The Robo-Advisors That Don't Call Themselves Robo-Advisors
The SEC has a checkbox for internet advisers. Acorns, Stash, Betterment, Wealthfront, SoFi and Robinhood all leave it blank. Reading Form ADV structurally instead of taking the declaration at face value finds 40 firms managing money for 13.2 million Americans — with 454 people doing the advising.
Fidelon Research · Note 04•September 3, 2026•Revision 1.1
Basis: every figure on this page reflects filings the SEC had on record as of May 12, 2025, and has not been restated since publication. Form ADV client and asset counts are annual and firms revise them freely, so current filings will differ. A later review of filings dated September 7, 2026 reproduces this same group of firms — 40 of them — and the headline finding at 87.4%.
The problem
A self-declaration nobody declares
A rule lets an adviser register with the SEC on the grounds that it gives advice through an interactive website. Form ADV Item 2.A(11) is where a firm says so. It is the regulator’s own robo-adviser flag, and it is free for anyone to check.
It is also nearly empty. Of 21,893 SEC-registered investment advisers on file, 210 check it — just under 1%. The median declaring firm reports 55 clients. Ninety-two of them report fewer than a thousand.
The reason is mundane: the internet-adviser box is a registration path, not a business description. A firm with $100 million in assets or a broker-dealer affiliate already qualifies for SEC registration on other grounds, so it never checks that box — no matter how thoroughly its product is an app. The checkbox tracks how a firm got in the door, not how it delivers advice.
Every firm that declares itself an internet adviser serves 2.0 million clients between them. Acorns, which does not declare, serves 4.8 million by itself.
Any product that classifies advisors by trusting that field inherits the gap. Consumers searching the names they actually know — Betterment, Wealthfront, Stash — land on firms the label has quietly filed as ordinary human advisory practices.
Method
Three structural tests
Rather than ask a firm what it is, ask what its own filing implies it must be. Three measures, all already in what firms report to the SEC, all arithmetic — no model, no guessing, no starting list of names.
- 01
clients ≥ 10,000A firm with a retail app has retail scale. This is the floor for the question being asked; below it, the ratios get noisy.
- 02
clients per advisory employee ≥ 1,000Item 5.B(1) counts only staff performing advisory functions — not engineers, marketers or support. This is the load-bearing test: no human practice reaches 1,000 clients per advising employee. The industry median is 57.
- 03
AUM per client < $100,000Separates consumer apps from institutional sub-advisors and TAMPs, which also run enormous client counts on tiny advisory headcounts — but whose accounts are large. Without this test, Envestnet PMC and Schwab Investment Management land in the consumer bucket.
Why staff headcount, not total headcount
Total employee count and advisory staff count look interchangeable, and are not. Wealthfront Advisers reports far more staff overall than the small team actually doing the advising. Using total headcount, the signal is diluted by everyone who builds the app; using advisory staff only, it resolves.
Stash reports 124 employees in total. It reports 5 people doing the actual advising.
Evidence
The line runs through a quiet region
Plotted together, the three groups occupy separate regions. On this filing, the highest assets-per-client among the 40 app-native firms is $97,205 and the lowest among the excluded institutional managers is $122,351: no firm falls between, a gap of about 26%.
That gap is real but narrow, and it is a property of this one filing date rather than a fixed law. On filings dated September 7, 2026, the same boundary runs from $94,764 to $100,888 — still empty, but only 6.5% wide, with the nearest excluded firm clearing the line by $888. The $100,000 line is best read as a chosen cut that happens to land in a thin part of the distribution, not as a natural line between two kinds of firm.
Both axes are logarithmic. Each mark is one SEC-registered firm reporting client count, advisory headcount and regulatory assets. The shaded band marks the $100,000 assets-per-client line; the dashed line marks 1,000 clients per advisory employee.
The group
Forty firms, 13.2 million clients, 454 advisors
The full result. Declared marks whether the firm checks the SEC’s internet-adviser box — 25 of the 40 do not, and those 25 hold 86% of the group’s clients.
| Firm | Clients | Advisory staff | Clients / advisor | Assets / client | Declared |
|---|---|---|---|---|---|
| AcornsCRD 165926 | 4,813,137 | 17 | 283,126 | $2,157 | No |
| Stash InvestCRD 226550 | 2,282,272 | 5 | 456,454 | $1,825 | No |
| BettermentCRD 149117 | 1,200,673 | 33 | 36,384 | $46,948 | No |
| Guideline Investments, LLCCRD 281515 | 792,653 | 3 | 264,218 | $20,810 | Yes |
| MoneyLionCRD 289521 | 679,253 | 1 | 679,253 | $17 | Yes |
| Human Interest Advisors LLCCRD 269875 | 582,676 | 1 | 582,676 | $11,344 | No |
| Wealthfront Advisers LLCCRD 148456 | 536,340 | 20 | 26,817 | $66,965 | No |
| SoFi Wealth LLCCRD 167958 | 279,216 | 10 | 27,922 | $5,283 | No |
| NomadCRD 307764 | 237,362 | 22 | 10,789 | $1,890 | No |
| Albert Investments, LLCCRD 298006 | 230,377 | 3 | 76,792 | $91 | No |
Sorted by client count. Source: Form ADV Part 1A, as filed May 12, 2025. Fields: Items 1.F(5), 2.A(11), 5.A, 5.B(1), 5.F(2)(c), 5.F(2)(f), 5.I.
Two corrections this produced
Findings that change how the filings should be read
Wrap-fee assets are three fields, not one
A firm’s wrap-fee assets split into three separate buckets on Form ADV: assets where the firm is the sponsor, assets where it is the portfolio manager, and assets where it is both. Reading the sponsor field alone returns $0 for Betterment, Wealthfront, Acorns, SoFi, Titan, all of which are flagged wrap sponsors. Summing all three fields instead returns $56,400,000,000, $35,300,000,000, $10,400,000,000, $1,500,000,000, and $1,100,000,000, in that order. Across the group, 108.7 billion dollars is invisible to the single-field read.
Fifteen of these firms report one advisor or fewer
Between them they serve 1.8 million clients — MoneyLion 679,253 against 1; Human Interest 582,676 against 1; Webull 136,277 against 1. Any rule that treats a near-empty advisory staff count as evidence a firm is dormant will suppress exactly these.
State-registered firms can’t be answered this way
The internet-adviser box is absent from state filings entirely — state-registered advisers aren’t SEC registrants, so the exemption it tracks doesn’t apply to them. The fields this method relies on are present. State-registered app advisers have to be classified this way, structurally, or not at all.
Implication
Who is winning the advice war
Set this group against every other firm that reports retail-comparable clients, and the answer splits in two directions at once.
Human comparison set: 8,930 firms reporting clients, advisory staff and assets, excluding accounts averaging over $5M (family offices and institutional mandates). App-native: the 40 firms above.
Client relationships
Assets under management
Apps have taken 18% of retail advisory relationships and 0.63% of the assets. The average app account holds $13,800; the average human-advised retail account holds $475,210 — 34× larger.
Read one way, the incumbents are untouched: the money has not moved. Read the other way, the apps have already won the relationship with a generation whose balances are small because they are young, and 454 people are servicing 13.2 million of them at 172× the client load of a human practice.
The apps did not take the assets. They took the customers who do not have assets yet.
Which of those readings matters depends on whether those balances grow in place — a question this data cannot answer, but successive annual filings can. This report is one frame of it.
See the 40 firms, scored.
Every investing app and robo-advisor registered with the SEC, scored on what its own filings disclose.
Browse investing apps and robo-advisors →Limits
What this does not establish
- One filing date. Every figure here reflects filings as of May 12, 2025. Client and asset figures are annual and firms restate them freely. No trend is claimed from one snapshot.
- Self-reported throughout. Every field is the firm's own answer on Form ADV. The method replaces a self-declared category with self-declared quantities, which are harder to shade but not audited.
- Thresholds are judgment. 1,000 clients per advisor and $100,000 per account are chosen to sit inside thin regions of the distribution, not derived. Both are defensible; neither is unique. The account threshold is the sensitive one: the empty band around it is 26% wide on this filing date and 6.5% on filings dated September 7, 2026, so firms near the line move in and out between filings. This group's largest members sit orders of magnitude clear of it.
- IA side only. Form ADV covers investment advisers. Broker-dealer-only platforms — Robinhood Financial, Webull's brokerage entity — file with FINRA and are out of scope. Where a brand runs both, only the advisory entity appears.
- Boundary firms are genuinely mixed. Transamerica Retirement Advisors, Gradient and Signal Advisors sit near the AUM-per-client edge; Guided Choice at $88,187 is inside by $12k. These are recordkeeping and retirement-plan businesses that share the arithmetic of an app without being one.