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 generally are credentialed professionals such as CERTIFIED FINANCIAL PLANNERTM professionals, Certified Public Accountants, or CFA (Chartered Financial Analyst Charterholders) with at least five years of financial industry experience. Typically, we require that financial advisors attain the Accredited Investment Fiduciary (AIF®) credential to show a commitment to the fiduciary standard. If you have any questions about the designations mentioned in this brochure, please visit www.purefinancial.com. PURE follows a process of educating the client, evaluating client goals and resources, and then developing appropriate strategies to meet client goals. We offer assistance with implementing and monitoring client strategies to assess effectiveness towards achieving current and future client 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:  3040 Saturn Steet, Brea, CA Phone: (714) 924-7447  1784 Picasso Ave, Davis, CA Phone: (530) 758-2885  2020 Main Street, Irvine, CA Phone: (949) 777-4130  6320 Canoga Ave, Woodland Hills, CA Phone: (818) 805-5500  7000 E. Belleview Ave, Greenwood Village, CO Phone: (303) 327-7873  5 Revere Drive, Northbrook, IL Phone: (708) 350-7873  7525 SE 24th Street, Mercer Island, WA Phone: (206) 710-9309 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.
Page 5 of 21 ADV Part 2A Brochure 3/25/2024 Pure Financial Advisors, LLC offers the following advisory services to our clients: Financial Planning We provide financial planning services. Fees are negotiable depending on the complexity of the client’s financial situation and the actual services provided. Financial planning can be a limited engagement to assess, review or make recommendations on a specific issue. Financial planning can also be a comprehensive evaluation process in which numerous strategic recommendations are given. These recommendations may be applicable to the client’s current and/or assumed future financial state. Variables based on the client’s situation as well as historical and current market conditions may be used to project estimates of future cash flows, asset values and withdrawal strategies. Throughout the financial planning process, relevant client information and projections are considered. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, return objectives and attitudes towards risk. After completing a review and analysis of the information provided by the client, we develop analyses and recommendations, which are presented to the client. The forecasted impact of this information is then analyzed over the client’s expected life. Financial planning is also offered as a continuous engagement of planning review, strategic adjustments, and implementation. 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. 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, including as appropriate, living trusts, wills, estate tax strategies, powers of attorney, asset protection plans, long-term care, and Medicaid. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Page 6 of 21 ADV Part 2A Brochure 3/25/2024 Should the client implement the plan recommendations, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or investment advisor. Implementation of financial plan recommendations is entirely at the client's discretion. To participate in this service, an estimate of time and cost will be determined during or after the initial consultation. Following this, the client will sign a Financial Planning Agreement outlining the terms and conditions of the engagement, the scope of services to be provided, and the fees due. 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. 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, and/or stocks or bonds. 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 will generally include advice regarding the following securities: Exchange Traded Funds (ETF) Stocks and bonds Mutual fund shares Options 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.  We match portfolio trade requests to the client’s current risk tolerance questionnaire (RTQ) or investment policy statement (IPS). Page 7 of 21 ADV Part 2A Brochure 3/25/2024  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. Sub-Advisory Services In managing client portfolios, our firm may utilize the services of sub-advisors for specific asset classes, such as bonds. These sub-advisors are selected based factors such as investment philosophy, track record, and expertise in bond markets. Our firm may allocate a portion of client assets to the sub- advisor to benefit from their specialized knowledge and experience in bond investing. Clients should be aware that while we exercise discretion in selecting and monitoring these managers, their investment decisions are independent of our firm's direct control. The sub-advisor is responsible for continuously monitoring client accounts and making trades in client accounts when necessary. We do not have any trading authority with respect to your designated account managed by the sub-advisor. The sub-advisor will receive an investment advisory fee based on the bond strategy fee schedule established by the Client with the unaffiliated sub-advisor, in addition to the fee paid to PURE. We are available to answer questions that clients may have regarding their account and act as the communication conduit between the client and the sub-advisor. Pension Consulting Services We provide Pension Consulting Services separately or in combination. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we 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 use any or all of these services. Investment Policy Statement (IPS) Preparation We will meet with the client to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Our firm then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. Page 8 of 21 ADV Part 2A Brochure 3/25/2024 Selection of Investment Vehicles We assist plan sponsors in constructing appropriate asset allocation models. We will then review various investment vehicles to determine which investments are appropriate to implement the client's IPS. The number of investments to be recommended will be determined in consultation with the client. Monitoring of Investment Performance We monitor client investments continually, based on the procedures and timing intervals delineated in the Investment Policy Statement. We supervise the client's portfolio and will make recommendations to the client as market factors and the client's needs dictate. 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 designed for the plan participants. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. 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 avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to Pontera, we will review the current account allocations. Client account(s) will be reviewed periodically, and allocation changes will be made as deemed necessary. We are not affiliated with Pontera in any way and receive no compensation from them for using their platform. Pontera charges PURE an annual percentage fee based on assets under management. Clients do not incur additional charges for this service. Managed Variable Annuities We may include the management of Variable Annuity (VA). We have approved VA carrier products for this service. We manage various model portfolios for each VA carrier product, the portfolios are actively managed for the client on a discretionary basis. The investment selections for the VA are limited to the choices offered through the specific product. Specifics regarding the annuities are found in the annuities’ prospectuses and application documents. Moreover, variable annuities carry investment risk similar to mutual funds. Investors should carefully review the terms of the variable annuity contract before investing. Asset Under Management Asset Under Management as of March 25th, 2024 Discretionary Non-Discretionary Total Assets Managed $ 6,194,701,331 $ 98,112,989 $ 6,292,814,320 Page 9 of 21 ADV Part 2A Brochure 3/25/2024