Important Disclosures

TABLE OF CONTENTS

Safeguarding Your Identity

Important Disclosure Information

Client portal access

Privacy Policy

Disaster Recovery

Trademark Disclosures

Additional Disclaimers, including:

  • Simply Money Advisors
  • Simply Money Insurance Agency
  • Simply Money Foundation
  • CERTIFIED FINANCIAL PLANNER™ Standards
  • TD Ameritrade
  • Accessing third party websites

Safeguarding Your Financial Information

As society becomes increasingly dependent upon online and electronic transactions, consumers must make protecting financial information a top priority. Thieves depend on a lack of awareness and due diligence. To counter-act, follow these seven helpful steps for shielding your personal data:

Passwords and PINs – Don’t become complacent with your growing list of passwords and PINs. Yes, we’re all accumulating more - and each site seems to require its own special tweak - but don’t store your passwords or PINs on your computer. Despite the hassle, regularly change passwords and use different passwords for each account. If you need to write down your passwords, keep them in a secure, private place. Protecting these “gateways” is the highest priority.

Computer Security – Your computer is only as safe as your personal firewall and security software package. If you’re engaging in online financial transactions, anti-virus and anti-spam features are a must. Also, make sure your software is current and configured for automatic updates. Handling this responsibility is not always the easiest so consider seeking expert advice and guidance when getting started.

Logging Out – A good rule of thumb is avoiding multi-tasking on multiple web pages when online and checking your financial accounts. Also, pay attention to the “log out” button when accessing your financial firm’s website. If you simply close or minimize your browser, access may not be terminated. If anyone else uses your computer, they may be able to re-enter the site and access your account. For maximum security, use the “log out” button each time.

Financial Statements – To thwart theft as soon as possible, read all your bank, brokerage, and credit card statements. Confirm each transaction is one you made or authorized. If there is any doubt, contact the financial institution immediately. Financial thieves often “test” the attention and acumen of potential victims by trying one or two minor transactions. If undetected, the thieves become emboldened for more aggressive maneuvers.

Free Credit Report – You can obtain a free credit report every twelve months by contacting the Annual Credit Request Service at http://www.annualcreditreport.com. Please note: under federal law, this is the only authorized online source for you to receive a free credit report. As with reviewing your financial statements, an annual review of your credit report will go a long way to alerting you to unauthorized activity and potential inaccuracies.

Wireless Connections – Be wary of accessing your online financial accounts while on public area wireless networks commonly found within airports, hotels, restaurants, and coffee shops. Security settings are often reduced to make access easier, which increases the possibility a thief can intercept your private information.

Documents – While much of the advice has concerned online or electronic information, don’t ignore those old-fashioned paper documents. Keep them in a safe, secure place. When discarding, don’t just drop in the trash. Shred or burn documents containing sensitive financial or identification information.

Our Position

Simply Money and its business partners are dedicated to protecting and preserving your financial data and identity. We believe there is no higher priority. Privacy and confidentiality are always at the forefront of what we do. This commitment will never change. If you ever have a question regarding your statements, accounts, or our measures, please contact us immediately at 513.469.7500.

IMPORTANT DISCLOSURE INFORMATION

Simply Money (“Company”) is an SEC registered investment adviser located in Cincinnati, Ohio. Company and its representatives are in compliance with the current filing requirements imposed upon SEC registered investment advisers by those states in which Company maintains clients. Company may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements. Company’s web site is limited to the dissemination of general information pertaining to its advisory services, together with access to additional investment-related information, publications, and links. Accordingly, the publication of Company’s web site on the Internet should not be construed by any consumer and/or prospective client as Company’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication by Company with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. For information pertaining to the registration status of Company, please contact the SEC or the state securities regulators for those states in which Company maintains a notice filing. A copy of Company’s current written disclosure statement discussing Company’s business operations, services, and fees is available from Company upon written request. Company does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Company web site or incorporated herein, and takes no responsibility therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.

Please remember that different types of investments involve varying degrees of risk, and there can be no assurance that the future performance of any specific investment or investment strategy (including those undertaken or recommended by Company) will be profitable or equal any historical performance level(s).

Certain portions of Company’s web site (i.e. newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to, Company (and those of other investment and non-investment professionals) positions and/or recommendations as of a specific prior date. Due to various factors, including changing market conditions, such discussion may no longer be reflective of current position(s) and/or recommendation(s). Moreover, no client or prospective client should assume that any such discussion serves as the receipt of, or a substitute for, personalized advice from Company, or from any other investment professional. Company is neither an attorney nor an accountant, and no portion of the web site content should be interpreted as legal, accounting or tax advice.

To the extent that any client or prospective client utilizes any economic calculator or similar interactive device contained within or linked to Company’s web site, the client and/or prospective client acknowledges and understands that the information resulting from the use of any such calculator/device, is not, and should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice from Company, or from any other investment professional.

Each client and prospective client agrees, as a condition precedent to his/her/its access to Company’s web site, to release and hold harmless Company, its officers, directors, owners, employees and agents from any and all adverse consequences resulting from any of his/her/its actions and/or omissions which are independent of his/her/its receipt of personalized individual advice from Company.

CLIENT WEB SITE ACCESS ACKNOWLEDGMENT

As a client of Simply Money (“Company”), you elect to participate in the password-protected access portion of Company Internet web site. You understand that your participation will allow you to review certain investment-related information published by Company and unaffiliated third parties. This password-protected access is made available to clients of Company free of charge. This authorization shall continue until canceled in writing.

You understand that the password-protected section is a secure web site intended only to allow a client access to information relative to your specific account. You also understand that you will be assigned an individual password. You agree not to share my password with any other person. You hereby release and hold Company harmless from any adverse consequences relative to any failure by you to keep the identity of your password secure.

PRIVACY POLICY

Simply Money Advisors (referred to as “SMA”) maintains physical, electronic and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, SMA attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of SMA to restrict access to all current and former clients' information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client.

SMA may disclose the client’s information if SMA is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with SMA, including, but not limited to the client’s other professional advisors and/or service providers (i.e. attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by SMA in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e. broker-dealer, investment adviser, account custodian, insurance company, etc.), including information obtained in any document completed and/or executed by the client for SMA (i.e. advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.

SMA permits only authorized employees and affiliates who have signed a copy of SMA Privacy Policy to have access to client information. Employees violating SMA Privacy Policy will be subject to SMA disciplinary process. Additionally, whenever SMA hires other organizations to provide services to SMA clients, SMA will require them to sign confidentiality agreements and/or the Privacy Policy.

Should you have any questions regarding the above, please contact Ken Madsen, Chief Compliance Officer at 513.469.7500.

SUMMARY OF THE DISASTER RECOVERY/BUSINESS CONTINUITY PLAN pertaining to Simply Money Advisors (“Adviser”)

Significant Business Disruptions (SBDs)


Adviser’s plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only Adviser’s ability to communicate and do business, such as a fire in Adviser’s building.  External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Adviser’s response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of custodians used by Adviser.

Business Description

Adviser conducts asset management business in exchange traded funds, mutual funds, equity and fixed income securities. Adviser does not hold customer funds or securities. Adviser accepts and enters orders. Transactions are sent to the custodian who then executes the orders. The account custodian maintains customers’ accounts, can grant customers access to them, and delivers funds and securities. The Adviser uses TD Ameritrade as its custodian.

Office Location

Office is located at 7890 East Kemper Road, Suite 200, Cincinnati, Ohio 45249. Our main telephone number is 513.469.7500 and the fax number is 513.469.1234. Adviser engages in order taking and entry at this location under normal circumstances. In addition, Adviser conducts all other adviser activities necessary to carry out its duties under the advisory agreements it has with clients.

Alternative Physical Location(s) of Employees

In the event of a SBD, Adviser may move staff from affected offices to the closest unaffected office location. If another office location is not available to receive those staff, Adviser can effect trades through alternative channels and have the required staff operate from their residences or other remote locations deemed appropriate by Management Staff. 

Customers’ Access to Funds and Securities

In the event of an internal or external SBD, if telephone service is available, our Advisory Representatives will take customer orders or instructions and contact account custodians on clients’ behalf, and if our Web access is available, Adviser will post on its Web site, how customers may access their funds and securities by contacting TD Ameritrade directly. 

Mission Critical Systems

Adviser’s “mission critical systems” are those that ensure prompt and accurate processing of securities transactions, including order taking, entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, and the delivery of funds and securities. More specifically, these systems include the use of telephones, fax and the Internet.

Our vendor contracts provide that the account custodians we utilize will maintain a business continuity plan and the capacity to execute that plan. In the event the broker/dealers and/or account custodians change or execute any of their plans, they represent that they will notify us of such execution and provide us with equal access to services as it does with other customers. The firms have the following SBD recovery time and resumption objectives: Single building disruption recovery time period of up to one hour; a large disruption event (city wide or regional) recovery period of up to four hours during that business day. Recovery refers to the restoration of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process new transactions and payments. 

Order Taking

Currently, Adviser receives orders from customers via telephone, during face-to-face meetings or email by the customer. During a SBD, either internal or external, we will continue to take orders through any of these methods that are available and reliable, and in addition, as communications permit, we will inform our customers when communications become available to tell them what alternatives they have to send their orders to us.  Customers will be informed of alternatives by telephone, fax, Internet website or email. If necessary, we will advise our customers to place orders directly with the account custodian at TD Ameritrade. 

Order Entry

In the event of an internal SBD, we will enter and send records to our custodian firm by the fastest alternative means available, which includes electronically or by telephone. In the event of an external SBD, we will maintain the orders in electronic or paper format, and deliver the order to the custodian firm by the fastest means available. In addition, during an internal SBD, we may need to refer our customers to deal directly with TD Ameritrade for order entry.

Other Services Currently Provided to Customers

In addition to those services listed above in this section, Adviser also provides customer servicing which is accomplished through telephone, fax, and email. In the event of an internal SBD, we would continue the same operations through alternative physical locations including residences and other branch offices.

Alternate Communications between the Adviser and Customers

Adviser now communicates with customers using the telephone, e-mail, our Web site, fax, U.S. mail, and in person visits at Adviser’s office location. In the event of a SBD, Adviser will assess which means of communication are still available and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a party by e-mail but the Internet is unavailable, we will call them by telephone and follow up where a record is needed with a paper copy in the U.S. mail. 

Updates and Annual Review

Adviser will update this plan whenever we have a material change to our operations, structure, business or location or to those of our custodian firm. Rankings and/or recognition by unaffiliated rating services and/or publications should not be construed by a client or prospective client as a guarantee that he/she will experience a certain level of results if Company is engaged, or continues to be engaged, to provide investment advisory services, nor should it be construed as a current or past endorsement of Company by any of its clients. Rankings published by magazines, and others, generally base their selections exclusively on information prepared and/or submitted by the recognized adviser.

To the extent that any client or prospective client utilizes any economic calculator or similar interactive device contained within or linked to Company’s web site, the client and/or prospective client acknowledges and understands that the information resulting from the use of any such calculator/device, is not, and should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice from Company, or from any other investment professional.

Each client and prospective client agrees, as a condition precedent to his/her/its access to Company’s web site, to release and hold harmless Company, its officers, directors, owners, employees and agents from any and all adverse consequences resulting from any of his/her/its actions and/or omissions which are independent of his/her/its receipt of personalized individual advice from Company.

TRADEMARK DISCLOSURES

Simply Money™ and the spiral symbol are trademarks of Simply Money IP Holdings, LLC.

"You're the point" is a trademark of Simply Money IP Holdings, LLC.

"We make money simple" is a trademark of Simply Money IP Holdings, LLC.

Simply Money, Simply Money Advisors, and Simply Money Investments are registered trade names of The Financial Network Group, Ltd.

Simply Money Media is a registered trade name of EPIX Productions, LLC.

Simply Money Insurance Agency is a registered trade name of The Financial Network Group Insurance Agency, Inc.

ADDITIONAL DISCLOSURES

Simply Money Advisors

Advisory services offered through Simply Money Advisors, an SEC registered investment advisor. To review our disclosure statement click here

Simply Money Insurance Agency

Insurance services offered through Simply Money Insurance Agency, an independent insurance agency. 

Simply Money Foundation

Simply Money Foundation is a nonprofit, tax-exempt, publicly supported organization formed under Section 501(c)3 of the U.S. Internal Revenue Code and is incorporated and registered in Ohio.  All donations are tax deductible as charitable contributions for U.S. federal income tax purposes to the extent allowed by law.

Simply Money Foundation is not affiliated with Simply Money Advisors.

CERTIFIED FINANCIAL PLANNER™ Standards

Certified Financial Planner Board of Standards Inc. owns the certification marks CFP®, CERTIFIED FINANCIAL PLANNER™ and federally registered CFP® (with flame design) in the U.S., which it awards to individuals who successfully complete CFP Board’s initial and ongoing certification requirements.

TD Ameritrade

Your investment advisor’s web site is not affiliated with, sponsored by, or endorsed by TD Ameritrade, Inc. In addition, your advisor’s web site has not been reviewed by TD Ameritrade and TD Ameritrade makes no representations regarding its content. The information contained therein should not be considered either a recommendation or endorsement by TD Ameritrade. The foregoing information is provided for reference purposes only and TD Ameritrade, Inc. cannot guarantee its accuracy or completeness. Your monthly statements constitute the definitive source of account information. Any account discrepancies should be brought to our attention immediately. Access to services and your account may be affected by market conditions, system performance or for other reasons.

Accessing Third Party Websites

When you link to any of the websites provided herewith, you are leaving this site. Simply Money™ and Simply Money Advisors make no representation as to the completeness or accuracy of information that is provided at these sites.