Bunker is a investment adviser based in San Francisco, CA, that holds a 82.8/100 Fidelon TransparencyScore (22nd percentile among investing apps), with 2 registered advisors. Score based on public SEC and FINRA filings.
Bunker
Smartadvisor · CRD #319690
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Bunker is an SEC-registered investment adviser in San Francisco, CA. It used to be called Smartadvisor LLC. It has 2 registered advisors. It manages $29.2 million across 138 client accounts. It charges one yearly percentage of your account, and it does not report earning commissions. Its services include financial planning. Its record shows no customer complaints, regulatory actions or fines.
This firm gives advice through an app, not through individual advisors. There is no advisor to look up here — the firm's own record is what you're reading.
Peer Context
Ranked among investing apps, not against advisory firms that work with you in person.
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Charges fixed fees for specific services
- Does not earn commissions on product sales
What you’d pay
Your balance falls in the $8,000 and above band, charged at 0.50% on the full amount.
This fee is negotiable
“Fees may be waived, reduced, or negotiated at BUNKER’s discretion.”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Clients may incur additional charges including but not limited to wire transfer and electronic funds fees, and other miscellaneous fees and taxes on brokerage account and securities transactions. Exchange Traded Funds also charge internal management fees, which are disclosed in a fund’s prospectus. The fees and expenses charged by the ETFs are separate and distinct from the fee charged by BUNKER.
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| $8,000 and above | 0.50% |
Billed monthly in arrears
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Fee-only compensation — no commission income reported
- Registered as investment adviser with fiduciary obligation
- No broker-dealer registration — advisory services only
- Clean regulatory record — no disclosures, arbitrations, or fines
- Transparent fee structure — charges advisory fees, no commissions
Things You Should Know
- Its brochure names payments to people who refer clients to the firm as a conflict, but it does not explain what this arrangement tempts the firm to do, say what the firm is paid for it, or say what it can cost you. Ask whether anyone was paid to refer you to the firm, and whether that affects what you pay.Items 10, 11, 12.B and 14
- Brochure fee terms — not found in the brochure: fee schedule; deducted from the account or billed (Item 5)
Conflict Audit
Zero material conflicts identified in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
What this firm says about how it gets paid
“more assets you have in the advisory account, including cash, the more you will pay us. We therefore have an incentive to increase the assets in your account in order to increase our fees.”
“We direct execution of client securities through APEX”
Source: the firm’s own Form CRS, filed 2024-05-17 — quoted directly
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
81/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
50/100
Weak
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Their two-page relationship summary
The SEC requires every SEC-registered investment adviser to hand you this summary, called a Form CRS, and says what it must cover. We checked this firm's against that list. What is a Form CRS?
- Does it include everything the SEC requires?
- Required sections
- 86/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
What to askAsk the advisor to name every way the firm gets paid besides your fee, and how each one can affect their advice.
- 45/100
- Can you tell what you would pay?
- What you pay
- 95/100
- Is it written in plain English?
- Plain language
- 91/100
This firm's Form CRS averages 79 out of 100. It adds 4.81 points once the firm's filings and record score 90 on their own; they score 82.8 today.
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity53/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Can you tell what you'd pay?Not found in the brochureItem 5.A
Without a fee schedule you cannot compare this firm with any other.
What to askAsk for the fee schedule in writing, including what you would pay at your account size.
- Does it say whether the fee can be negotiated?CoveredItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
Fees may be waived, reduced, or negotiated at BUNKER’s discretion.p. 6
- Does it say whether the fee comes out of your account or gets billed?Not found in the brochureItem 5.B
A fee taken straight from your account is easy to stop noticing.
What to askAsk whether fees are taken from your account automatically, and how you will see each charge.
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
BUNKER’s fees are billed and deducted monthly in arrears based on a percentage of AUM or minimum monthly fee of $10 for accounts below $8,000p. 6
- Does it list the other costs you pay, like fund and custodian fees?CoveredItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
Clients may incur additional charges including but not limited to wire transfer and electronic funds fees, and other miscellaneous fees and taxes on brokerage account and securities transactions.p. 8
- Does it say how you get money back if you leave mid-period?Does not applyItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity50/100
The SEC asks the brochure to name each way the firm gets paid besides your fee, what that tempts the firm to do, and what it can cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
If the firm pays people who refer clients, does it explain those payments?
Payments to people who refer clients to the firm
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
In the event a client is introduced to BUNKER by either an unaffiliated or an affiliated promoter, BUNKER may pay that promoter a referral fee in accordance with applicable state securities laws and fully in compliance with requirements of Rule 206(4)-1 under the Advisers Act.p. 19
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether anyone was paid to refer you to the firm, and whether that affects what you pay.
If the firm is paid for referring clients elsewhere, does it explain those payments?
Payments received for referring clients elsewhere
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
When BUNKER endorses or recommends the use of certain products or services identified as partnerships, be advised that such recommendations might be the result of a partnership or referral agreement where BUNKER may receive payment or other consideration for such referral.p. 19
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether the firm is paid when it sends you to another company, and by whom.
Do they earn commissions on products, and do they say so?Brochure Sales CompensationNot applicable
Not applicable: the brochure describes no product-sales commissions
Do they get free research or services from brokers, and does it affect you?Brochure Soft DollarsNot applicable
Not applicable: the brochure describes no research or services from brokers
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
Next Steps
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.15 · CRD #319690