Vanguard Advisers is a investment adviser based in Malvern, PA, that holds a 56.7/100 Fidelon TransparencyScore (0th percentile among investing apps), with 2,281 registered advisors. Score based on public SEC and FINRA filings.
Vanguard Advisers
Vanguard Advisers, INC. · CRD #106715
A registered investment adviser held to a fiduciary standard.
Fidelon Fact Sheet
Vanguard Advisers, INC. is an SEC-registered investment adviser in Malvern, PA. Its 2,281 registered advisors typically serve individuals and families and pension and profit-sharing plans. It manages $344.6 billion across 791,528 client accounts. It charges a percentage of the money it manages for you, and it does not report earning commissions. Its services include financial planning, portfolio management, educational seminars and investment newsletters. It reports that it can hold or access client money, which the SEC requires firms to disclose. It has regulatory actions on file, most recently in 2025.
This firm gives most advice through an app and also has 2,584 registered advisors. You may not be matched with a specific one.
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
Specializations
Extracted from Form ADV Part 2A brochure
Who They Typically Serve
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
- Transparent fee structure — charges advisory fees, no commissions
Things You Should Know
- 4 regulatory complaints in public regulatory filings
- $39M in regulatory fines
- Registration filings contain less detail about business practices and client commitments than higher-scoring firms
Conflict Audit
Our analysis identified 1 potential conflict of interest 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
“As you invest more assets in the programs, the amount of fees we collect will increase; therefore, there could be an incentive to encourage you to increase your assets.”
“The funds’ expense ratios are received by The Vanguard Group, Inc., an affiliate, as revenue.”
Source: the firm’s own Form CRS, filed 2026-03-30 — quoted directly
Regulatory Track Record
4
Disclosures
$39M
Total Fines
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
60/100
Weak
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.
43/100
Weak
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.
60/100
Fair
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
65/100
Fair
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
- 84/100
- 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.
- 50/100
- Can you tell what you would pay?
- What you pay
- 78/100
- Is it written in plain English?
- Plain language
- 95/100
This firm's Form CRS averages 77 out of 100. It adds 4.19 points once the firm's filings and record score 90 on their own; they score 56.71 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 Clarity59/100
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?Not found in the brochureItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
What to askAsk whether the fee is negotiable, and what other clients at your account size pay.
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
Fees will be assessed quarterly (approximately every 90 days) and based on your average daily balance in each holding of each Enrolled Account across the entire fee period after the completion of a fee period and will generally be deducted within 30 days of assessment.p. 22
- 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.
Fees will be assessed quarterly (approximately every 90 days)p. 22
- 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.
You will be responsible for paying underlying fund, collective investment trust, or ETF expenses charged at the individual holding levels within your Enrolled Accounts.p. 18
- 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 Specificity57/100
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 it has an affiliated adviser or private fund, does it explain what that means for you?
An affiliated adviser or private fund
- 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 giving advice to Clients, we will recommend the purchase of Vanguard Funds serviced by our corporate parent, Vanguard.p. 50
- 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?CoveredStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
Acting in accordance with our advice to purchase Vanguard’s proprietary funds will result in the payment of fees to the Vanguard Funds that are separate from, and in addition to, any advisory fees assessed by us.p. 51
- 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 any fund or adviser recommended to you is owned by or tied to the firm, and what fees that adds.
If it uses an affiliated broker-dealer, does it explain what that means for you?
An affiliated broker-dealer
- 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 giving advice to Clients, we will recommend the purchase of Vanguard Funds distributed by our affiliate, VMC.p. 51
- 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 your trades or products go through a company the firm owns or is tied to, and what that costs.
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.
These Referral Programs may include compensating Clients, affiliates, strategic partners, or third‐party solicitors for referring the Services to prospects.p. 58
- 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?CoveredStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
Compensation will include flat fees or payments based on certain performance triggers, like enrolling in the Services.p. 58
- 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.
Do they earn commissions on products, and do they say so?Brochure Sales Compensation71/100
When a firm or its people sell products for a commission, the SEC asks the brochure to say so, name the pull, and tell you whether you could buy elsewhere.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it say that earning commissions is a conflict of interest?CoveredItem 5.E.1
A firm paid to sell a product has a reason to recommend it that has nothing to do with you.
VMC receives transaction fees, front- and back-end loads, sales charges, and 12b-1 fees in connection with certain transactions in third-party mutual funds through VMC’s FundAccess® program.p. 20
- Does it say commissions can shape what they recommend?CoveredItem 5.E.1
Naming the pull is the first step to controlling it; silence leaves it working on you.
These may be considered revenue sharing and represent a significant source of revenue for VMC.p. 20
- Does it say you can buy the same products elsewhere?Not found in the brochureItem 5.E.2
You may be able to buy the same product for less somewhere else.
What to askAsk whether you could buy any recommended product through another broker or insurer.
- Does it say whether commissions lower your advisory fee?Does not applyItem 5.E.4
If the firm earns a commission and the full advisory fee, you pay twice for one recommendation.
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
Advisor Roster
2,281 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Troy Carl Watson | 2593856 | — | — |
| Joanne Marie Samples | 2120904 | — | — |
| Robert Harvey Pothier | 4409678 | — | — |
| James Louis Duchene | 4655062 | — | — |
| Elisheba Pheodosia Gainey | 4859397 | — | — |
| Oliver Beecher Bailey III | 1719155 | — | — |
| Michael Leslie Perhne | 1997876 | — | — |
| Gail Marjorie Tshudy | 4285217 | — | — |
| John Onufreiczuk | 4320440 | — | — |
| Gladimir Ambroise | 2964035 | — | — |
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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 #106715