 San Diego, CA 92131 Phone: (858) 695-6600 Fax: (877) 692-9700 www.retiremeasap.com This brochure supplement provides information about Eric Sigdestad supplements the SimpliFi, Inc.’s (“SimpliFi”) brochure. You should have received a copy of that brochure. Please contact our Chief Compliance Officer at 858- 695-6600 if you did not receive SimpliFi, Inc.’s brochure or if you have any questions about the contents of this supplement. Thank you. Additional information about the above-named individuals is available on the SEC’s website at www.adviserinfo.sec.gov. Item 1: Cover Page 19 ERIC SIGDESTAD, CFP® (CRD# 3140614) Item 2: Educational Background and Business Experience Born: 1976 Educational Background: • California State University, Fullerton, Fullerton, California, B.A. - Finance, 1998 Business Background: • SimpliFi, Inc. (formerly Sigdestad Financial, Inc.), Chief Executive Officer, August 2010 - Present • SimpliFi, Inc. (formerly Sigdestad Financial, Inc.), Chief Compliance Officer, August 2010 - January 2024 Eric Sigdestad holds the following professional designations: • CERTIFIED FINANCIAL PLANNER™ practitioner • CTEC Registered Tax Preparer (CRTP) Certified Financial Planner™ (CFP®) professional - attained January 2004 I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional, and I may use these and CFP Board’s other certification marks (the “CFP Board Certification Marks”). The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.CFP.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. 20 Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. • Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. CTEC Registered Tax Preparer (CRTP) - attained March 2025 The California Tax Education Council (CTEC) was established by the California State Legislature to promote competent tax preparation within the State of California. CTEC is a California non-profit Corporation that registers tax preparers, the second largest segment of tax preparation professionals serving California, following certified public accountants. Anyone who, for a fee, assists with or prepares a state or federal income tax return, excluding certified public accountants, attorneys, enrolled agents, enrolled actuaries, and certain financial institutions or their employees, must be registered with CTEC. CTEC is also charged with approving providers of tax education and maintaining and distributing to the public a list of those approved providers. To earn the CRTP designation, applicants must complete 60-hours (43 hours federal, 15 hours CA State, and 2 hours of ethics) of qualifying tax education from a CTEC Approved Provider, pass a background check and live scan, obtain a PTIN (Preparer Tax Identification Number) from the IRS, and purchase a $5,000 tax preparer bond. To maintain registration, all CRTPs must complete 20-hours (10 hours federal tax law, 3 hours federal tax update, 2 hours of ethics, and 5 hours CA State) of continuing tax education each year, maintain a valid PTIN, maintain a $5,000 tax preparer bond, and renew the registration by October 31st of each year. More information is available at https://www.ctec.org/. Item 3: Disciplinary Information Eric Sigdestad, as an investment adviser representative of SimpliFi, Inc., is required to disclose all material facts regarding any legal or disciplinary event that would be material to a client’s evaluation of him. Mr. Sigdestad has no applicable legal or disciplinary events required to be disclosed under this Item. Item 4: Other Business Activities Mr. Sigdestad’s only business is providing investment advice through SimpliFi, Inc. Item 5: Additional Compensation Mr. Sigdestad’s only compensation comes from his regular salary and ownership interest of SimpliFi, Inc. Item 6: Supervision Eric Sigdestad is the CEO and sole portfolio manager at SimpliFi, Inc. As such, Mr. Sigdestad is responsible for all advice provided to clients. Mr. Sigdestad can be contacted at (858) 695-6600 or eric@retiremeasap.com. 21 ® ® March 2024 WHAT DOES SIMPLIFI®, INC. DO WITH YOUR PERSONAL INFORMATION? FACTS Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The types of personal information we collect and share depend on the product or service you have with us. This information can include: What? • Social Security Number and Income • Assets and Account Balances • Investment Experience and Risk Tolerance When you are no longer our customer, we continue to share your information as described in this Notice. How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons SimpliFi®, Inc. chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does SimpliFi® share? Can you limit this sharing? Yes No For our everyday business purposes— Such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No For our marketing purposes— To offer our products and services to you For joint marketing with other financial companies No We don’t share No We don’t share For our affiliates’ everyday business purposes— Information about your transactions and experiences, or your creditworthiness For our affiliates to market to you No We don’t share For our non-affiliates to market to you No We don’t share Page 1 QUESTIONS? Call 858-695-6600 or retiremeasap.com Page 2 FACTS How does SimpliFi® protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We collect your personal information, for example, when you: How does SimpliFi® collect my personal information? • Open an account or enter into an investment advisory contract • Give us your income information or provide employment information • Tell us about your investment or retirement portfolio or give us your contact information We also collect your personal information from other companies. Federal law gives you the right to limit: • Sharing for affiliates’ everyday business purposes—information about your creditworthiness Why can’t I limit all sharing? • Affiliates from using your information to market to you • Sharing for non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing. Definitions Companies related by common ownership or control. They can be financial and nonfinancial companies. Affiliates • SimpliFi® does not share with affiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies. Non-affiliates • SimpliFi® does not share with non-affiliates so they can market to you A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Joint Marketing • SimpliFi® does not jointly market Other important information Information for California and Nevada Customers In response to a California law, we automatically treat accounts with California billing addresses as if you do not want to disclose personal information about you to non-affiliated third parties except as permitted by the applicable California law. We will also limit the sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us. Nevada law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling 1-831-759-6300. To obtain further information, contact the Bureau of Consumer Protection, Office of the Nevada Attorney General at 555 E. Washington Ave., Suite 3900, Las Vegas, NV 88101; phone 1-702-486-3132; email BCPINFO@ag.state.nv.us Page 2 QUESTIONS? Call 858-695-6600 or retiremeasap.com