Description of Firm
PUREfi Wealth, LLC (“Firm” or “Adviser”) provides individuals and other types of Clients with a
wide array of investment advisory services. Our firm is a limited liability company formed under
the laws of the State of Delaware in September 2023 and has been in business since that time.
Our firm is principally owned by Pure Wealth Management, LLC.
Our firm also goes by the name PUREfi Wealth Partners.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation, and any other matters related to investment decisions made by our
firm or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest.
As used in this brochure, the words "we," "our," and "us" refer to PUREfi Wealth, LLC and the
words "you," "your," and "client" refer to you as either a Client or prospective Client of our firm.
Types of Advisory Services Offered
Portfolio Management Services:
Our firm provides Portfolio Management Services to clients on a discretionary or non-
discretionary basis. This service will include asset management and/or financial planning or
consulting services. The service is designed to assist clients in meeting their financial goals by
ascertaining each client’s investment objectives. Thereafter, the Firm will have the responsibility
and authority to formulate investment strategies on the client’s behalf. Our firm will conduct client
meetings to understand their current financial situation, existing resources, and tolerance for risk.
Based on what is learned, an investment approach is presented to the client, consisting of
individual stocks, bonds, ETFs, options, mutual funds and other public and private securities or
investments. Once the appropriate portfolio has been determined, portfolios are continuously and
regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, and
stated goals and objectives. Upon client request, the Firm will provide a summary of observations
and recommendations for the planning or consulting aspects of this service.
Clients that agree to engage our firm on a non-discretionary investment advisory basis must be
willing to accept that the firm cannot effect any account transactions without obtaining prior
consent to any such transaction(s) from the client. Therefore, our firm will be unable to effect any
account transactions (as it would for its discretionary clients) without first obtaining the client’s
consent.
Financial Planning and Consulting Services:
Our firm offers financial planning services which typically involve providing a variety of advisory
services to clients regarding the management of their financial resources based upon an analysis
of their individual needs. These services can range from broad-based financial planning to
consultative subject planning, which may include, but are not limited to, any or all of the following:
Business Planning, Cash Flow Forecasting, Trust and Estate Planning, Financial Reporting,
Investment Consulting, Insurance Planning, Retirement Planning, Risk Management, Charitable
Giving, Distribution Planning, College Planning, and Manager Due Diligence.
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Retirement Plan Consulting:
Our firm may provide retirement plan consulting services to employer plan sponsors on an
ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in
establishing, monitoring, and reviewing their company's participant-directed retirement plan. As
the needs of the plan sponsor dictate, areas of advising may include:
• Establishing an Investment Policy Statement – Our firm will assist in the development
of a statement that summarizes the investment goals and objectives along with the
broad strategies to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset
allocation models to aid Participants in developing strategies to meet their investment
objectives, time horizon, financial situation, and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general
guidance on allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory
services with respect to the following types of assets: employer securities, real estate (excluding
real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or
assets, other illiquid investments, or brokerage window programs (collectively, “Excluded
Assets”). All retirement plan consulting services shall be in compliance with the applicable state
laws regulating retirement consulting services. This applies to client accounts that are retirement
or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security
Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts
appointment to provide services to such accounts, our firm acknowledges its fiduciary standard
within the meaning of Section 3(21) or 3(38) of ERISA, as designated by the Retirement Plan
Consulting Agreement, with respect to the provision of services described therein.
Retirement Plan Rollover Recommendations:
A client or prospective client leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money in the
former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or
(iv) cash out the account value (which could, depending upon the client’s age, result in adverse
tax consequences). If our firm recommends that a client roll over their retirement plan assets into
an account to be managed by our firm, such a recommendation creates a conflict of interest if our
firm will earn new (or increase its current) compensation as a result of the rollover. If our firm
provides a recommendation as to whether a client should engage in a rollover or not, the firm is
acting
as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts.
No client is under any obligation to roll over retirement plan assets to an account managed by our
firm.
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Selection of Independent Money Managers:
Our firm may recommend that you use the services of a third-party money manager ("TPMM") to
manage all, or a portion of, your investment portfolio. After gathering information about your
financial situation and objectives, we may recommend that you engage a specific TPMM or
investment program. Factors that we take into consideration when making our recommendation(s)
include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees,
your financial needs, investment goals, risk tolerance, and investment objectives. Our firm will
monitor the TPMM(s)' performance to ensure its management and investment style remains
aligned with your investment goals and objectives. The TPMM(s) will actively manage your
portfolio and will assume discretionary investment authority over your account. In addition,
TPMM(s) may be granted authority to further delegate such discretionary investment authority to
other TPMM(s). In such discretionary relationships, our firm will assume discretionary authority
to hire and fire TPMM(s) and/or reallocate your assets to other TPMM(s) where we deem such
action appropriate.
Assets Held Away From Our Firm:
We may leverage an Order Management System through Pontera to implement investment
selection and rebalancing strategies on behalf of the client in held away accounts (i.e., accounts
not directly held with our recommended custodian). These are primarily 401(k) accounts, HSAs,
403bs, 529 education savings plans, 457 plans, profit sharing plans, and other assets not
custodied with our recommended custodian. We regularly review the available investment options
in these accounts, monitor them, rebalance, and implement our strategies in the same way we do
other accounts, though using different tools as necessary. There may be a difference in the
performance of our strategies of an account using Pontera in comparison to accounts held at our
recommended custodian.
Dynasty Network:
We have entered a contractual relationship with Dynasty Financial Partners, LLC ("Dynasty"),
which provides our firm with operational and back-office support including access to a network of
service providers. Through the Dynasty network of service providers, we may receive preferred
pricing on trading technology, reporting, custody, brokerage, compliance, and other related
services. In addition, Dynasty's subsidiary, Dynasty Wealth Management, LLC ("DWM") is an SEC
registered investment adviser, that provides access to a range of investment services including:
separately managed accounts (“SMA”), mutual fund and ETF asset allocation strategies, and
unified managed accounts ("UMA") managed by external Third-Party Managers (collectively, the
"Investment Programs"). We may separately engage the services of Dynasty and/or its
subsidiaries to access the Investment Programs. Under the SMA and UMA programs, we will
maintain the ability to select the specific, underlying Third Party Managers that will, in turn, have
day-to-day discretionary trading authority over the requisite client assets.
DWM sponsors an investment management platform (the "Platform" or the "TAMP") that is
available to the advisers in the Dynasty Network, such as our firm. Through the Platform, DWM
and Dynasty collectively provide certain technology, administrative, operations, and advisory
support services that allow us to manage our client portfolios and access Third-Party Managers
that provide discretionary services in the form of traditional managed accounts and investment
models. We can allocate all or a portion of Client assets among the different Third-Party Managers
via the Platform. We may also use the model management feature of the TAMP by creating our
own asset allocation model and underlying investments that comprise the model. Through the
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model management feature, we may be able to outsource the implementation of trade orders and
periodic rebalancing of the model when needed.
Dynasty charges a “Platform Fee,” for which, unless otherwise disclosed, the Client will be
charged, separate from and in addition to such client’s annual investment management fee, as
described in Item 5 below. The annual investment management fee charged to the Client is not
affected if Platform Fees are changed by Dynasty.
We seek at all times to ensure that any conflicts are addressed on a fully disclosed basis and
investment decisions are handled in a manner that is aligned with the Client’s best interests. Our
firm does not receive any portion of the fees paid directly to Dynasty or the service providers made
available through its platform.
We will maintain the direct contractual relationship with the Client and obtain, through such
agreements, the authority to engage independent third-party managers, DWM and/or Dynasty, as
applicable, for services rendered through the Platform in service to the Client. We may delegate
discretionary trading authority to DWM and/or independent Third-Party Managers to effect
investment and reinvestment of Client assets with the ability to buy, sell, or otherwise effect
investment transactions and allocate client assets. If the Client participates in certain Investment
Programs, DWM or the designated manager, as applicable, is also authorized without prior
consultation with either us or the Client to buy, sell, trade, or allocate Client assets in accordance
with the Client’s designated portfolio, and to deliver instructions to the designated broker-dealer
and/or custodian of the Client’s assets.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Clients. Each Client may impose reasonable
restrictions, in writing, on the types of investments to be held in the portfolio or our firm’s services.
Restrictions on investments in certain securities or types of securities may affect the performance
of the account due to the level of difficulty of the restriction when managing the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of this filing, we provide continuous management services for $107,560,136 in client
assets on a discretionary basis, and no client assets on a non-discretionary basis.