PURE FINANCIAL ADVISORS, LLC

Part 2A of Form ADV: Firm Brochure Pure Financial Advisors, LLC SEC File Number: 801-70137 3131 Camino Del Rio North Suite 1550 San Diego, CA 92108 Telephone: 866-876-7873 Email: compliance@purefinancial.com Web Address: www.purefinancial.com Brochure February 12th, 2026 This brochure provides information about the qualifications and business practices of Pure Financial Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at 866- 876-7873 or at compliance@purefinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Registration of an investment advisor does not imply a certain level of skill or training. Additional information about Pure Financial Advisors, LLC. also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 144316.  Item 2  Material Changes  The current Form ADV dated February 12th, 2026, replaces the prior Form ADV dated February 5th, 2026. In this summary of material changes, we discuss only the material changes since the last update of this brochure. The following are material changes to this filing: Item 5 has been modified to reflect updates to the asset management fee schedule.  In the past we have offered or delivered information about our qualifications and business practices to clients on at least an annual basis. Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. Our Brochure can be requested at any time, by contacting compliance@purefinancial.com or calling 866-876-7873. Our Brochure is also available through our web site www.purefinancial.com, free of charge. Additional information about Pure Financial Advisors, LLC is available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any person affiliated with Pure Financial Advisors, LLC who are registered, or are required to be registered, as investment adviser representatives of Pure Financial Advisors, LLC. ADV Part 2A Brochure 2/12/2026 Page 2 of 25  Item 3 Table of Contents Page Investment Discretion 1 Item 1 Cover Page 2 Item 2 Material Changes 3 Item 3 Table of Contents Item 4 Advisory Business 4 Item 5 Fees and Compensation 10 14 Item 6 Performance-Based Fees and Side-By-Side Management 15 Item 7 Types of Clients 15 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 18 Item 9 Disciplinary Information 18 Item 10 Other Financial Industry Activities and Affiliations 19 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 20 Item 12 Brokerage Practices 22 Item 13 Review of Accounts 23 Item 14 Client Referrals and Other Compensation 23 Item 15 Custody 24 Item 16 25 Item 17 Voting Client Securities 25 Item 18 Financial Information ADV Part 2A Brochure 2/12/2026 Page 3 of 25  Item 4 Advisory Business Pure Financial Advisors (PURE) was established on March 21, 2007, to provide strategic financial planning and asset management for mid to high-net-worth clients. PURE's mission is to help clients of all financial profiles achieve maximum net after-tax purchasing power relative to their own unique and changing lifetime financial goals. PURE's vision is to serve our client's interests by bringing experienced and credentialed financial advisors together within a scalable business model that is designed to promote transparency, adhere to academic standards for financial planning and asset management while reducing conflicts of interest. PURE's financial advisors who are assigned to develop and recommend financial strategies to the client are employees of PURE acting as the client's fiduciary. PURE's financial advisors are qualified professionals, generally with a minimum of five years of experience in the financial industry. They typically hold recognized industry credentials such as CERTIFIED FINANCIAL PLANNER® (CFP®) certification reflecting their commitment to fiduciary care and financial expertise. For more information about designations, please visit www.purefinancial.com. PURE typically follows a process that begins with educating clients, understanding their goals and resources, and developing strategies tailored to their needs. We offer assistance with implementing and monitoring these strategies to assess their effectiveness in helping clients work towards their current and future goals. Pure Financial Advisors, LLC’s principal place of business is: 3131 Camino Del Rio North, Suite 1550, San Diego, CA 92108 Phone: 866-876-7873 Branch office locations:  3623 Crossings Dr, Prescott, AZ Phone: 928-465-2711 Phone: 714-924-7447  3040 Saturn Steet, Brea, CA Phone: 530-758-2885  1784 Picasso Ave, Davis, CA Phone: 949-777-4130  2020 Main Street, Irvine, CA Phone: 818-805-5500  6320 Canoga Ave, Woodland Hills, CA Phone: 303-327-7873  7800 E Union Ave., Denver CO Phone: 708-350-7873  650 Dundee Rd, Northbrook, IL Phone: 630-990-9000  104 E. Roosevelt Rd, Wheaton, IL Phone: 615-696-7873  725 Cool Springs Blvd, Franklin, TN Phone: 385-508-3105  3450 N. Triumph Blvd, Lehi, UT  7525 SE 24th Street, Mercer Island, WA Phone: 206-710-9309 Phone: 425-883-7990  22500 NE Marketplace Drive, Redmond, WA Principal Owners PURE is a limited liability company (LLC), which is indirectly owned (through PFA Acquisition 1, LLC and other intermediate holding entities), by certain personnel of PURE as well as by Lee Equity Partners Fund III(A), L.P. and other investment funds managed by Lee Equity Partners, a privately held New York-based private equity firm. ADV Part 2A Brochure 2/12/2026 Page 4 of 25  Pure Financial Advisors, LLC offers the following advisory services to our clients: Financial Planning We provide financial planning services, with fees that are negotiable based on the complexity of the client’s financial situation and the specific services provided. Financial planning may involve a limited engagement to assess, review or provide recommendations on a particular issue. Alternatively, financial planning can also be a comprehensive evaluation process that includes strategic recommendations applicable to the client’s current and/or anticipated future financial circumstances. We gather required information through comprehensive personal interviews, including details on the client's current financial status, tax status, future goals, return objectives, and attitudes towards risk. After a thorough review and analysis of the information provided, we develop and present tailored analyses and recommendations to the client. Projections of future cash flows, asset values, and withdrawal strategies may be based on client-specific variables, as well as historical and current market conditions. Throughout the financial planning process, we carefully consider relevant client information and projections. Financial planning services may address any of the following areas: Personal We review family records, budgeting, personal liabilities, estate information and financial goals. Cash Flow We analyze the client’s current and future cash flow needs. We then illustrate the possible impact of various tax strategies and investment decisions on the client's future ability to create the income desired. Tax Planning We review the client’s current tax situation including income, investments, deductions, estate issues, and current tax law to identify opportunities for reducing current and future tax liabilities. Investments We analyze the client’s current investment resources to determine how they might align with the client’s objectives. During this analysis we review the tax efficiency, fees and expenses, diversification, risk and investment performance. Risk Management We review potential threats to the client’s financial well-being from unexpected circumstances and then propose strategies to manage risks. We analyze existing insurance policies to assess recommended coverage for life, health, disability, long-term care, liability, home and automobile. Estate Planning We assist the client in assessing and developing long-term strategies, which may include living trusts, wills, estate tax strategies, powers of attorney, asset protection plans, long-term care, and Medicaid planning, as appropriate. To engage in financial planning services, an estimate of cost will be determined during or after the initial consultation. Clients will then sign a Foundation Financial Planning Agreement that outlines the terms and conditions of the engagement, the scope of services to be provided, and the associated fees. Typically, financial plan recommendations will be presented to the client within six months of the ADV Part 2A Brochure 2/12/2026 Page 5 of 25  contract date, provided that all necessary information has been promptly provided. Important: Timely client participation is essential. Delays or incomplete information may affect the scope, quality, or timing of financial planning services. Financial planning recommendations present a potential conflict of interest, as PURE has an incentive to recommend planning and investment services offered by the firm. However, clients are under no obligation to implement any recommendations or maintain an ongoing relationship with the Advisor. Financial planning engagements terminate upon delivery of the plan. If the client chooses to implement the plan recommendations, we encourage them to work closely with their attorney, accountant, insurance agent, and/or investment advisor. Implementation of financial plan recommendations are entirely at the client's discretion. Portfolio Management Our firm provides portfolio management services to clients using asset allocation portfolios. Each portfolio is designed to meet a particular investment profile in terms of risk and expected return over specific time horizons. We have portfolios designed to meet specific risk and expected return profiles. These portfolios have equity exposure from 0% to 100% and can be structured with a combination of ETFs, no-load index funds, mutual fund shares, stocks or bonds, and alternative investments. Specific strategies or vehicles selected will depend upon the client’s individual circumstances and objectives. Generally, portfolios are globally diversified to control the risk associated with traditional markets. We manage these advisory accounts on a discretionary basis. Portfolio selection and account supervision is guided by the client's cash flow needs, risk tolerance, and stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax planning considerations. We can also manage several accounts of differing account tax structures within a single portfolio allocation to create a tax profile designed to increase tax efficiency. Through our financial planning process, we include personal discussions with the client in which the client's goals and objectives are established and identified in the client investment policy statement (IPS). Once we determine the suitability of a portfolio, the portfolio is managed to meet each client's individual needs. Clients retain individual ownership of all accounts and securities. Our recommendations are not limited to any specific investment offered by a custodian or fund family and may include advice regarding types of securities such as: Stocks and bonds Options Exchange Traded Funds (ETF) Mutual fund shares Alternative Investments To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will:  Request that each Portfolio Management Services client engage in a process of continuous financial planning and plan implementation with us. Exceptions are made, for example when there are pre-existing assets or related households. ADV Part 2A Brochure 2/12/2026 Page 6 of 25   We match portfolio trade requests to the client’s current risk tolerance questionnaire (RTQ) or investment policy statement (IPS).  Each client account is reviewed on a regular basis to ensure that the portfolio is within specified tolerances.  During periodic plan reviews we request any updated information regarding changes in the client's financial situation and investment objectives.  We are available to consult with the client regarding any changes that could affect the appropriateness of a portfolio.  We maintain client suitability information in each client's records. Transitional Portfolio Management Our firm provides continuous advice to clients regarding the investment of client funds based on the individual needs of the client. Through a financial planning process that includes personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client's personal investment policy to manage a portfolio based on that policy. During our data- gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. Individual portfolio management services are designed to accommodate existing client assets during a limited transition period to avoid short-term adverse tax consequences when transitioning to a PURE portfolio. We evaluate investment securities including exchange traded funds (ETF), mutual fund shares, stocks and bonds, options, and any other investment vehicles we believe will help the client meet their objectives. Unmanaged Non-Discretionary Accounts From time to time, and at the request of a client, PURE agrees to maintain its systems and report on certain client account(s) on an unmanaged basis. This type of account is offered as an accommodation to our clients and is referred to as an “non-discretionary”. Clients should understand that they maintain full investment authority over the account. Pure does not provide any investment research or advice and must receive your instruction and authorization prior to entering any client direct investment decision. Non-discretionary accounts do not receive portfolio management services, investment monitoring, or investment recommendations or advice for investment holdings of the account. As a result, accounts are not charged an advisory fee but are subject to any other custodian transactional and other brokerage-related fees (see Item 5, Fees and Compensation). Held Away Accounts PURE offers clients two options for assistance with employer-sponsored retirement plan accounts such as 401ks, 4013bs, or similar held-away assets. Pontera-Managed Accounts: Pure may utilize a third-party platform, Pontera Order Management System (“Pontera”) to provide discretionary management of held-away accounts. Pontera allows PURE to implement investment changes directly in client retirement plan accounts without having access to client login credentials or custody of client funds. Clients who choose this service will receive a secure link to connect their plan account(s) to the Pontera platform. Once connected, PURE will review the current allocations and, when appropriate, make adjustments to maintain alignment with the client’s investment objectives. Accounts managed through Pontera are reviewed periodically and are included in the client’s overall managed portfolio for billing ADV Part 2A Brochure 2/12/2026 Page 7 of 25  purposes. Fees for Pontera-managed accounts are assessed under PURE’s standard quarterly, asset- based advisory fee schedule and are typically deducted from a non-qualified brokerage account managed by PURE. Complimentary Annual Review: Alternatively, PURE offers clients an annual review of their held-away retirement plan account(s) at no charge. This review includes an evaluation of the available investment options within the plan and general recommendations on how those investments may be allocated. Because PURE receives advisory fees when clients elect ongoing management through Pontera but not for the complimentary annual review, this arrangement creates a material conflict of interest. PURE and its investment adviser representatives therefore have a financial incentive to recommend the Pontera-managed service. Clients should carefully consider whether they prefer the complimentary annual review or the ongoing management service before deciding. PURE seeks to mitigate this conflict by clearly disclosing it to clients and supervising recommendations for Pontera-managed accounts. Clients retain full discretion to choose either option. PURE is not affiliated with Pontera and does not receive compensation from Pontera for using its platform. Pontera charges PURE an annual percentage-based fee on assets managed through its system; however, clients do not incur additional charges for the use of Pontera. Managed Variable Annuities We may provide management services for Variable Annuity (VA) using approved VA carrier products. For each VA carrier product, we manage a range of model portfolios, which are actively managed on a discretionary basis. The investment options within each VA are limited to the choices available through the specific product. Detailed information regarding the annuities is provided in the annuities’ prospectuses and application documents. Moreover, variable annuities carry investment risk similar to those associated with mutual funds. Investors should carefully review the terms of the variable annuity contract before investing. Sub-Advisory Services In managing client portfolios, PURE may utilize the services of independent third-party managers (‘Subadvisers”) for specific asset classes, such as bonds or direct indexing for stock holdings. These Subadvisors are selected based on factors such as investment philosophy, track record, and expertise. Depending on the arrangement, Subadvisers may provide trade signals, exercise trading authority, or offer research and market insights. While PURE selects and monitors these managers, their investment decisions are made independently. Clients should be aware that Subadvisers manage their designated accounts and are compensated according to the fee schedule agreed upon with the client, in addition to PURE’s advisory fee. Pure evaluates these fees prior to engaging with a subadvisor in order to insure they are comparable to similar investment options. PURE facilitates communication between clients and Subadvisers and is available to answer questions. Clients should carefully review each Subadviser’s Brochure (Form ADV Part 2A) and client Relationship Summary 9 Form CRS) to understand their services, fees, and potential conflicts of interest. Additional information about Subadvisers is available on the SEC’s website at www.adviserinfo.sec.gov. Pension Consulting Services We provide Pension Consulting Services either separately or in combination with our other offerings. ADV Part 2A Brochure 2/12/2026 Page 8 of 25  Our primary clients for these services are pension, profit sharing and 401(k) plans; however, we may also offer these services, where appropriate, to corporations, individuals and trusts, estates, and charitable organizations. Our Pension Consulting Services generally consist of four components. Clients may engage us for any or all of these services. Investment Policy Statement (IPS) Preparation We meet with the client to develop an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Based on these discussions, we prepare a written IPS that outlines the plan’s needs, goals, and the policies to achieve them. The IPS also specifies the criteria for selecting investment vehicles and defines the procedures and timing intervals for monitoring investment performance. In connection with these services, we generally act as a fiduciary to the plan under ERISA Section 3(21), providing non-discretionary investment advice to the plan sponsor. Selection of Investment Vehicles We assist plan sponsors in constructing appropriate asset allocation models. After establishing the model, we review various investment vehicles to identify those that align with the client's IPS. The number and type of investment options recommended will be determined in consultation with the client. Monitoring of Investment Performance We monitor client investments according to the procedures and intervals outlined in the IPS. As part of this process, we review the performance of plan investment options and provide recommendations to the plan sponsor regarding changes that may be appropriate based on market conditions or the evolving needs of the plan. Employee Communications For pension, profit sharing and 401(k) plan clients with individual plan participants who exercise control over assets in their accounts (self-directed plans), we may provide educational support and group investment workshops. Topics and materials are developed in collaboration with the plan sponsor and are intended to comply with the guidelines of ERISA Section 404(c) These services are designed to help participants understand general investment principles and available plan options. They do not constitute individualized investment advice or personal asset allocation recommendations to any participant. Asset Under Management (AUM) Asset Under Management as of February 5th, 2026 Assets Managed Discretionary $ 10,850,613,808 Non-Discretionary $ 203,445,558 Total $ 11,054,059,366 In addition, PURE advises on approximately $108.8 million in assets (“Assets Under Advisement” or “AUA”). The firm does not have discretionary authority over these assets and does not provide continuous and regular supervisory or management services. As such, these assets are not included in the AUM reported above or in Form ADV Part 1A. ADV Part 2A Brochure 2/12/2026 Page 9 of 25  Item 5 Fees and Compensation Fees and Expenses We charge fees for advisory services, including financial planning and asset management. We offer a complimentary, no obligation limited engagement financial planning service known as a “Financial Assessment”. Our comprehensive financial planning engagement fees, such as the “Foundation Financial Plan” are calculated on a flat fee basis and quoted in advance. If client engages PURE in the Foundation Financial Plan and PURE is also managing the client’s assets, continuous financial planning and plan implementation services are included in the asset management fee. Asset management fees are based on the ending quarterly gross value of the asset accounts managed by us. PURE believes its advisory fees are reasonable in relation to the services provided. Clients should review custodial account statements to verify that advisory fees have been properly deducted. The qualified custodian does not verify the accuracy of advisory fees deducted. Financial Planning Fees Our financial planning fees are based on the level of the services provided and the complexity of each client’s circumstances, typically ranging from $1,000.00 to over $5,000.00. The negotiated fees may vary higher or lower depending on the scope and complexity of the plan to be prepared. All financial planning fees are agreed upon prior to entering into a contract with the client. All financial planning services agreements can be terminated with written notice within five (5) days of signing, in which case a full refund will be provided. If termination occurs after five (5) days, the client will receive a prorated refund of fees paid, calculated at $275.00 per hour for actual planning time spent through the effective date of termination. Advance payment will never exceed $1,200.00 for work that will not be completed within six months. Continuous Financial Planning and Plan Implementation When we implement and maintain a Foundation Financial Plan and manage assets in accordance with that Foundation Financial Plan, the asset management fee includes continuous financial planning and plan implementation advisory services. In most cases, a Foundation Financial Plan is required as a prerequisite to this service; however, we may waive this requirement in our discretion on a case-by- case basis. Examples may include related household relationships, or other circumstances we determine are appropriate. Fees for Portfolio Management Our asset management fees for portfolio management services are based upon a percentage of assets under management and generally range from 0.50% to 1.60% annually under a progressive fee schedule, which generally results in a blended effective rate, based on the total gross value of the client’s managed accounts at the end of each quarter. Fees are deducted quarterly in advance at the beginning of each calendar quarter from client investment accounts. For client relationships exceeding $10 million, advisory fees are negotiable. Billable account values are calculated as of the close of business on the last business day of the prior calendar quarter. For the initial partial quarter, asset management fees on capital inflows and outflows exceeding $100.00 will be prorated and applied to on the next quarterly billing cycle. Similarly, any ADV Part 2A Brochure 2/12/2026 Page 10 of 25  future capital inflows and outflows exceeding $100.00 will be prorated and increase or reduce fees due on the next quarterly billing. The annualized fee for portfolio management services will be charged as a percentage of assets under management, according to the following schedule: Fee Schedule Assets Under Management Progressive Annual Fee $0 to $350,000 1.60% annually $350,001 to $500,000 1.25% annually $500,001 to $750,000 1.00% annually $750,001 to $1,000,000 .90% annually $1,000,001 to $2,000,000 .85% annually $2,000,001 to $3,000,000 .80% annually $3,000,001 to $4,000,000 .75% annually $4,000,001 to $5,000,000 .70% annually $5,000,001 to $10,000,000 .50% annually $10,000,001 to and higher Negotiable Example: If the value of the assets managed by Advisor is $1,500,000 at the end of each calendar quarter for a period of one year, then the Asset Management Fee will be equal to $350,000 @ 1.60%, plus $149,999 @ 1.25%, plus $249,999 @ 1.00%, plus $249,999 @ 0.90%, plus $500,003 @ 0.85%. As such, the total Asset Management Fee would be approximately 1.10% on an annualized basis. In this example, the current Asset Management Fee of ~ 0.275% (1.10% divided by 4) would be billed each quarter. For relationships exceeding $10,000,001 in assets under management, advisory fees are negotiable based on relationship size, household aggregation, and service complexity, and are documented in the client’s advisory agreement. PURE generally calculates the management fee based on all assets in the investment account. In most cases, this includes cash balances invested in money market funds, short-term investment funds, ETFs, mutual funds, the entire market value of margined assets and short positions (if any), alternative investments (if any), and all other investment holdings. However, there may be exceptions depending on specific circumstances. Dependent upon the terms of the asset management agreement entered into between Pure and the Client, PURE’s asset management fee will be either (1) be deducted from a client’s account by the custodian and paid directly to PURE from client’s accounts, as authorized by the client in PURE’s asset ADV Part 2A Brochure 2/12/2026 Page 11 of 25  management agreement, or (2) PURE will obtain a written authorization from the client to receive our asset management fee via ACH transfer from the client’s bank account pursuant to PURE’s asset management agreement and an executed ACH Authorization Agreement for Direct Fee Deduction. Due to this fee processing arrangements, PURE is deemed to have custody of clients’ assets. Please refer to Item 15 of this Disclosure Brochure for detailed information about these arrangements. Sub-Advisory Services There will be additional fees associated with any sub-advisor services. Please see their ADV Part 2A Brochure and advisory agreement to review the sub-advisor’s fees, calculations, and methodology. In some cases, Pure is able to negotiate fees lower than those shown in the sub-advisor’s ADV Brochure. PURE does not receive any portion of fees from the custodian or from the sub-advisor. Management fees charged by PURE are separate and distinct from those set by the sub-advisor. Donor-Advised Fund Services We offer two types of Donor-Advised Fund (“DAF”) solutions for clients who wish to engage in charitable giving: 1. Custodian-managed DAFs, where charitable assets are held and managed by a third-party sponsor. We do not charge an advisory fee on these assets. 2. Advisory-managed DAFs, where we manage the charitable assets directly under our investment management program and assess our standard advisory fee. When you use an advisory-managed DAF, the assets in that account are aggregated with your other household accounts for purposes of determining your fee tier under our tiered fee schedule, which may result in a lower overall fee rate across all managed assets. Clients should be aware that we are compensated based on the total amount of assets under our management. This creates a conflict of interest, as we have a financial incentive to recommend advisory-managed DAFs over custodian-managed DAFs that do not generate fees. We mitigate this conflict by disclosing it to you, offering both options based on your needs and goals, and supervising our advisors’ recommendations to ensure alignment with your financial and charitable objectives. Pension Consulting Fees For pension, profit sharing and 401(k) trustee-directed plans where PURE services as a service provider, billing arrangements may vary based on the recordkeeper’s capabilities and client preferences. In most cases, the plan’s recordkeeper facilitates the calculations and payment of fees automatically. Due to the ongoing flow of contributions and distributions within retirement plans, intra- quarter cash flows are typically not included in fee calculations. Annual fees are based on a percentage of plan assets under advisement (AUA) and typically range from 0.20% to 1.00%, depending on the scope and complexity of services provided. Advisory fees for pension consulting services may be paid either by the plan sponsor (company) or from plan assets, as authorized by the plan fiduciary. The payment method is determined by the sponsor and reflected in the service agreement. When paid from plan assets, fees are generally allocated among participants on a pro rata basis in accordance with plan documents. Regardless of the payment source, PURE’s fiduciary duty and the requirement that fees be reasonable remain the same. ADV Part 2A Brochure 2/12/2026 Page 12 of 25  Educational Seminars and Workshops Fees for educational seminars and workshops are charged either to participants through a pre- determined price (typically $49) or to a sponsoring company via a flat fee. In limited circumstances, the fees are waived. The information provided at these events is impersonal in nature and not specific to any attendee’s individual financial situation. General Information Termination of the Advisory Relationship Either party can terminate the client agreement at any time, for any reason, upon receipt of written notice, with such termination being effective upon receipt of such notice. As noted above, certain fees are paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. The reimbursement of fees will be prorated based on the number of days remaining in the billing period. Billing Exceptions and Negotiated Fees From time to time, PURE may deviate from our standard fee schedule by entering into a negotiated percentage-based fee arrangement. Negotiated fees are determined based on factors including, but not limited to, overall relationship size (including aggregated household asses), the scope and complexity of services provided, anticipated future assets, legacy arrangements, and other certain relationship considerations (including employees of the firm and their immediate family members). As a result, certain clients may pay fees that differ from those paid by other clients receiving similar services. Legacy Clients Certain legacy client relationships may remain subject to previously negotiated advisory fee arrangements that differ from PURE’s current published fee schedule. In addition, PURE has acquired other advisory firms, and clients of those firms may retain the billing practices that were in effect at the time they became clients. For example, per the terms of their original agreements with the acquired firms, those clients are subject to billing practices such as billing in advance rather than in arrears, or other arrangements that differ from PURE’s standard billing practices. Mutual Fund Fees All fees paid to PURE for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees may include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge (it is PURE's policy to not use funds that impose a sales charge). A client could invest in a mutual fund directly (institutional mutual funds are not directly available to individual investors), without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Additional Fees and Expenses In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians including, but not limited to, any transaction charges imposed by a broker dealer with which an independent investment manager effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. All non- ADV Part 2A Brochure 2/12/2026 Page 13 of 25  investment management fees and expenses charged to an account as well as all investment management fees charged by other investment managers are client’s responsibility and are not covered by PURE’s advisory fees. Disclosure for Retirement Investors PURE is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income Security Act of 1974 (“ERISA”). As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, PURE may only charge fees for investment advice about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees. In instances where a qualified retirement plan will not allow for direct deduction of advisory fees; deduction can be made from the client’s non-qualified brokerage account with PURE. 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 (ERISA) 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 interest 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.  Give you basic information about conflicts of interest. Advisory Fees in General Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Additionally, some clients may be on different fee schedules. Limited Prepayment of Fees Under no circumstances do we require or solicit payment of fees in excess of $1,200.00 more than six months in advance of services rendered. Item 6 Performance-Based Fees and Side-By-Side Management PURE does not charge performance-based fees or other fees based on the share of capital gains or capital appreciation of client’s assets. ADV Part 2A Brochure 2/12/2026 Page 14 of 25  Item 7 Types of Clients PURE provides advisory services to the following types of clients: Individuals and High Net Worth Individuals   Trusts, Estates or Charitable Organizations  Pension and Profit-Sharing Plans (other than plan participants)  Corporations, Limited Liability Companies and/or other Business Types PURE does not have a minimum asset requirement to become a client. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss We firmly believe in a financial Planning-centered approach to wealth management and investing. Accordingly, the specific strategy that we recommend and/or implement is based on each client’s specific situation. To ensure comprehensive decision-making, we rely on an Investment Committee, which utilizes various analysis methods and research. These methods include modern portfolio theory, asset correlation, and academic-based financial research, all aimed at identifying persistent historical patterns to guide current decisions. We continuously evaluate our investment strategies against the latest research data to enhance our portfolios and financial strategies. However, it's important to note that while historical guidance can be helpful, the future is inherently unpredictable. Clients must be prepared to accept the risks associated with any investment strategy, as we do not guarantee future portfolio performance or the success of any recommended strategy. We utilize several significant strategies in an effort to affect the net investment results of our portfolios. Our primary investment objective is to produce an acceptable level of after-tax purchasing power growth relative to our client’s unique lifetime financial goals. We use strategies that are designed to diversify investment risk, manage portfolio volatility, manage performance risk over time, manage erosion from taxes, manage erosion from expenses and manage sustainable income distributions. Our strategies include the following: Asset Diversification Strategy We use portfolios that spread investment risk over multiple asset classes. We utilize classes such as domestic equities, international equities, domestic fixed income, international fixed income, and several alternative asset classes as well as sub-sets of these broad asset classes. Asset Class Diversification Strategy We choose to broadly diversify each asset class in our portfolios across the broad market represented by the asset class. Asset Allocation Strategy Asset allocation is constructing portfolios with different asset classes that have a history of differing and partially offsetting volatility patterns. If the asset classes are combined in efficient proportions, the overall portfolio volatility may be reduced relative to the expected return. Tolerance Based Rebalancing Strategy We monitor client portfolios for alignment with the applicable allocation model. Rebalancing decisions are implemented as appropriate based on client circumstances, market conditions, cash flows, and trading considerations. ADV Part 2A Brochure 2/12/2026 Page 15 of 25  Asset Location Strategy To manage the net after tax total return over time, we can unify multiple accounts of differing tax structures and manage them under one portfolio. By matching the individual asset tax characteristics with a complementary account type from a tax perspective, net after tax returns may be improved. As a simplified example, if the portfolio is 50% bonds and 50% stocks, then the bonds may be placed in an IRA because the bond interest is taxed as ordinary income and IRA distributions are also taxed as ordinary income. Bonds generally have a lower expected future return than stocks and any growth in an IRA is currently taxed at an individual’s highest rate. The stocks may be placed in a taxable or trust account because long term stock gains may be taxed at lower long-term capital gain tax rates when in a taxable account. If the stocks were placed in the IRA, then the long-term stock gains would be taxed at typically higher ordinary income tax rates. If a Roth account is present, we will attempt to direct more stocks there than bonds because of the higher future expected return of stocks and the Roth’s overall tax-free nature. We have created an asset ranked tax grouping system to direct assets to an appropriate tax structure and to rebalance the overall portfolio across multiple tax structures. Costs Matter Investment costs are inevitable, but minimization of investment costs and taxes can enhance long-term performance. In an effort to control investment expenses and fees, we carefully consider costs in relation to value of investment vehicles when considering whether to use them. Income Management Strategy Research indicates that certain individual factors may have a positive impact on maximizing the amount and duration of sustainable portfolio income distributions. We review and consider each of the following independent strategies to establish individual client income strategy recommendations.  Adding asset classes tends to increase sustainable withdrawal rates.  Certain asset ratios (equities vs. fixed income) tend to increase sustainable withdrawal rates.  Tax efficient asset management tends to increase sustainable withdrawal rate.  Laddering income from segmented portfolio pools tends to buffer return sequence risk.  Rules based withdrawal adjustments tend to allow for higher starting withdrawal rates.  Our retirement income management strategies incorporate some or all of these research findings to create a customized client retirement income investment strategy. Option Strategies For clients with special circumstances, we occasionally employ the use of options. Below are some of the main risks associated with investing in options:  When writing covered call options to produce income for a client’s account, there can be times when the underlying stock is “called” (call option contract exercised or assigned) by the investor that purchased the call option. That means the client would be required to sell the underlying security at the exercise (pre-determined) price to that investor.  Clients could be required to open a margin account to invest in options, which carries additional risks and could result in margin interest costs to the client.  Option positions can be adversely affected by company specific issues (the issuer of the underlying security) which include but are not limited to bankruptcy, insolvency, failing to file with regulatory bodies, being delisted, having trading halted or suspended, corporate reorganizations, asset sales, spin offs, stock splits, mergers, and acquisitions. In addition, market related actions, political issues, and economic issues can adversely affect the option market. These factors could restrict, halt, suspend, or terminate option positions written (sold) or purchased. ADV Part 2A Brochure 2/12/2026 Page 16 of 25   Changes in value of the option do not always correlate with the underlying security, and with some strategies the account could lose more than principal amount invested.  Past performance is not indicative of future results. Therefore, clients should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in options involves risk of loss. Further, depending on the different types of investments there are varying degrees of risk. Because of the inherent risk of loss associated with investing, we are unable to represent, guarantee, or even imply that PURE’s services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. Alternative Investments “Alternative investments” is a broad term that generally refers to non-traditional investment strategies or structures that may differ from publicly traded stocks and bonds. Some alternative investments are publicly traded and provide daily liquidity (for example, certain ETFs, mutual funds, or exchange-traded REITs that pursue alternative strategies). Other alternatives are not listed on a public exchange and may offer limited liquidity or periodic repurchase features (for example, interval funds, tender-offer funds, non-traded closed-end funds, non-traded REITs, private funds, and other non-traditional vehicles). PURE may recommend or include alternative investments as part of a diversified portfolio strategy when appropriate. Alternative investments may involve more complex structures and may carry different or higher fees and risks than traditional investments. Depending on the product, risks may include limited liquidity, restrictions on transfers or redemptions, leverage, valuation and pricing complexity, limited transparency, and potentially higher volatility or loss of principal. Certain alternative investments may only be available to investors who meet specific eligibility requirements, such as accredited investor or qualified purchaser standards under applicable securities laws. Clients should carefully review applicable offering documents and disclosures to understand the specific risks, costs, liquidity terms, and potential benefits associated with any recommended alternative investment. Environmental, Social and Governance Fund (“ESG”) or Socially Responsible Investments (“SRI”) When directed by the client, values-based, ESG or SRI investments may be included in the client’s portfolio. A client should carefully consider the risks and investment objectives of values-based, ESG or SRI funds, as an investment in these funds may not be appropriate for all investors and is not designed to be a complete investment program. Depending on the strategy or client-specific restrictions, a client’s account may undergo exclusionary or inclusionary screening based on values- based, ESG, and/or SRI criteria. These criteria are non-financial reasons to exclude or include a security, and therefore the client’s account or strategy may forgo some market opportunities available to portfolios that don’t use such screening. Municipal Bond Market Risk The amount of public information available about municipal bonds is generally less than that for corporate equities or bonds Risks for all forms of analysis Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly- available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. ADV Part 2A Brochure 2/12/2026 Page 17 of 25  Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Neither PURE nor our management persons have any reportable disciplinary events to disclose. Item 10 Other Financial Industry Activities and Affiliations Adult Education Our financial advisors teach adult education programs focused on retirement planning and investing. These classes are typically held by colleges and universities and may be part of the regular adult education class curriculum. Our advisors may be required to register with the college as adjunct faculty and receive compensation for teaching the class. Clients should be aware that the receipt of additional compensation by PURE and its management persons or employees creates a conflict of interest that may impair the objectivity of our firm and these individuals when making advisory recommendations. We attempt at all times to put the interest of our clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps to address this conflict:  We disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our employees to earn compensation from advisory clients in addition to our firm's advisory fees.  We collect, maintain and document accurate, complete, and relevant client background information, including the client’s financial goals, objectives and risk tolerance.  Our firm conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances.  We educate our advisors regarding the responsibilities of being a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. Bookkeeping Certain supervised persons of PURE may provide non-advisory administrative services (e.g., bookkeeping) to non-advisory clients. These services are entirely separate from the investment advisory services of the firm and are governed by separate agreements. ADV Part 2A Brochure 2/12/2026 Page 18 of 25  Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. PURE and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement, and recordkeeping provisions. PURE’s Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any particular access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You can request a copy by email sent to compliance@purefinancial.com or by calling us at 877-222-6044. PURE and individuals associated with our firm are prohibited from engaging in principal transactions or agency cross transactions. Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm may buy or sell for their personal account securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. We may aggregate our employee trades with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients will receive an average share price, and transaction costs will be shared equally and on a pro-rata basis. In the instances where there is a partial fill of a particular batched order, we will allocate all purchases pro-rata, with each account paying the average price. Our employee accounts will be included in the pro-rata allocation. As these situations represent actual or potential conflicts of interest to our clients, we have established policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest. ADV Part 2A Brochure 2/12/2026 Page 19 of 25  Item 12 Brokerage Practices PURE utilizes the services of independent third-party custodians to maintain custody of assets managed by the firm. PURE participates in the institutional advisor program of qualified custodians; Charles Schwab & Co., Inc. (“Charles Schwab”), National Financial Services LLC (“Fidelity”), Axos Clearing, LLC, TradePMR, Inc. and TIAA Advisors (Teachers Insurance and Annuity Association of America) to maintain custody of clients' assets and to effect trades for their accounts. All custodians are members of FINRA/SIPC. PURE is independently owned and operated and not affiliated with any custodian. PURE does not permit clients to direct brokerage to any other specific broker-dealers. Trade-PMR clears trades and custodies assets with First Clearing. First Clearing is a trade name used by Wells Fargo Clearing Services, LLC., a non-bank affiliate of Wells Fargo & Company. As PURE maintains relationships with legacy clients who entered into agreements under previous custodian relationships, these arrangements may differ from the current offerings outlined in this brochure. Legacy clients are generally not required to transition to the firm’s current fee schedule or service models with their respective custodian unless mutually agreed upon. However, should any material changes be made to the services provided or the terms of the relationship, we will provide appropriate notice in accordance with our client agreement and regulatory obligations. Although PURE may recommend a particular qualified custodian, it is the client’s decision whether to open an account. If the client chooses to open an account, the account agreement will be opened directly with the custodian of the client’s choice. Custodians may charge fees unrelated to PURE’s asset management fee. These fees could be brokerage commissions or transaction fees for effecting security transactions. In addition to PURE’s asset management fee, clients incur fees for mutual fund management and other fund expenses. The commissions and/or transactions fees charged by these brokers may be higher or lower than those charged by other broker dealers. For our client accounts maintained in its custody, qualified custodians do not charge separately for custody services but are compensated by account holders through commissions and other transaction- related or asset- based fees for securities trades that are executed through the custodian or that settle into accounts. Custodian services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Products and services offered by our custodians that assist us in managing and administering our clients' accounts include software and other technology that: facilitate payment of our fees from clients' accounts; and  provide access to client account data (such as trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts;   provide research, pricing, and other market data;   assist with back-office functions, recordkeeping, and client reporting. Custodians also offer other services intended to help us manage and further develop our business enterprise. These services may include:  compliance, legal and business consulting; ADV Part 2A Brochure 2/12/2026 Page 20 of 25   publications and conferences on practice management and business succession; and  access to employee benefits providers, human capital consultants and insurance providers. PURE does not receive fees or commissions from any of these arrangements, although PURE may benefit from electronic delivery of client information, electronic trading platforms and other services provided by custodians for the benefit of clients. PURE may also benefit from other services provided by custodians, such as educational events, practice management advice, and occasional business entertainment of our personnel. Custodians may make available, arrange and/or pay third-party vendors for the types of services rendered. Custodians may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to our firm. These benefits are standard in a relationship with these custodians and are not in return for client recommendations or transactions. In addition, we offer investment management services for clients with variable annuity products, employer-sponsored retirement plans, and 529 college savings plans. We advise on allocating assets within these plans, held either by the issuing insurance company or a designated custodian. However, we don't guarantee the most favorable transaction execution, and recommended platforms may have higher costs. As noted previously, the firm may use sub-advisors to manage some or all of certain clients’ portfolios. The brokerage and trading practices of the Sub-Advisor will be disclosed in the Sub- Advisor’s Disclosure Brochure (ADV Part 2A). Trade Errors PURE has a legal and fiduciary obligation to ensure that clients are not disadvantaged by trade errors in any way. A trade error refers to an error in the placement, execution, or settlement of a client’s trade. When a trade error occurs, PURE works with all relevant parties in the trading process to promptly correct the error while ensuring it does not disadvantage the client. PURE’s policies and procedures generally provide that if an error occurs, whether that error results in a gain or a loss, PURE will correct the error, which may include transferring the trade to an “error account’ held by PURE. PURE bears all costs (if any) associated with correcting the error. Aggregation and Allocation of Client Trades PURE evaluates trades on a client-by-client basis. On any given day, the number of securities traded that are common across clients will vary greatly. When possible, PURE utilizes software programs to enhance its trading efficiency including the aggregating or blocking of trades in securities across clients. Upon execution, the pricing of such blocked trades is averaged and proportionately allocated among the corresponding client accounts. Given normal trade size and depth of the market for such securities, PURE’s execution of aggregated trades is not expected to have a material impact on pricing. If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with the allocation file. If the order is partially filled, it will be allocated pro-rata based on the allocation file. PURE’s books and records will separately reflect, for each client account, the orders of which are aggregated, the securities held by, and bought and sold for that account. Funds and securities of clients whose orders are aggregated will be deposited with custodian, and neither the client’s cash nor their securities will be held collectively any longer than is necessary to settle the purchase or sale in question on a delivery versus payment basis. Cash or securities held collectively for clients will be delivered out to the custodian as soon as practicable following the settlement. PURE will receive no additional compensation of any kind as a result of the proposed aggregation. ADV Part 2A Brochure 2/12/2026 Page 21 of 25  Item 13 Review of Accounts Financial Planning Reviews Financial plans that are implemented and monitored by PURE under a continuous engagement agreement are reviewed by the client's assigned Financial Advisor. Financial plans are reviewed at varying stages and frequencies based on the client’s individual circumstances and needs. Reports Financial Plans that are under a continuous monitoring agreement have multiple reports available through an encrypted client website. Financial Planning clients who do not implement through PURE will receive a completed financial plan or report documenting the planning engagement results. Additional reports will not typically be provided unless otherwise contracted for. Portfolio Management Reviews Client accounts are reviewed on an ongoing basis by the Firm’s portfolio management personnel. Reviews are conducted periodically and are designed to ensure accounts remain aligned with the client’s investment objectives, guidelines, and any applicable investment restrictions. Reviews may also be conducted in response to material changes in market conditions or a client’s financial circumstances. The frequency and scope of such reviews may vary based on the type of account, strategy employed, and client needs. Reports Clients receive account statements and transaction confirmations directly from the qualified custodian generally at least monthly. Advisory fees are reflected on custodial account statements. Clients are encouraged to review custodial statements and compare them to any reports provided by PURE. If a client believes there are material discrepancies between custodial reporting and reports received from PURE, or if a client is not receiving reporting as expected, the client should contact us at compliance@purefinancial.com. Clients also have electronic access, at any time, to account performance reports made available through PURE’s reporting portal. Additional report formats, including printed reports or supplemental information, may be made available upon request, subject to availability. Subadviser Review PURE maintains regular communications with Subadvisers and periodically evaluates their services to assess ongoing alignment with client objectives and the Firm’s standards. This evaluation may include reviewing performance, adherence to stated investment strategies, and relevant compliance matters. If we identify concerns regarding a Subadviser’s services, we will re-evaluate the relationship and may recommend changes, which could include terminating the Subadviser relationship, as appropriate. Pension Consulting Services Reviews and Reports PURE will review the client's Investment Policy Statement (IPS) whenever the client advises us of a change in circumstances regarding the needs of the plan. Additionally, PURE will review the plan’s investment options according to the agreed upon time intervals established in the IPS. ADV Part 2A Brochure 2/12/2026 Page 22 of 25  Item 14 Client Referrals and Other Compensation PURE engages independent solicitors to provide client referrals. If a client is referred to PURE by a solicitor, the solicitor will disclose this practice to the client in writing. PURE will disclose these arrangements to affected investors, and all agreements will comply with SEC rule 206(4) under the Investment Advisers Act of 1940. Solicitors who refer clients to PURE may receive compensation from PURE, such as a retainer, a flat fee per referral and/or a percentage of advisory fees. Any such compensation will be paid pursuant to a written agreement with the solicitor and generally may be terminated by either party from time to time. As a matter of firm policy, the advisory fees paid by clients referred by a solicitor will not be increased due to the referral relationship. Solicitors do not supervise PURE nor have responsibility for PURE’s management of client portfolios or other advisory services. From time to time, PURE may receive third-party endorsements from publications, rating services, or other organizations. These endorsements may include, but are not limited to, ratings, awards, or testimonials. These ratings may be based on various factors, including the firm’s assets under management growth history, and/or client reviews. While these endorsements provide valuable information for clients who are evaluating PURE, we caution against relying solely on such endorsements when making investment decisions. Additionally, past ratings are not indicative of future performance. PURE was previously a participant in TD Ameritrade Institutional’ s AdvisorDirect program, which has been acquired by Charles Schwab. Although PURE no longer participates in the referral program, we continue to service and receive compensation for accounts opened while participating. PURE does not charge clients referred through the referral program any fee or expense higher than its standard fee schedule or otherwise pass referral fees payable to Charles Schwab to clients. This solicitation fee is usually a percentage (not to exceed 25%) of the advisory fee that the client pays to PURE. Other Specialized Professionals We frequently refer clients to unaffiliated professionals—such as attorneys, accountants, insurance agents, and consultants—for services outside the scope of investment advisory services. Referrals are made based on the professional’s experience and reputation and in the client’s best interest. Clients are under no obligation to use any referred professional and may select any qualified provider. From time to time, professionals to whom we refer clients to may also refer clients to us. These referrals are informal and unpaid. PURE does not pay for, or receive, any cash or non-cash compensation in connection with these referrals. PURE does not endorse or guarantee any third-party professional’s services. All Third-party professionals are independent and not an agent of PURE, and PURE is not responsible for the third-party services or outcomes. Item 15 Custody PURE strives to create as many safeguards for its clients’ assets as possible. It is our policy to not accept physical custody of your funds or securities at any time. Although PURE does not take custody or possession of the funds or securities that a client has placed under its management, PURE is deemed by the SEC to have custody of those accounts where our asset management fees are debited directly from the client’s custodian or client’s bank account. We have disclosed our billing practices in the "Fees and Compensation" section (Item 5) of this Brochure. ADV Part 2A Brochure 2/12/2026 Page 23 of 25  For clients that have our asset management fee debited from their managed accounts, PURE advises each client's custodian in writing of the amount of the asset management fee to be deducted from that client's account(s). On at least a quarterly basis, the client’s custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial account statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. In addition to the periodic statements that clients receive directly from their custodians, we also send account value and performance statements with our billing summary on a quarterly basis. We urge our clients to carefully compare the information provided on these statements to ensure that all account transactions, holdings, and values are correct and current. Direct Fee Deduction via ACH For fee payments via ACH transfers, each client is required to execute Pure’s Authorization Agreement for Direct Fee Deduction. Pursuant to the terms of the ACH Authorization Agreement, the client’s written authorization for receiving a quarterly invoice by Pure followed by debiting our advisory fee from your bank account via an ACH transfer will remain in effect until revoked in writing by client. PURE will provide the client with an invoice for each billing quarter, which identifies the client’s account(s) subject to the payment, the amount of the asset management fee, and the method of calculation. Clients will also receive account statements directly from their bank reflecting these transactions and should verify the accuracy of the fee deductions by comparing the fee amount reflected in the bank statement with the amount outlined in the invoice provided by PURE. Clients should contact us directly if there is any discrepancy. Standing Letters of Authorization or Instruction Custodians have long provided clients with the option to set up periodic transfers from their accounts to third parties, known as "Standing Letters of Authorization" (SLOA) or similar terms. With the client's signed documentation, these transfers can be directed by the client. When a client authorizes a SLOA, PURE can execute transfers of funds or securities on their behalf to designated third parties. While the Custodian physically holds the client's assets, PURE is considered to have constructive custody in accounts where the client has granted written and signed authority to instruct the custodian for such transfers. This information, along with the number of accounts and assets, is detailed in Form ADV Part 1, Item 9. Moreover, PURE relies on the SEC's no-action letter issued to the Investment Adviser Association in February 2017 and thus doesn't require a surprise audit for these assets. Item 16 Investment Discretion Clients may engage us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client:  Determine the security to buy or sell,  Determine the amount of the security to buy or sell and  Determine the timing of when to buy or sell. ADV Part 2A Brochure 2/12/2026 Page 24 of 25  Clients give us discretionary authority when they sign a limited power-of-attorney (LPOA) for full trading authorization through their custodian and a discretionary agreement with PURE. Clients may limit this authority by giving us written instructions. Clients may also change/amend such limitations by once again providing us with written instructions. For clients for whom a Sub-Advisor has been engaged, the Sub-Advisor will have discretionary authority to buy, sell, exchange, and otherwise trade securities within the client account. The investment strategies of the Sub-Advisor will be disclosed in their Disclosure Brochure (ADV Part 2A). Item 17 Voting Client Securities As a matter of firm policy, PURE does not vote proxies on behalf of clients. Clients retain exclusive responsibility for voting proxies and for making all elections related to corporate actions (including mergers, acquisitions, tender offers, and bankruptcy proceedings) involving securities held in their accounts. Clients receive proxy materials and shareholder communications directly from their custodian. Clients are encouraged to review the proxy materials and make voting decisions based on the information provided. Although PURE does not vote proxies, clients may contact us with questions about a particular proxy. PURE will not be deemed to have proxy voting authority solely as a result of providing information or advice regarding a vote. Item 18 Financial Information PURE is not required to provide financial information to its clients because:  Under no circumstances do we require or solicit payment of fees in excess of $1,200.00 per client more than six months in advance of services rendered.  The firm does not have a financial condition or commitment that impairs its ability to meet contractual and fiduciary obligations to clients.  The firm has never been the subject of a bankruptcy petition. ADV Part 2A Brochure 2/12/2026 Page 25 of 25