A. Firm Information
Lester Antman d/b/a SimplyRich (“SimplyRich” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (the “SEC”), which is organized as a sole proprietorship under the
laws of the State of California. SimplyRich was founded in February 2001 by Lester M. Antman.
This Brochure is designed to inform you of the services offered by SimplyRich. It will give you an idea of the
types of Clients we advise, the types of investments we handle, our fees and the general way we do business. We
hope this will help you make informed decisions about whether SimplyRich is the advisor for you.
B. Advisory Services Offered
SimplyRich offers investment advisory services to individuals in several states (each referred to as a “Client”).
This Brochure provides Clients with information regarding SimplyRich and the qualifications, business practices,
and nature of advisory services that should be considered before becoming an advisory client of SimplyRich.
SimplyRich provides financial planning and investment management services. The details of these service
offerings are provided below.
Personalized Asset Management
SimplyRich provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary investment management and
consulting services. SimplyRich works with each Client to identify their investment goals and objectives as well
as risk tolerance and financial situation in order to create a portfolio allocation.
SimplyRich will then construct a portfolio for each Client consisting of individual equity and fixed income
securities; mutual funds and exchange traded funds; options and commodities; and other investments as
appropriate to meet the Client’s objectives.
SimplyRich’s investment strategy is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held less than one year to meet the objectives of the Client or due to market conditions.
SimplyRich will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place
reasonable restrictions on the types of investments to be held in their respective portfolio, subject to the
acceptance by the Advisor. Comprehensive financial services are not included in this service.
Other Information on Advisory Services
SimplyRich may recommend, on occasion, redistributing investment allocations to diversify the portfolio.
SimplyRich may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement, which may adversely affect
the portfolio. SimplyRich may recommend selling positions for reasons that include, but are not limited to,
harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities,
overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating
cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Prior to rendering investment advisory services, SimplyRich will ascertain, in conjunction with the Client,
the Client’s financial situation, risk tolerance, and investment objective[s].
SimplyRich will provide investment advisory services and portfolio management services and will not provide
custodial or other administrative services. At no time will SimplyRich accept or maintain custody of a Client’s
funds or securities. All Client assets will be managed within their designated brokerage account or pension
account, pursuant to the Client Investment Advisory Agreement.
Retirement Rollovers-No Obligation/Conflict of Interest: A client leaving an employer typically has four options
(and may engage in a combination of these options): 1) leave the
money in his former employer’s plan, if
permitted, 2) roll over the assets to his/her new employer’s plan, if one is available and rollovers are permitted,
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3) rollover to an Individual Retirement Account (IRA), or 4) cash out the account value (which could, depending
upon the client’s age, result in adverse tax consequences).
SimplyRich may recommend an investor roll over plan assets to an IRA managed by SimplyRich. As a result,
SimplyRich may earn an asset-based fee; however, a recommendation that a client or prospective client leave
their plan assets with their old employer will result in no compensation. SimplyRich has an economic incentive
to encourage an investor to roll plan assets into an IRA that SimplyRich will manage.
There are various factors that SimplyRich may consider before recommending a rollover, including but not
limited to: i) the investment options available in the plan versus the investment options available in an IRA, ii)
fees and expenses in the plan versus the fees and expenses in an IRA, iii) the services and responsiveness of the
plan’s investment professionals versus those of SimplyRich, iv) required minimum distributions and age
considerations, and vi) employer stock tax consequences, if any. No client is under any obligation to roll over
plan assets to an IRA managed by SimplyRich.
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or
the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make
money creates some conflicts with your interests, so we operate under a special rule that requires us to act in
your best interest and not put our interests ahead of yours.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Account Management
Prior to engaging SimplyRich to provide investment advisory services, each Client is required to enter into an
Investment Advisory Agreement with the Advisor that defines the terms, conditions, authority and
responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Policy Statement – SimplyRich, in connection with the Client, may develop a
statement that summarizes the Client’s investment goals and objectives along with the broad
strategy[ies] to be employed to meet the objectives. An Investment Policy Statement generally includes
specific information on the Client’s stated goals, time horizon for achieving the goals, investment
strategies, Client risk tolerance and any restrictions imposed by the Client.
• Asset Allocation – SimplyRich will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
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• Portfolio Construction – SimplyRich will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision - SimplyRich will provide investment management and
ongoing oversight of the Client’s portfolio and overall account.
D. Wrap Fee Programs
SimplyRich does not place Client assets into a wrap fee program. Investment management services are provided
directly by SimplyRich.
E. Assets under Management
Assets under management as of December 31, 2022, are $243,176,497 in discretionary assets.