Simplify files six Smart Leverage ETFs that target 2x without a daily reset

Simplify Asset Management asked the SEC on Thursday to register six new exchange-traded funds that would try to deliver twice the long-term price return of WTI crude, copper, a 500-stock U.S. large-cap book, the Nasdaq-100, biotech, and semiconductors. The leverage would come from writing puts and buying calls that reset on a horizon longer than a month, not from the daily 2x protocol that already has billions of dollars in several of those same sleeves.

What “smart leverage” means in the prospectus

“Smart leverage in the Fund’s name,” the filing says, “refers to dual aspects of the adviser’s strategy of (i) achieving leverage through a focus on options (ii) without locking the Fund into a 2x daily reset protocol.” The options would reset on a greater-than-one-month horizon. The adviser may adjust positions weekly, monthly, quarterly, or annually, and more often when volatility rises or to take gains.

The construction is a risk reversal: buy an out-of-the-money call and sell an out-of-the-money put, using exchange-listed options, over-the-counter options, or FLEX options, which are exchange-listed contracts with customized strikes and expirations. The filing’s example is a $100 reference, a $105 call, and a $95 put. The prospectus says that mix “may allow for lower than 2x downside returns and greater than 2x upside returns in extreme markets,” and that the combination of options-based leverage and resets longer than a month “is economically smarter than more traditional 2x daily reset leveraged funds.”

The same document does not treat that as a floor. It says the adviser “will not attempt to position any Fund’s portfolio to ensure that a Fund does not gain or lose more than a maximum percentage of its net asset value on a given trading day.” If the reference falls more than the fund’s current leveraged exposure, “i.e., 50% on a day when the respective Fund is 2x leveraged,” investors “would likely lose all of their money.” Written puts can lose more than the premium received. During high volatility, the funds “may not perform as expected” when the holding period is shorter than long-term. Investors, it says, should intend to monitor the positions.

Unused cash would sit in short-term high-quality debt, including affiliated money-market ETFs. Reverse repos, futures, swaps, and other leveraged products are also permitted.

The paper is a Form N-1A post-effective amendment, No. 255, filed after the close on Thursday under Securities Act File No. 333-238475. It is still preliminary. The prospectus says the information is not complete and may be changed, and that the funds may not be sold until the registration statement is effective. Simplify checked the box for effectiveness 75 days after filing under Rule 485(a)(2), the clock that applies when an existing trust adds a new series. The preliminary prospectus is dated November [_], 2026. No ticker symbols are assigned, and every statutory fee table in the prospectus still prints as a blank.

Six series, blank tickers

Each fund is a new series of Simplify Exchange Traded Funds. Five would list on NYSE Arca; the Nasdaq-100 series would list on The Nasdaq Stock Market. Every ticker field is still [___].

The objectives are parallel. Each fund “targets long-term investment results, before fees and expenses, of two times (2x)” the price performance of its reference, and each “defines long-term as any period greater than one-year.” Under normal circumstances each would put at least 80% of net assets, plus borrowings, into instruments with economic characteristics substantially similar to that reference. The board could change both the objective and the 80% policy without a shareholder vote, the latter on 60 days’ written notice.

The oil and copper series would be commodity pools. Each expects to take up to 25% of assets through a wholly owned Cayman Islands subsidiary, and Simplify Asset Management would register as a commodity pool operator with the CFTC for those two. The four equity series rely on a Rule 4.5 notice claiming exemption from that CPO registration for their own operations. Those four would lever a portfolio of about 500 of the largest U.S.-listed equities, the Nasdaq-100 Index, more than 100 of the largest U.S. biotech companies by free-float market capitalization, and about 25 of the largest U.S.-traded semiconductor companies, including ADRs.

Thursday’s amendment adds only these six series. It does not rewrite, rename, or close any fund already trading.

Daily 2x funds already sit in four of the six sleeves

A registration is not a comparison chart, but these six names are not empty categories. Daily-reset 2x funds already take the large-cap, Nasdaq-100, semiconductor, and WTI oil sleeves in size. Copper and biotech 2x do not.

As of Friday, September 11, ProShares Ultra QQQ AQLD, which seeks 2x the daily Nasdaq-100, held $13.86 billion and charges 0.98%. ProShares Ultra S&P500 BSSO, 2x the daily S&P 500, held $8.77 billion at 0.88%. ProShares Ultra Semiconductors BUSD, 2x the daily Dow Jones U.S. Semiconductors Index, held $2.64 billion at 0.95%. ProShares Ultra Bloomberg Crude Oil CUCO, 2x the daily Bloomberg Commodity Balanced WTI Crude Oil Index, held $471 million at 0.95%.

The copper and biotech 2x comparators are much smaller. USCF Daily Target 2X Copper Index ETF DCPXR, a daily 2x copper-futures product, held $14.1 million at 1.20%.

Direxion Daily Biotech Top 5 Bull 2X ETF DTBXU, 2x a five-name biotech index, held $5.0 million and charges 6.27%. Simplify’s biotech paper describes a book of more than 100 names, not five. Beyond strict 2x, Direxion Daily S&P Biotech Bull 3X Shares BLABU, which seeks 3x the daily S&P Biotechnology Select Industry Index, held $522 million at 0.96%.

Those listed 2x funds reset every session and tell holders not to treat a 2x daily objective as a 2x result over weeks or years.

Simplify’s paper is written the other way: a holding period longer than a year, and options that do not reset daily.

Gold is already on a shorter clock

This six-fund amendment is the second Smart Leverage paper in two weeks, not the first.

On August 31, Simplify filed a separate 485APOS to rename Simplify Gold Strategy ETF BYGLD, the name that August paper uses for the series, as Simplify Smart Leverage Gold ETF and to set a matching objective: 2x the long-term price performance of gold futures, long-term again defined as any period greater than one year. That amendment elected effectiveness on November 1, 2026 under Rule 485(a)(1), the material-change clock for an existing series. BYGLD held $37.3 million as of Friday. Its current portfolio is still a gold-futures strategy with options, not the 2x product described in the August paper.

The gold conversion, if it becomes effective, would put the Smart Leverage label on an existing ticker weeks before the six new series could come off a 75-day clock. Thursday’s filing does not complete that gold change, and it does not make the six new funds a launch.

A 0.85% fee in the SAI, blanks in the prospectus

Every statutory fee table is unfinished. Management fees print as 0.[_]%, other expenses as [0.__]%, and total annual fund operating expenses as [0.__]%. Distribution (12b-1) fees are 0.00%, with a plan that could charge up to 0.25% and no current plan to impose it. Other expenses are estimated for each fund’s first fiscal year. The one- and three-year cost examples are dollar blanks.

Simplify Asset Management Inc., 10845 Griffith Peak Drive in Las Vegas, is the adviser. Foreside Financial Services, LLC would distribute the shares; the funds would not pay Foreside under the distribution agreement.

The statement of additional information is further along than the prospectus a buyer would read. It states that the adviser is paid a monthly management fee at an annual rate of 0.85% of average daily net assets of each fund. That is a management fee, not a completed total expense ratio. Other expenses, acquired-fund fees, and any waiver remain unfilled in the prospectus tables. The funds would define long-term as any period greater than one year. The fee a holder would actually pay over that year is still a blank.