The Apps Took the Customers. They Did Not Take the Money.

The question

Two scoreboards, two winners

Ask who is winning the market for financial advice and the answer depends entirely on what you count. Count people, and the apps are a serious force. Count dollars, and they barely register.

A structural review of the SEC’s filings identified 40 firms that deliver advice through an app — found by how they actually operate, not by trusting the SEC’s internet-adviser checkbox, which turns out to miss most of them. This note sets that cohort against the rest of the retail advisory industry and asks what share each side actually holds.

The comparison group is 9,570 firms reporting client counts, advisory staff and regulatory assets, with average accounts under $5 million — a cut that removes family offices and institutional mandates from what is meant to be a retail comparison. Both cohorts exclude Exempt Reporting Advisers, which file no client or asset data at all.

Neither figure is a projection or an estimate. Both are sums of what firms reported on Form ADV Part 1A, Items 5.F(2)(c) and 5.F(2)(f), in the SEC’s records as of September 7, 2026.

Evidence

The gap is account size, and it is 34 times wide

A single number reconciles the two scoreboards. The average account at an app-native firm holds $14,980. The average account at a human retail advisory firm holds $509,034.

That is the whole story. The apps are not competing for the same accounts and losing. They are holding a completely different kind of account — and holding a great many of them.

The median tells a sharper version of the same story than the mean does. The median app-native account holds $6,393; the median human-advised retail account holds $504,865. Within the app cohort the mean sits well above the median because a handful of firms — the ones whose customers use them as an actual investment account rather than a spare-change tool — pull it upward.

Evidence

Forty firms, 558 people, 13.4 million clients

The labour side of the comparison is the most extreme figure in the data. App-native firms report 558 advisory employees between them — against 376,739 at the human firms. That is one seventh of one percent of the industry’s advisory workforce serving one sixth of its relationships.

Per person: 24,038 clients at an app-native firm, 176 at a human one. A factor of 137.

Advisory staff is Item 5.B(1) — employees performing investment advisory functions — not Item 5.A total employees, which counts engineers and operations staff and runs 10 to 30 times higher at these firms. Source: Form ADV Part 1A, snapshot 2026-09-07.

One firm in this cohort reports serving 738,184 clients with zero advisory employees. That is not a filing error and not an outlier to be discarded: it is what a fully automated advisory product looks like on a regulatory form designed for firms staffed by people.

Context

Two readings, both defensible

The same two numbers support opposite conclusions about the industry’s future, and Form ADV cannot settle which is right.

Which reading proves correct turns on a single question this data cannot answer: do those balances grow in place? If a $14,980 app account becomes a $150,000 app account over twenty years, the relationship share was the leading indicator and the asset share was a lagging one. If those customers move to a human advisor at the point their balance becomes worth advising on, then the apps are a customer-acquisition channel for the incumbents rather than a competitor to them.

Form ADV records one year at a time. Successive annual filings will answer it; a single snapshot cannot, and this report does not claim to.

Context

Not every app client chose an app

Seven firms in the cohort — retirement-plan and health-savings platforms — account for 1,845,255 clients, or 13.8% of the total. Their customers did not download anything. They were enrolled through an employer, and the advisory relationship arrived with the job.

They belong in the cohort: they deliver advice at app-like scale with app-like staffing, which is what the tests measure. But “consumers are choosing apps” is not the right description of that 13.8%. The remaining 11.57 million clients across 33 firms did choose directly, and that is the figure to use for any claim about consumer preference.

Concentration is worth stating plainly too: the five largest firms hold 72.7% of the cohort’s clients. This is not a broad field of forty comparable competitors. It is a handful of large platforms and a long tail.

Limits

What this does not establish

• One snapshot, named and dated. Every figure comes from SEC filing data as of September 7, 2026. Client and asset figures are annual and firms restate them freely. No trend is claimed from one frame.
• Self-reported and unaudited. Every field is the firm's own answer on Form ADV. This method replaces a self-declared category with self-declared quantities, which are harder to shade but are not audited by anyone.
• The comparison set is a choice. 9,570 firms with average accounts under $5 million. The cut is disclosed in the note along with what happens without it. A different reasonable cut would move the asset share; it would not move the relationship share materially.
• Relationships are not people. Item 5.F(2)(f) counts client relationships, not individuals. One household with three accounts at one firm may appear as one client or three depending on how that firm reports. Neither cohort is immune, but app firms with per-goal accounts are likelier to count higher.
• Investment advisers only. Form ADV covers investment advisers. Brokerage-only platforms file with FINRA and are out of scope entirely. Where a brand operates both, only the advisory entity is counted here.
• No firm is assessed. This report describes structure and scale. Nothing here evaluates the quality, suitability or cost of any firm's advice, and no firm named is characterized as better or worse than another.