REBALANCE LLC

Rebalance, LLC Client Brochure & Privacy Policy Item 1: Cover Page This brochure provides information about the qualifications and business practices of Rebalance, LLC as well as its Privacy Policy. If you have any questions about the contents of this brochure, please feel free to contact us at 650-396-3900 or by email at: spuritz@rebalance360.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Rebalance, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Rebalance, LLC’s CRD number is: 158242. SEC registration does not imply a certain level of skill or training. 635 Bryant St., #6 Palo Alto, California, 94301 Version Date: 03/20/2025  Item 2: Material Changes The advisory fee and account minimums have been updated. These changes are outlined in Item 5: Fees and Compensation. 2 | Bethesda, MD Palo Alto, CA rebalance360.com  Item 3: Table of Contents Item 1: Cover Page 1 Item 2: Material Changes 2 Item 3: Table of Contents 3 Item 4: Advisory Business 4 Item 5: Fees and Compensation 6 Item 6: Performance-Based Fees and Side-By-Side Management 8 Item 7: Types of Clients 8 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss 9 Item 9: Disciplinary Information 10 Item 10: Other Financial Industry Activities and Affiliations 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 10 Item 12: Brokerage Practices 11 Item 13: Reviews of Accounts 13 Item 14: Client Referrals and Other Compensation 13 Item 15: Custody 14 Item 16: Investment Discretion 14 Item 17: Voting Client Securities (Proxy Voting) 14 Item 18: Financial Information 14 Privacy Policy 15 3 | Bethesda, MD Palo Alto, CA rebalance360.com  Item 4: Advisory Business Rebalance, LLC (hereinafter “Rebalance”) is a Delaware limited liability company formed in June 2011 (as MR Advisers, Inc.). The principal owners are Somerset Group Enterprise, Inc. and Penny Investor, Inc., owned respectively by Scott Puritz and Mitchell Tuchman. Through the Rebalance360 program, Rebalance provides investment management (“Invest360”), financial planning (“Plan360”), and decision-making (“Advise360”) advice and support (Invest360, Plan360, and Advise360, collectively, “Rebalance360”) to its clients. Invest360 Rebalance offers ongoing portfolio management services for both taxable and tax-deferred investment accounts, including all kinds of IRAs (such as roll-over, traditional, Roth, SEP, inherited). Rebalance reviews each client’s goals related to the particular investment account, including, age, time to retirement, investment experience, and risk tolerance levels, and then recommends an appropriate model portfolio that Rebalance feels is appropriate for the client. Rebalance’s investment services may include, but are not limited to, the following: • Investment Strategy • Risk Tolerance • Portfolio Rebalancing • Portfolio Monitoring • Asset Allocation • Financial Planning • Fund Selection Rebalance requires discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are calculated for each client using an internal “diagnostic,” which is both quantitative and qualitative, and the recommended portfolio and goals are documented in Exhibit A of the Investment Advisory Agreement entered into with each client (the “Investment Advisor Agreement”). Rebalance limits its securities selection to a small universe of Exchange Traded Funds (ETFs) and generally invests clients’ savings into one of seven model portfolios. These models are comprised of five to nine ETFs representing domestic and international equities, fixed income and real estate investment trusts. The model portfolios are: • Income • Balanced Income • Balanced Growth • Growth • Diversified Income • Income Ladder • Diversified Growth 4 | Bethesda, MD Palo Alto, CA rebalance360.com  Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. In certain instances, clients may transfer taxable investment accounts to Rebalance that include highly appreciated securities. When the immediate sale of these securities would result in significant tax consequences, Rebalance may retain such positions and incorporate them into a client’s broader portfolio strategy. In these cases, Rebalance works with the client to align the account, to the extent practicable, with one of the firm’s model portfolios or a mutually agreed upon asset allocation. Where appropriate, certain legacy securities may be used as proxies for model portfolio components. Over time, Rebalance may recommend the selective sale of these holdings in a manner that is intended to be tax-efficient and consistent with the client’s long-term investment plan. Plan360 As a part of Plan360, Rebalance offers financial planning services to those clients who have $1,000,000 or more in assets under management with Rebalance as part of the bundle of services comprising Rebalance360. Services provided by the financial planning team may include the following: (i) reviewing and prioritizing clients’ goals and objectives; (ii) developing a summary of clients’ current financial situation; (iii) completing a retirement planning assessment, including financial projections of assets at estimated retirement date; and (iv) preparing a written financial plan. Specific client financial plans and their implementation are dependent upon the client’s current situation (income, tax levels, and risk tolerance levels). Rebalance constructs a client-specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets of the client. The written financial plan is designed from the personal information and documents furnished to Rebalance by the client and it is based on the client’s expression of personal investment objectives. It is essential that tax and legal planning be undertaken only with the advice of the client’s attorney, CPA, and other financial advisors. The written financial plan is not to be construed as offering legal or accounting advice. Clients are encouraged to discuss the financial plan prepared by Rebalance with their attorneys and accountants. Advise360 Advise360 provides clients with access to a knowledge base comprised of whitepapers that provide useful information regarding a wide range of personal financial topics that may arise during the course of a client’s financial planning. 5 | Bethesda, MD Palo Alto, CA rebalance360.com  Other Wealth Management Services In addition to Rebalance360, Rebalance’s Managing Directors, Scott Puritz and Mitchell Tuchman, offer a personalized service to a select group of friends, family and high net worth individuals. Services provided by Mr. Puritz and Mr. Tuchman may include financial planning, asset allocation, and investment management services. Rebalance manages some or all of the client’s capital in the context of the client’s full financial picture. These clients may execute a different Investment Advisory Agreement than the one used for the Rebalance360 (above). For these clients, Rebalance prefers, but does not limit its securities selection to, Exchange Traded Funds (ETFs) and may in certain cases utilize or oversee the use of mutual funds, equities, bonds, fixed income, debt securities, private equity, commodities, venture capital, hedge funds, and government securities. Rebalance may use other securities as well to help diversify a portfolio when appropriate. These services are provided at the discretion of Rebalance’s Managing Directors. Client Assets Under Management Rebalance has approximately $1,558,126,646 under management as of December 31, 2024. Rebalance has discretionary authority over all of these assets. Wrap Fee Program A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. Rebalance does not participate in any wrap fee programs. Item 5: Fees and Compensation Rebalance’s annual advisory fees for new client accounts for our Rebalance360 service (as a percentage of total assets under management) are as follows: Up to $5,000,000 Over $5,000,000 Up to $1m 0.75% Up to $7.5m 0.50% $1m - $2m 0.65% $7.5m - $15m 0.25% $2m - $5m 0.50% Over $15m 0.12% 6 | Bethesda, MD Palo Alto, CA rebalance360.com  The advisory fee is generally charged quarterly based upon the account value as of the last day of the prior quarter. For an account opened intra-quarter the advisory fee is prorated. For existing accounts, there are no charges on funds added during the quarter, nor adjustments made for funds withdrawn during the quarter. Fees are deducted from the accounts. Fees are charged beginning from the date a new account has been funded. At Rebalance’s discretion, the firm may negotiate the Rebalance360 fees, which will be reflected in the Investment Advisory Agreement signed by the client. Additionally, Rebalance’s Managing Directors Scott Puritz and Mitchell Tuchman offer personalized services to a limited number of clients for a fee that is negotiable depending upon the needs of the client and complexity of the client’s portfolio. The final fee schedule is included in the Investment Advisory Agreement signed by the client. Rebalance provides periodic educational seminars and workshops to clients and the general public free of charge. Neither Rebalance nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales, charges, or services fees from the sale of mutual funds. Account Minimums The account minimum for Rebalance360 accounts is $1,000,000, although this minimum may be waived at Rebalance’s discretion. Clients may terminate the Investment Advisory Agreement at any time by providing five days’ written notice to Rebalance. A pro-rata refund of management fees will be returned to the client for any unearned fees during a quarter after the termination request has been received. Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, ETF fund fees, transaction fees, etc.). Third-party fees are separate and distinct from the fees and expenses charged by Rebalance and are charged separately to clients’ accounts. Please see Item 12 of this brochure regarding Brokerage Practices. 7 | Bethesda, MD Palo Alto, CA rebalance360.com  BetterK – 401(k) Services Rebalance’s annual fee for 401(k) and cash balance pension plan clients is 0.75% of the fair market value of the plan assets, excluding certain assets, with an account minimum of $1,000,000, payable quarterly. However, the fee may be changed by Rebalance upon thirty (30) days advance notice to the client. Fees paid as a percentage of plan assets are based on the fair market value of the assets on the last trading day of the month of the previous calendar quarter as reported by the plan custodian. Fees may be paid (i) directly by the client, or (ii) out of the plan assets if the client has provided written instructions to the plan record keeper or custodian to calculate and remit fees directly to Rebalance. All fees will be prorated for partial periods. Item 6: Performance-Based Fees and Side-By-Side Management Rebalance does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients Rebalance generally provides investment advice and/or management supervisory services to the following types of clients: • Individuals • 401(k) and Other Retirement Plans • Pooled Investment Vehicles • High Net Worth Individuals • Charitable Organizations Rebalance imposes an account minimum of $1,000,000, which may be waived by Rebalance in certain circumstances based on the needs of the client and the complexity of the client’s portfolio. 8 | Bethesda, MD Palo Alto, CA rebalance360.com  Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss Methods of Analysis Strategic Asset Allocation is a top-down investment strategy used by Rebalance that focuses on general movements in the market rather than on performance of individual securities. The rise and fall of certain securities may not react according to predicted trends. Other factors such as risk tolerance, market timing, portfolio size, and investment expenses may also affect the portfolio performance. Investment Strategies Rebalance predominantly uses long-term rebalancing strategy designed to capture market rates of both return and risk. Rebalance generally seeks investment strategies where risk is in line with that of the general domestic and/or international equity and fixed income markets. Rebalance recommends one of seven basic portfolios. These portfolios are made up of publicly traded ETFs. The risks of these seven portfolios are correlated with the risks of the global equity and bond markets because the ETFs Rebalance recommends are broad market indices. All portfolios have a target minimum amount in cash, generally under 1%. In rare cases, a client may have moved illiquid or unlisted securities because it would be detrimental to the client to sell when investing in one of the seven portfolios. In these rare circumstances, Rebalance will leave these securities in place until such time that the sale of the securities is possible. Personalized wealth management clients have all or a portion of their portfolios using a strategic asset allocation strategy with ETFs where it is possible. In other cases, for example where highly appreciated stock is held in a taxable account, or where a client wishes to hold existing positions, Rebalance may leverage existing client positions in order to accomplish the asset allocation strategy agreed upon with the client. Risk of Investment Loss Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Additionally, Rebalance relies on the financial and other information clients provide to Rebalance to provide the Rebalance360 services. Rebalance has no duty or obligation to investigate the accuracy or completeness of this information. 9 9 | Bethesda, MD Palo Alto, CA rebalance360.com rebalance360.com  Each client agrees in the Investment Advisory Agreement with Rebalance to update any financial and other information provided to Rebalance. Also, any written financial plan prepared for a client by Rebalance is based on assumptions that may or may not occur, and asset values and investment returns will fluctuate based on a variety of factors over time. Item 9: Disciplinary Information There are no criminal or civil actions, administrative proceedings, or self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations Rebalance is not, and has not applied to be, a securities broker or dealer. None of Rebalance’s officers, employees, or independent contractors are registered representatives of a securities broker-dealer. Neither Rebalance nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, a Commodity Pool Operator, or a Commodity Trading Advisor. Rebalance does not utilize nor select other advisors or third-party managers. All assets are managed by Rebalance management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Rebalance has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, 10 | Bethesda, MD Palo Alto, CA rebalance360.com  Annual Review, and Sanctions. Rebalance’s Code of Ethics is available free upon request to any client or prospective client. Rebalance does not recommend that clients buy or sell any security in which a related person to Rebalance or Rebalance has a material financial interest. From time to time, representatives of Rebalance may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of Rebalance to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. Rebalance and its representatives will implement client’s transactions before transactions on behalf of Rebalance or its representatives when similar securities are being bought or sold. Item 12: Brokerage Practices Because of the trading models used by Rebalance and the type of investment advisory services Rebalance provides, client-directed securities brokerage is not permitted for Rebalance360. Rebalance requires its clients to use either Charles Schwab & Co. (“Schwab”) or Fidelity Brokerage Services, LLC (“Fidelity”) for custodial and securities execution services. The decision to direct a client to Schwab or Fidelity is made by Rebalance in its sole discretion. Rebalance receives research, products, or other services from the broker-dealer firms to which it directs its clients in connection with client securities transactions. There is no specific incentive provided to Rebalance to select Schwab or Fidelity as the client custodian. Rebalance believes that the execution practices and services between Schwab and Fidelity are substantially equivalent. Schwab and Fidelity provide Rebalance with access to institutional trading and custody services which are typically not available directly to Schwab or Fidelity’s retail customers. These services generally are available to independent investment advisers at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab or Fidelity. Schwab and Fidelity provide brokerage services that are related to the execution of securities transactions, (including that in the form of advice, analyses and reports), 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. For Rebalance client accounts maintained in Rebalance’s 11 | Bethesda, MD Palo Alto, CA rebalance360.com  custody, Schwab or Fidelity generally do not charge separately for custody services but are compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or Fidelity or that settle into Schwab or Fidelity accounts. Schwab and Fidelity also make available to Rebalance other products and services that benefit Rebalance but may not benefit its clients’ accounts. These benefits may include national, regional, or Rebalance specific educational events organized and/or sponsored by Schwab or Fidelity. Other potential benefits may include occasional business entertainment of personnel of Rebalance by Schwab or Fidelity personnel, including meals, invitations to sporting events (including golf tournaments), and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist Rebalance in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of Rebalance’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping, and client reporting. Many of these services generally may be used to service all or some substantial number of Rebalance’s accounts. Schwab and Fidelity also make available to Rebalance other services intended to help Rebalance manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Schwab and Fidelity may make available, arrange and/or pay vendors for these types of services rendered to Rebalance by independent third parties. Schwab or Fidelity 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 Rebalance. Rebalance is independently owned and operated and not affiliated with Schwab or Fidelity. Rebalance receives no referrals from Schwab, Fidelity or any other third party in exchange for directing business to that broker-dealer or third party. Rebalance does, however, require that clients have either a Schwab or Fidelity account in order for Rebalance to execute transactions. Rebalance may aggregate or place “block” trade orders for the same securities across accounts, particularly when implementing periodic rebalancing of accounts. Aggregating purchase or sale orders for clients may result in reduced conversion and other trade execution costs. Securities purchased on an aggregate basis will be allocated by Rebalance on a fair and equitable basis in accordance with Securities and Exchange Commission (“SEC”) guidance. 12 | Bethesda, MD Palo Alto, CA rebalance360.com  Item 13: Reviews of Accounts Rebalance’s model portfolios are reviewed periodically by an Investment Advisory Committee made up of Mitchell Tuchman (Managing Director & Chief Investment Officer), Scott Puritz (Managing Director & Chief Compliance Officer), Burton Malkiel, Charles Ellis, Jay Vivian, and Kristi Craig. These reviews are intended to determine that the composition of each model portfolio is achieving the expected goals in line with performance of broad indices of similar risk profile. Registered investment advisor representatives working for Rebalance conduct a thorough review of every client’s financial situation to determine that the selected Rebalance model portfolio is in line with the client’s risk profile. This process takes place using information gathered during the “diagnostic” interview with the client. After the diagnostic session, the client confirms the model portfolio selected and executes an Investment Advisory Agreement. Regularly scheduled reviews with the client help determine if their risk profile has changed over time, which might necessitate a change in the recommended portfolio utilized for that client. Mitchell Tuchman supervises the registered investment advisor representatives working for Rebalance and assists when needed in reviewing specific client situations. Each client has access to view their account through the custodian’s website as well as through Rebalance’s online portal hosted by a third-party vendor. In addition, each client will receive, at least monthly from the custodian, a statement or an email notification that a statement is available, that provides details on the client’s account such as assets held, asset values, and transactions in the account, including deductions for fees. Item 14: Client Referrals and Other Compensation Rebalance may enter into arrangements with individuals, including its own employees or contractors (“Promoters”), who may refer prospective clients to Rebalance. In return, Rebalance agrees to compensate the Promoters, on the basis of an agreed-upon percentage of Rebalance’s investment advisory fee, but only if the referred client enters into a written advisory agreement with Rebalance. Payments to a Promoter are made pursuant to a written agreement between Rebalance and the Promoter. The advisory fee charged to clients will not increase as a result of compensation being shared by Rebalance with a Promoter. 13 | Bethesda, MD Palo Alto, CA rebalance360.com  Item 15: Custody Rebalance, with client written authority, has limited custody of client’s assets through the authority of Rebalance to deduct fees charged by Rebalance directly from client’s accounts. Clients should carefully review account statements for accuracy. Item 16: Investment Discretion For those client accounts where Rebalance provides ongoing investment management, the client has given Rebalance written discretionary authority over the client’s accounts with respect to securities to be bought or sold and the amount of securities to be bought or sold. Details of this relationship are fully disclosed to the client before any advisory relationship has commenced. The client provides Rebalance discretionary authority in the written Investment Advisory Agreement and in the contract between the client and the custodian. Item 17: Voting Client Securities (Proxy Voting) Rebalance will not ask for nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information Rebalance does not require nor solicit prepayment of more than $1,200 in fees for any client six months or more in advance and therefore is not required to include a balance sheet with this brochure. Neither Rebalance nor its management have any financial conditions that are likely to reasonably impair Rebalance’s ability to meet contractual commitments to clients. Rebalance has never been the subject of a bankruptcy petition. 14 | Bethesda, MD Palo Alto, CA rebalance360.com  Privacy Policy Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. Federal law gives customers the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information. Types of Nonpublic Personal Information We Collect We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to your Social Security number, date of birth, banking information and financial account numbers and/or balances, sources of income, credit card numbers, or other information. When you are no longer our customer, we may continue to share your information only as described in this Policy. Parties to Whom We Disclose Information Any investment adviser may need to share personal information to run its everyday business. In the section below, we list the typical reasons that Rebalance may share your personal information: • For everyday business purposes — such as to process your transactions, maintain your account(s), or respond to court orders and legal investigations, or report to credit bureaus; • For our marketing — to offer our products and services to you; • For joint marketing with other financial companies; • For our affiliates’ everyday business purposes — information about your transactions and experiences; • For non-affiliates to market to you. Clients may opt out of sharing information for joint marketing to other financial companies, to our affiliates, and to non-affiliates. If you are a new customer, we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information as described in this Policy. However, you can contact us in writing at any time to limit our sharing. Protecting the Confidentiality of Current and Former Client’s Information To protect your personal information from unauthorized access and use, we use security measures that comply with federal law, including computer safeguards and secured files and building. 15 | Bethesda, MD Palo Alto, CA rebalance360.com  Definitions Affiliates – companies related by common ownership or control. They can be financial and nonfinancial companies; Non-affiliates – companies not related by common ownership or control. They can be financial and nonfinancial companies; Joint marketing – a formal agreement between non-affiliated financial companies that together market financial products or services to you. Please call if you have any questions. Your privacy, our professional ethics, and the ability to provide you with quality financial services are very important to us. 16 | Bethesda, MD Palo Alto, CA rebalance360.com