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 March 27th, 2025 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 March 27th, 2025, replaces the prior Form ADV dated March 25th, 2024. 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 include information related to providing you with more options regarding processing ACH payments. 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 new 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 877-222-6044. 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 persons 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 3/27/2025  Page 2 of 22                                                     Item 3  Table of Contents  Page  Fees and Compensation  Investment Discretion  Item 1  Cover Page  Item 2  Material Changes  Item 3  Table of Contents  Item 4  Advisory Business  Item 5  Item 6  Performance‐Based Fees and Side‐By‐Side Management  Item 7  Types of Clients  Item 8  Methods of Analysis, Investment Strategies and Risk of Loss  Item 9  Disciplinary Information  Item 10  Other Financial Industry Activities and Affiliations  Item 11  Code of Ethics, Participation or Interest in Client Transactions and Personal Trading  Item 12  Brokerage Practices  Item 13  Review of Accounts  Item 14  Client Referrals and Other Compensation  Item 15  Custody  Item 16  Item 17  Voting Client Securities  Item 18  Financial Information  1  2  3  4  9  13  13  13  15  15  16  17  19  20  20  21  22  22  ADV Part 2A Brochure 3/27/2025  Page 3 of 22              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®) 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: (877) 222-6044 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  7000 E. Belleview Ave, Greenwood Village, CO Phone: (708) 350-7873  5 Revere Drive, Northbrook, IL Phone: (385) 508-3105  3300 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 3/27/2025  Page 4 of 22                       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. 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.  To engage in financial planning services, an estimate of cost will be determined during or after the initial consultation. Clients will then sign a 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 contract date, provided that all necessary information has been promptly provided. It's important to note that financial planning recommendations may present a potential conflict of interest, as PURE may have an incentive to recommend investment services offered by the firm. However, clients are under no obligation to implement any recommendations made or maintain an ongoing relationship with the Advisor. Financial planning engagements terminate upon delivery of the plan.  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. We also offer financial planning is a continuous engagement, which includes regular reviews, strategic adjustments, and implementation support. In general, the financial planning services can 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.  ADV Part 2A Brochure 3/27/2025  Page 5 of 22                 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. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. 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 is 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, 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  ADV Part 2A Brochure 3/27/2025  Page 6 of 22                               there are pre-existing assets or related households.  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 assure 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 Accounts From time to time, and at the request of a client, PURE agrees to maintain on 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”. Client 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 directed 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 has the option to utilize a third-party platform, Pontera Order Management System (“Pontera”) for the direct management client 401(k)s, 403(b)s, or other employer-based retirement plan participant accounts over which we have discretion. Pontera allows us to manage these accounts without being considered to have custody of Client funds, as we do not have direct access to Client log-in credentials to affect trades. Clients will receive a secure link to connect their account(s) to the Pontera platform. Once the account(s) are connected, we will review the current allocations and make adjustments as deemed necessary. Client account(s) will be reviewed periodically to ensure the allocation remains aligned with their investment objectives. PURE is not affiliated with Pontera and does not receive any compensation from them for using their platform. Pontera charges PURE an annual percentage-based fee on assets under management;  ADV Part 2A Brochure 3/27/2025  Page 7 of 22                   however, clients do not incur additional charges for this service. 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 in 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. While our primary clients for these services will be pension, profit sharing and 401(k) plans, we also offer these services, where appropriate, to corporations, individuals and trusts, estates, and charitable organizations. Pension Consulting Services are comprised of four distinct services. Clients may choose to engage 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. 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 continually monitor client investments according to the procedures and timing intervals outlined in the IPS. As part of this process, we supervise the client's portfolio and provide recommendations based on market conditions and the evolving needs of the client.  ADV Part 2A Brochure 3/27/2025  Page 8 of 22                   Employee Communications For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), we may also provide annual educational support and investment workshops. The nature of the topics to be covered will be determined in collaboration with the client and in accordance with the guidelines established under ERISA Section 404(c). It is important to note that these educational support services and workshops do not provide plan participants with individualized, tailored investment advice or personalized asset allocation recommendations. Asset Under Management Asset Under Management as of March 27th, 2025 Assets Managed Discretionary $ 7,867,273,362 Non-Discretionary $ 155,956,505 Total $ 8,023,229,867 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 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.  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 contracts may be terminated with a written notice within five (5) days of contract signing, with a full refund provided. Contracts terminated after five (5) days of signing will receive a refund for payments made, adjusted for work performed at the standard $275.00 per hour for planning time spent. 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 Plan, the asset management fee includes continuous financial planning and plan implementation advisory services. Generally, a Foundation Financial Plan is required as a prerequisite to this service; however, exceptions can be made for certain clients, such as those with pre-existing assets and related households.  ADV Part 2A Brochure 3/27/2025  Page 9 of 22                 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 .40% to 1.60% annually, depending on the total gross value of the client’s managed accounts at the end of each quarter and are deducted in advance from client investment accounts. Billable account values are calculated on the last business day of the 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 future capital inflows and outflows exceeding $100.00 will be prorated and increase or reduce fees due on the next quarterly billing. Either party may terminate the advisory contract for asset management services at any time without cause by providing written notice. Upon termination, fees will be prorated to the date that written notification is received or sent by us, and we will refund the unearned portion of pre-paid asset management fees to the client. 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 Pure Level I $0 to $350,000 1.60% annually Pure Level II $350,001 to $500,000 1.25% annually Pure Level III $500,001 to $650,000 1.00% annually Pure Level IV $650,001 to $800,000 .80% annually $800,001 to $1,100,000 .70% annually Pure Level V  $1,100,001 to $2,000,000 .60% annually Pure Level VI  $2,000,001 to $10,000,000 .50% annually Pure Level VII  $10,000,001 to and higher .40% annually Pure Level VIII  Example: If PURE is managing $1,200,000 of assets for Client’s household, $350,000 @ 1.60% plus $150,000 @ 1.25%, plus $150,000 @ 1.00%, plus $150,000 @ .80%, plus $300,000 @ .70%, plus $100,000 @ .60% the total fee would equal an annualized 1.07%. The current fee of ~ .27% (1.07 x .25) would be billed for the following quarter. 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.  ADV Part 2A Brochure 3/27/2025  Page 10 of 22                 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 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 debiting arrangement, 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 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 subadvisor’s ADV. 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. Pension Consulting Fees For pension, profit sharing, and 401(k) trustee-directed plans with individual plan participants, in which PURE is a service provider, billing arrangements may vary based on the recordkeeper and client preferences. Generally, each plan recordkeeper provides automatic calculations and payment of invoices. We reserve the discretion to reduce or waive the hourly fee and/or the minimum fixed fee and provide services for a flat fee instead of an asset-based charge. Given the constant flow of assets into and out of plans, intra-quarter flows are typically not considered when calculating fees. Educational Seminars and Workshops Fees for educational seminars and workshops may be charged either to participants through a pre- determined price (typically $49) or a sponsoring company via a flat fee. In limited circumstances, the fees may be waived. The information provided at these events is impersonal in nature and not specific to any attendee’s specific financial situation. General Information Termination of the Advisory Relationship Either party may cancel the client agreement at any time, for any reason, upon receipt of written 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 On a client-by-client basis, we may use discretion to deviate from the standard fee schedule and charge a fixed percentage fee. While discounts are generally not available to our advisory clients, we will evaluate the circumstances when negotiating our fees. Legacy Clients Certain legacy client agreements may follow fee schedules that differ from our current practices. Additionally, PURE has acquired other advisory firms and clients of those firms may retain the billing practices that were in effect at the time they become clients. For example, per the terms of their original agreements with the acquired firms, those clients may be subject to billing practices such as billing in advance rather than arrears, or other arrangements that may differ from PURE’s standard billing practices.  ADV Part 2A Brochure 3/27/2025  Page 11 of 22           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 who effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. 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 Securities 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 prior fee schedules.  ADV Part 2A Brochure 3/27/2025  Page 12 of 22           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. 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.  ADV Part 2A Brochure 3/27/2025  Page 13 of 22                       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  All individual portfolio assets are periodically checked against the allocation model. If an individual asset within a portfolio is out of tolerance, the asset is manually reviewed for an opportunity to rebalance the portfolio. 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.  ADV Part 2A Brochure 3/27/2025  Page 14 of 22                    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.  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. 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. 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 our firm 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:  ADV Part 2A Brochure 3/27/2025  Page 15 of 22                            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. 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.   ADV Part 2A Brochure 3/27/2025  Page 16 of 22                               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. 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”), and Axos Clearing, LLC 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. PURE also utilizes TradePMR, Inc. and TIAA Advisor (Teachers Insurance and Annuity Association of America) as custodians, generally only for legacy clients from acquired firms. 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.  ADV Part 2A Brochure 3/27/2025  Page 17 of 22                 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;  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.  ADV Part 2A Brochure 3/27/2025  Page 18 of 22                 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. 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 Underlying securities within Portfolio Management accounts are regularly monitored and reviewed by our portfolio management department to identify opportunities to systematically rebalance, harvest tax losses, and manage cash positions. Accounts are reviewed in the context of the investment objectives and guidelines of each portfolio as well as any investment restrictions provided by the client. More frequent reviews by the client's Financial Advisor may be triggered by material changes in variables such as the client's individual circumstances. Reports In addition to the monthly statements and confirmations of transactions that clients receive directly from the custodian, we provide electronic access to reports summarizing account performance, balances, holdings, and fees assessed. While clients receive a standard summary statement, detailed billing statements are available upon request. Quarterly performance reports will also remind the client to notify us if there have been changes in the client's financial situation or investment objectives. Printed client reports are available upon request. Clients should always check to ensure that custodian reporting is consistent with reporting received from PURE. Clients should contact compliance@purefinancial.com if major inconsistences appear in report(s) and/or if reporting is not received. Subadviser Review PURE maintains regular communications with subadvisors and continuously evaluates their services and offerings to ensure alignment with client objectives and firm standards. This ongoing assessment includes monitoring performance, adherence to investment strategies, and compliance with regulatory requirements. If we identify any concerns or a decline in service quality, we will re-evaluate the relationship and may recommend changes, including terminating the subadvisor relationship if  ADV Part 2A Brochure 3/27/2025  Page 19 of 22                   necessary. 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. 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 perforamnce.  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 often refer clients to technical or specialized professionals, such as attorneys, accountants, insurance providers, or consultants, with whom we have relationships. However, clients are under no obligation to retain or engage any of these professionals. Neither PURE nor the outside professionals receive compensation for the referral. 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 3/27/2025  Page 20 of 22               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. 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. 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  ADV Part 2A Brochure 3/27/2025  Page 21 of 22                         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, we do not vote proxies on behalf of clients. Therefore, although our firm may provide investment advisory services relative to client investment assets, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets, to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. Our clients are encouraged to read through the information provided with the proxy-voting documents and make a determination based on the information provided. Although we do not vote proxies, if clients have questions about a particular proxy, they should feel free to contact us. However, the client has the ultimate responsibility for making all proxy-voting decisions. We will not be deemed to have proxy voting authority solely as a result of providing advice or information about a vote to a client. 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 3/27/2025  Page 22 of 22