EX-99.(I) 2 simplifyetf_exi.htm EXHIBIT (I)

 

Exhibit (i)

 

 

 

December 18, 2024

 

Simplify Exchange Traded Funds

10845 Griffith Peak Drive, 2/F

Las Vegas, NV 89135

 

Dear Board Members:

 

This letter is in response to your request for our opinion in connection with the filing of Post-Effective Amendment No. 131 to the Registration Statement, File Nos. 333-238475 and 811-23570 (the “Registration Statement”), of Simplify Exchange Traded Funds (the “Trust”).

 

We have examined a copy of the Trust’s Agreement and Declaration of Trust, the Trust’s By-Laws, the Trust’s record of the various actions by the Trustees thereof, and all such agreements, certificates of public officials, certificates of officers and representatives of the Trust and others, and such other documents, papers, statutes and authorities as we deem necessary to form the basis of the opinion hereinafter expressed. We have assumed the genuineness of the signatures and the conformity to original documents of the copies of such documents supplied to us as copies thereof.

 

Based upon the foregoing, we are of the opinion that, after the Post-Effective Amendment No. 131 is effective for purposes of applicable federal and state securities laws, the shares of each fund listed on the attached Exhibit A (the “Funds”), if issued in accordance with the then current Prospectus and Statement of Additional Information of the applicable Fund, will be legally issued, fully paid and non-assessable.

 

The opinions expressed herein are limited to matters of Delaware statutory trust law and United States Federal law as such laws exist today; we express no opinion as to the effect of any applicable law of any other jurisdiction. We assume no obligation to update or supplement our opinion to reflect any facts or circumstances that may hereafter come to our attention, or changes in law that may hereafter occur.

 

We hereby give you our permission to file this opinion with the Securities and Exchange Commission as an exhibit to Post-Effective Amendment No. 131 to the Registration Statement and we consent to all references to us in Post-Effective Amendment No. 131. This opinion may not be filed with any subsequent amendment, or incorporated by reference into a subsequent amendment, without our prior written consent. This opinion is prepared for the Trust and its shareholders, and may not be relied upon by any other person or organization without our prior written approval.

 

Very truly yours,
  
 /s/ THOMPSON HINE LLP
 Thompson Hine LLP

 

 

 

 

 

 

 

 

EXHIBIT A

 

1 Simplify Aggregate Bond ETF
2 Simplify Bitcoin Strategy PLUS Income ETF
3 Simplify Commodities Strategy No K-1 ETF
4 Simplify Conservative Allocation ETF
5 Simplify Enhanced Income ETF
6 Simplify Gamma Emerging Market Bond ETF
7 Simplify Growth Allocation ETF
8 Simplify Health Care ETF
9 Simplify Hedged Equity ETF
10 Simplify High Yield PLUS Credit Hedge ETF
11 Simplify Income Allocation ETF
12 Simplify Interest Rate Hedge ETF
13 Simplify Intermediate Term Treasury Futures Strategy ETF
14 Simplify Macro Strategy ETF
15 Simplify Managed Futures Strategy ETF
16 Simplify Market Neutral Equity Long/Short ETF
17 Simplify MBS ETF
18 Simplify Moderate Allocation ETF
19 Simplify Multi-QIS Alternative ETF
20 Simplify National Muni Bond ETF
21 Simplify Next Intangible Core Index ETF
22 Simplify Next Intangible Value Index ETF
23 Simplify Opportunistic Income ETF
24 Simplify Propel Opportunities ETF
25 Simplify Short Term Treasury Futures Strategy ETF
26 Simplify Treasury Option Income ETF
27 Simplify Tara India Opportunities ETF
28 Simplify US Equity Plus Complexity ETF
29 Simplify US Equity Plus Downside Convexity ETF
30 Simplify US Equity Plus Bitcoin Strategy ETF
31 Simplify US Equity PLUS QIS ETF
32 Simplify US Equity Plus Upside Convexity ETF
33 Simplify Wolfe Alpha Capture ETF
34 Simplify Wolfe US Equity 150/50 ETF
35 Simplify Wolfe Market Neutral SHIELD ETF
36 Simplify Wolfe Market Neutral Quality ETF
37 Simplify Volatility Premium ETF
38 Simplify Volt TSLA Revolution ETF
39 Simplify Gold Strategy PLUS Income ETF
40 Simplify US Small Cap PLUS Income ETF
41 Simplify Currency Strategy ETF
42 Simplify Downside Interest Rate Hedge Strategy ETF
43 Simplify China A Shares PLUS Income ETF