Are Vanguard advisors fiduciaries?
Vanguard's advisory programs are fiduciary services. Vanguard Personal Advisor Services, Vanguard Personal Advisor Select, and Vanguard Personal Advisor Wealth Management all run through an arm called Vanguard Advisers, Inc. That arm is a Registered Investment Adviser. It owes clients a fiduciary duty under the Investment Advisers Act of 1940. The brokerage side of Vanguard is a different story. Vanguard Brokerage Services follows Reg BI, the broker rule, not the fiduciary rule. Most Vanguard customers — anyone who just buys index funds and ETFs in a self-directed account — is on the brokerage side. The fiduciary advisory programs are an opt-in product on top of that, with their own fee schedule. Vanguard puts the dual setup in plain English in its Form ADV and Form CRS at adviserinfo.sec.gov. The disclosures are clear. The split is real. Whether you are getting fiduciary advice depends on which Vanguard service you signed up for.
When Vanguard is acting as a fiduciary
Three programs run on the advisory side:
- Vanguard Personal Advisor Services. Hybrid robo plus human, ~0.30% fee, $50K minimum.
- Vanguard Personal Advisor Select. More dedicated CFP access, ~0.30% fee, $500K minimum.
- Vanguard Personal Advisor Wealth Management. Tiered fee starting around 0.30%, $5M minimum, full planning team.
In each, the advisory entity is Vanguard Advisers, Inc. Read its Form ADV Part 2A for the precise terms.
When Vanguard is acting as a broker
A self-directed Vanguard account — IRA, brokerage account, 529, taxable individual — is a brokerage relationship. Vanguard does not give you advice unless you opt into one of the advisory programs. If you call to talk through a fund choice with a phone rep, the rep is operating under Reg BI, not the Advisers Act.
How Vanguard's advisory price compares
Vanguard's ~0.30% advisory fee is much lower than the typical 0.85% to 1.10% AUM rate at independent fee-only RIAs. The trade-off is depth of planning. An independent fee-only RIA usually offers more customized advice, especially for complex households with equity comp, business interests, or estate work. The Vanguard advisor model is best fit for the household with simple-to-moderate planning needs and a portfolio under $5M.
How to confirm which side you are on
Read the Form CRS Vanguard sent you when the account opened. It says, in bold, whether the relationship is brokerage or advisory. You can also check the title of your account — names that include "Personal Advisor" are on the advisory side. Names without it are usually brokerage.