Exhibit (i)
July 8, 2025
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. 164 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. 164 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. 164 to the Registration Statement and we consent to all references to us in Post-Effective Amendment No. 164. 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 ETF |
11 | Simplify Income Allocation ETF |
12 | Simplify Interest Rate Hedge ETF |
13 | Simplify Intermediate Term Treasury Futures Strategy ETF |
14 | Simplify Managed Futures Strategy ETF |
15 | Simplify MBS ETF |
16 | Simplify Moderate Allocation ETF |
17 | Simplify Multi-QIS Alternative ETF |
18 | Simplify National Muni Bond ETF |
19 | Simplify Next Intangible Core Index ETF |
20 | Simplify Opportunistic Income ETF |
21 | Simplify Propel Opportunities ETF |
22 | Simplify Short Term Treasury Futures Strategy ETF |
23 | Simplify Treasury Option Income ETF |
24 | Simplify Tara India Opportunities ETF |
25 | Simplify US Equity Plus Convexity ETF |
26 | Simplify US Equity Plus Downside Convexity ETF |
27 | Simplify US Equity Plus Bitcoin Strategy ETF |
28 | Simplify US Equity Plus Upside Convexity ETF |
29 | Simplify Wolfe Alpha Capture ETF |
30 | Simplify Wolfe Market Neutral SHIELD ETF |
A-1
31 | Simplify Wolfe Market Neutral Quality ETF |
32 | Simplify Volatility Premium ETF |
33 | Simplify Volt TSLA Revolution ETF |
34 | Simplify Gold Strategy PLUS Income ETF |
36 | Simplify Currency Strategy ETF |
37 | Simplify Bond Bull ETF |
38 | Simplify China A Shares PLUS Income ETF |
39 | Simplify Tactical US ETF |
40 | Simplify Target 15 Distribution ETF |
41 | Simplify Target 25 Distribution ETF |
42 | Simplify Barrier Income ETF |
43 | Simplify Piper Sandler US Small-Cap PLUS Income ETF |
44 | Simplify Kayne Anderson Energy and Infrastructure Credit ETF |
45 | Simplify Government Money Market ETF |
A-2