QIS

1. Summary

2. Key facts

Item Detail Source
Name and ticker Simplify Multi-QIS Alternative ETF (QIS) QIS-FS, page 1, header and "Details"; QIS-PR, page 1, cover
Exchange NYSE Arca, Inc. Conflict: the fact sheet says "NYSE". QIS-PR, page 1, cover; QIS-FS, page 1, "Details"
CUSIP 82889N533 QIS-FS, page 1, "Details"
SEC series ID and LEI Series S000080584. Series LEI 5493000ECD76VI8L4769. Class C000243093. QIS-NP, Items A.2.b, A.2.c and B.5.b
Inception date July 10, 2023. Conflict: the financial highlights give "July 11, 2023 (commencement of operations)". QIS-FS, page 1, "Details"; QIS-PR, page 137, "Performance"; QIS-PR, page 316, "Consolidated Financial Highlights" footnote (j)
Trust Simplify Exchange Traded Funds, a Delaware statutory trust organized on February 28, 2020. QIS is "a diversified series of the Trust". The adviser "manages only the Funds", so this is a single-sponsor trust, not a multi-client series trust (my inference). QIS-SAI, page 3, "The Funds"; QIS-PR, page 286, "Management"
Fiscal year end June 30 QIS-PR, page 316, "Consolidated Financial Highlights"; QIS-SAI, page 51, "Allocation of Portfolio Brokerage"; QIS-NP, Item A.3.a
Net assets and NAV $48,954,346 on September 30, 2026. NAV per share $10.04 and net assets $39 million on June 30, 2026. The N-PORT gives net assets of $38,717,489.30, total assets of $46,313,319.58 and total liabilities of $7,595,830.28 on June 30, 2026. QIS-FS, page 1, "Details"; QIS-PR, page 316, "Consolidated Financial Highlights"; QIS-NP, Item B.1
Morningstar category and rating Not stated
Number of long and short positions Not stated. The documents count strategies, not stocks, and they disagree: the prospectus says "10-20 strategies"; the fact sheet says "A portfolio of 25 – 35 strategies" and "Exposure to 25+ quantitative investment strategies". On June 30, 2026 the N-PORT lists 27 holdings: 11 swaps on 4 affiliated ETFs, 3 directly held affiliated ETFs, 6 Treasury bills, 6 purchased call option lines and 1 money market fund. QIS-PR, page 132, "Principal Investment Strategies"; QIS-FS, page 1, "Strategy Details" and "Key Points"; QIS-NP, Part C
Distribution frequency Income declared and paid quarterly; capital gains annually QIS-PR, page 292, "Dividends, Other Distributions and Taxes"
Creations and redemptions "Creation Units are issued and redeemed primarily in-kind for securities but may include cash." Creation Unit is 25,000 shares. Fee $500, plus up to 3% for cash purchases. QIS-PR, page 138, "Purchase and Sale of Fund Shares"; QIS-SAI, page 59, transaction fee table

Other data, as of September 30, 2026: SEC 30-day yield 4.27% (QIS-FS, page 1, "Details").

3. Service providers

Role Firm Source
Adviser Simplify Asset Management Inc., Las Vegas, NV QIS-PR, page 138, "Investment Adviser"; QIS-PR, page 286, "Management"
Sub-adviser Not stated (none named)
Portfolio managers David Berns, PhD (Chief Investment Officer) and David Jackson (Vice President of Portfolio Management), both since the fund started in July 2023 QIS-PR, page 138, "Portfolio Managers"; QIS-SAI, page 46, "Portfolio Managers"
Administrator Bank of New York Mellon QIS-PR, page 294, "Fund Service Providers"; QIS-SAI, page 54, "Fund Administration"
Fund accountant Bank of New York Mellon QIS-PR, page 294; QIS-SAI, page 55
Custodian Bank of New York Mellon. It is also custodian of the Cayman subsidiary. QIS-PR, page 294; QIS-SAI, page 55, "Custodian"; QIS-PR, page 285
Transfer agent Bank of New York Mellon QIS-PR, page 294; QIS-SAI, page 55, "Transfer Agent"
Distributor Foreside Financial Services, LLC QIS-PR, page 294; QIS-SAI, page 44; QIS-FS, page 3
Auditor Cohen & Company, Ltd. QIS-PR, page 294; QIS-SAI, page 71, "Independent Registered Public Accounting Firm"
Prime broker Not stated
Swap counterparties June 30, 2026: Bank of America, N.A. (4 swaps, $58.62 million notional), Citibank, N.A. (2 swaps, $27.42 million), UBS AG (1 swap, $22.29 million) and BNP Paribas (4 swaps, $17.15 million). Totals are my arithmetic. The prospectus and SAI name none; the SAI says only that a counterparty "will typically be a bank, investment banking firm or broker/dealer." QIS-NP, Part C, Item C.11.b; QIS-SAI, page 5, "Swap Agreements"
Securities lending agent Not stated. No securities were on loan on June 30, 2026. QIS-NP, Items B.4 and C.12

Legal counsel: Thompson Hine LLP (QIS-PR, page 294).

4. Strategy

5. Exposure and leverage

Swap ID Counterparty Reference ETF Notional % of net assets QIS pays Rate reset Value
TRSBA0006 Bank of America, N.A. CTA $24,948,379 64.44% SOFR + 0.00 Monthly -$1,767,668
TRSCI0011 Bank of America, N.A. SBAR $24,243,810 62.62% SOFR + 0.95 Daily -$86,550
TRSCI0009 Citibank, N.A. CTA $22,288,000 57.57% SOFR + 0.00 Monthly -$1,573,972
TRSUB0004 UBS AG CTA $22,288,000 57.57% SOFR + 0.00 Monthly -$1,576,131
TRSBA0003 Bank of America, N.A. FOXY $6,534,609 16.88% SOFR + 0.00 Monthly $185,090
TRSCI0008 Citibank, N.A. FOXY $5,135,162 13.26% SOFR + 0.00 Monthly $146,993
TRSBP0005 BNP Paribas FOXY $5,133,919 13.26% SOFR + 0.00 Daily $146,656
TRSBP0006 BNP Paribas XXV $4,789,506 12.37% SOFR + 0.00 Daily -$106,832
FOXBP1TRS BNP Paribas FOXY $3,614,275 9.33% SOFR + 0.00 Monthly $103,457
FOXBP2TRS BNP Paribas FOXY $3,614,275 9.33% SOFR + 0.00 Monthly $103,035
TRSBA0005 Bank of America, N.A. FOXY $2,891,420 7.47% SOFR + 0.00 Monthly $81,898
Total $125,481,355 324.09% -$4,344,024

6. Shorting, financing and collateral

7. Derivatives and Rule 18f-4

8. Costs

Item Amount Source
Management fee 1.00%. Unitary: "The Funds pay the Adviser a unitary fee". QIS-PR, page 132, "Fees and Expenses of the Fund"; QIS-SAI, page 40, "Investment Adviser"
Other expenses 0.03% QIS-PR, page 132
Dividend and interest expense on short sales Not stated (no direct short sales described)
Borrowing costs Interest expense of 0.03% of average net assets, fiscal year ended June 30, 2026: "includes interest expense fees of 0.03%." What the interest is for is not stated. QIS-PR, page 316, "Consolidated Financial Highlights" footnote (k)
Acquired fund fees 0.10% QIS-PR, page 132
Gross and net expense ratio 1.13% total (fee table). No waiver line. Financial highlights ratio: 1.03% (FY 2026), 1.00% (FY 2025), 1.00% annualized (FY 2024), excluding acquired fund fees. QIS-PR, page 132; QIS-FS, page 1; QIS-PR, page 316
Fee waivers or caps None for QIS. QIS is not in the waiver list, and its waived fees were $0 in each of the last three fiscal years. QIS-PR, page 287, "Management"; QIS-SAI, page 42
Stated financing spreads or rates June 30, 2026: SOFR plus 0.00 on 10 swaps; SOFR plus 0.95 on the BofA swap on SBAR (TRSCI0011). The filing does not state the unit of the spread; 0.95 is likely 0.95% (my inference). The prospectus gives no spread: the swap pays "a fixed or variable rate". QIS-NP, Part C, Item C.11; QIS-PR, page 133
Where financing costs are reported Inside swap returns. The fund pays a rate on swap notional, so "the return to a Fund on any swap agreement should be the gain or loss on the notional amount plus dividends on the stocks, for example, less the interest paid by the Fund on the notional amount." Only the 0.03% interest expense appears in the ratios. QIS-SAI, page 5, "Swap Agreements"; QIS-PR, page 316

9. Performance and risk

Fact sheet returns to September 30, 2026 (QIS-FS, page 2, "Performance"). Cumulative unless marked annualized.

Period NAV Market price ICE BofA 3-Month T-Bill
3 months 12.07% 12.06% 0.89%
6 months -6.42% -6.43% 1.78%
Year to date -24.70% -23.58% 2.65%
1 year -40.85% -40.81% 3.65%
3 years, cumulative -52.68% -53.32% 14.09%
3 years, annualized -22.08% -22.42% 4.49%
Since inception, cumulative -51.47% -51.64% 15.46%
Since inception, annualized -20.09% -20.19% 4.56%

Prospectus average annual returns to December 31, 2025 (QIS-PR, page 137, "Performance"):

Measure 1 year Since inception (7/10/23)
Return before taxes -36.92% -16.25%
After taxes on distributions -37.50% -17.15%
After taxes on distributions and sale -21.70% -12.13%
Bloomberg U.S. Aggregate Bond Index 7.30% 5.20%
ICE BofA 3 Month US Treasury Bill Index 4.18% 4.86%

10. History and structural changes

11. Principal risks

Summary list: QIS-PR, pages 133 to 136, "Principal Investment Risks". Fund-by-fund list: QIS-PR, pages 256 and 257. Longer descriptions: QIS-PR, pages 269 to 281.

No principal risk addresses model or strategy-provider risk for the third-party QIS models by name (my inference). None addresses the conflict of interest in swapping on affiliated Simplify ETFs, which the June 30, 2026 holdings show (my inference, QIS-NP, Part C).

12. Relevance to our fund

All reasoning in this section is my inference unless cited.

13. Gaps and open questions

What the documents don't answer, for a 150/150 fund:

Questions to ask:

Search terms tried for fields left "Not stated":

14. Documents used

Code Document Date Pages Pages read File name
QIS-FS Fact sheet, 3Q26 Data as of September 30, 2026 3 1 to 3 (all, text; pages 1 and 2 also as images) 60408187-QIS_fact_sheet.pdf
QIS-PR Prospectus for 29 Simplify ETFs, including QIS November 1, 2026. No supplements found. 326 In full: 1 to 5, 132 to 138 (QIS summary; page 137 also as an image), 227, 286, 294, 316. Keyword passages only: 199, 228, 240, 256, 257, 269, 270, 275, 276, 280, 281, 284, 285, 287, 291, 292, 295, 296. f3035fba-QIS_prospectus.pdf
QIS-SAI Statement of Additional Information for the same 29 funds November 1, 2026. No supplements found. 75 In full: 1 to 3, 5, 7, 8, 20, 21, 23, 24, 40, 51 to 55. Keyword passages only: 25, 28, 30, 41, 42, 44, 45, 46, 57, 59, 60, 61, 63, 64, 69, 71, 73. 81a00dfe-QIS_SAI.pdf
QIS-NP Form N-PORT-P, Simplify Multi-QIS Alternative ETF (series S000080584) Reporting date June 30, 2026. Signed August 21, 2026. Not paged All Parts A, B, C and E (27 holdings) 1c78bce6-attachment.txt

Page numbering.

15. Snapshot sources

16. Fund Documents

Fact Sheet

Prospectus

SAI