Pure Portfolios Holdings LLC (“Pure Portfolios”, “we”, “our,” or “us”) is a privately-owned limited liability company headquartered in Portland, OR. Pure Portfolios is a registered investment adviser with the U.S. Securities and Exchange Commission. The Firm was formed in 2016, became an independent LLC in 2020. Pure Portfolios is owned by Toby Weber and Nik Schuurmans. As of December 31st, 2023, Pure Portfolios managed approximately $293,393,960 in assets on a discretionary basis for over 285 clients. While this brochure generally describes the business of Pure Portfolios, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on the Firm’s behalf and is subject to the Firm’s supervision or control. Investment Management Services Pure Portfolios offers clients a broad range of investment, financial planning, and consulting services, which may include any or all of the following functions: Business Planning, Cash Flow Forecasting, Trust and Estate Planning, Financial Reporting, Investment Consulting, Investment Management, Insurance Planning, Retirement Planning, Risk Management, Charitable Giving, Distribution Planning, Tax Planning, and Manager Due Diligence. In performing these services, the Firm is not required to verify any information received from the client or from the client’s other professionals (e.g. attorneys, accounts, etc.) and is expressly authorized to rely on such information. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by the Firm under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the Firm’s recommendations and/or services. Wealth Management Services Pure Portfolios provides clients with wealth management services which may include a broad range of comprehensive financial planning and consulting services as well as discretionary management of investment portfolios. Pure Portfolios primarily allocates client assets using in-house stock models among various exchange-traded funds (“ETFs”), and individual stock and bond holdings in accordance with their stated investment objectives. The Firm tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. The Firm consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time

horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify the Firm if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if the Firm determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Retirement Plan Consulting Services The Firm may elect to provide various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized and may include any or all of the following services: Plan Design and Strategy, Plan Review and Evaluation, Executive Planning & Benefits, Investment Selection, Plan Fee and Cost Analysis, Plan Committee Consultation, Fiduciary and Compliance, and Participant Education. As disclosed in the Pure Portfolios Advisory Agreement, certain of the foregoing services are provided by Pure Portfolios as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Pure Portfolios’ fiduciary status, the specific services to be rendered and all direct and indirect compensation that Pure Portfolios reasonably expects under the engagement. Specialized Investment Services Pure Portfolios offers certain other services designed as an ongoing engagement to implement and provided services based on a per hour rate or flat fee for certain services personalized to a client’s situation. Such services may include:
• Customized Portfolios: Design and manage more complex portfolios, which may include individual stocks, bonds, ETFs, mutual funds, concentrated stock, low-basis stock, non-traded assets.
• Model Portfolios: Manage client assets within the current suite of five model portfolios.
• Customized Asset Class Strategy: ex. Emerging Markets strategy that may include both debt and equity securities.
• Other Services: Blog and or media content, quarterly and annual review commentary, strategy calls and or video conferencing, client strategy meetings. Use of Independent Managers The Firm may select certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Managers engaged to manage their assets. At this time, the Firm does not use Independent Managers.