Item 5. Fees and Compensation
The Firm offers services on a fee basis, which may include fixed and/or hourly fees, as well as fees based upon assets
under management or advisement.
Investment Management Fees
Pure Portfolios offers wealth management services (which includes financial planning, consulting, and investment
management services) for either an annual fee based on the amount of assets under management or a flat fee for
financial planning and advice for assets not under management.
The management fee for assets under management generally varies between 40 and 100 basis points (0.40% - 1.00%)
for Pure Portfolios depending on the size and composition of a client’s portfolio and the type of services rendered.
Performance Based Discounts
For qualified clients, a performance-based adjustment to the advisory fee may be applicable. Such discounted fee
adjustments will only be implemented in the event of underperformance of the client’s portfolio specific to a mutually
agreed upon hurdle rate. The discount will apply for the following 12-month calendar year. A qualified client is defined
as a client with a minimum of $1,000,000 of assets under management with the Firm.
Real, potential, or apparent conflicts of interest may arise with respect to performance-based discounts to the advisory
fee. Pure Portfolios may manage accounts with investment strategies which are the same, or similar to, strategies
employed for your account. Fees earned by the Firm may vary among these accounts. These factors could create
potential conflicts of interest because the Firm may have incentives to favor certain accounts over others. It is possible
that the Firm may not make equitable investments across client accounts due to the performance-based fee discount
conflict. A potential conflict may also exist if the Firm identifies a limited investment opportunity that may be appropriate
for more than one account, but the Firm is not able to take full advantage of that opportunity due to the need to allocate
that opportunity among multiple accounts. In addition, the Firm may execute transactions for another account that may
adversely impact the value of securities held by your account. These potential conflicts could have negative impacts to
Pure Portfolios Holdings LLC January 31st, 2025
your investment performance. However, the Firm believes that these risks are mitigated by the fact that accounts with
like investment strategies managed by the Firm are generally managed in a similar fashion taking into consideration the
investment objectives and strategies and any legal, tax or regulatory considerations.
Account Valuation Methodology
Fair market value for purposes of computing Pure’s compensation, if any, is determined by valuing the assets as follows:
• Cash and cash equivalents shall be valued at face amount.
• Notes, bonds, and other debt instruments' current market value shall be determined on the basis of market
quotations, or, if such quotations are not readily available, market value will be determined based on coupon,
maturity, rating, liquidity, industry factors, company factors, and management.
• Common stock and other equity securities shall have a value equal to their respective closing prices as quoted by
the NYSE or the NASDAQ Stock Exchange (“NASDAQ”) system on the last business day preceding the day on which
fair market value is being determined.
• Interest and dividends shall be accrued to the last business day preceding the day on which fair market value is
being determined.
• The annual fees disclosed above are provided for transparency and they do not include the expenses charged by
the fund companies. The annual fee is prorated and charged quarterly, in arrears, based upon the market value
of the assets being managed by the Firm on the last day of the previous billing period.
If assets in excess of $10,000 are deposited into or withdrawn from an account after the inception of a billing period, the
fee payable with respect to such assets may be adjusted to reflect the interim change in portfolio value. For the initial
period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated,
the fee for the final billing period is prorated through the effective date of the termination and the outstanding or
unearned portion of the fee is charged or refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away
assets, accommodation accounts, alternative investments, etc.), the Firm may negotiate a fee rate that differs from the
range set forth above.
Fee Discretion
The Firm may, in its sole discretion, charge a lesser fee based upon certain criteria, such as anticipated future earning
capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account
composition, pre-existing/legacy client relationship, account retention and pro bono activities.
Additional Fees and Expenses
In addition to the advisory fees paid to the Firm, clients may also incur certain charges imposed by other third parties,
such as broker-dealers, custodians, trust companies, banks, and other financial institutions (collectively “Financial
Institutions”). These additional charges may include securities brokerage commissions, transaction fees, custodial fees,
fees attributable to alternative assets, reporting charges, fees charged by the Independent Managers, margin costs,
charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund
management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
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