A.General Description of the Company Wealthfront Advisers is an automated investment adviser registered with the SEC. Wealthfront Advisers provides clients’ with software-based investment advisory and portfolio management services through the Wealthfront Advisers Program. This Program, launched in December 2011, is made available via brokerage accounts that all clients open at Wealthfront Brokerage LLC (“Wealthfront Brokerage”), a member of Financial Industry Regulatory Authority (“FINRA”).
Wealthfront Advisers became the successor investment adviser to Wealthfront Inc. effective August 1, 2018. On the same date, Wealthfront Inc. changed its name to Wealthfront Corporation. Software-based financial planning tools and services (as described further in Item 4.B below) are provided by Wealthfront Software LLC (“Wealthfront Software”). Since February 2019, Wealthfront Brokerage has offered a cash account to Clients, (the “Wealthfront Cash Account”), where Wealthfront Brokerage conveys uninvested cash account funds to depository institutions that accept and maintain such deposits (“partner banks”). Neither Wealthfront Brokerage nor its affiliates are a bank. The cash balance in a Client’s Wealthfront Cash Account is swept to one or more partner banks, where it earns a variable rate of interest and is eligible for Federal Deposit Insurance Corporation (“FDIC”) insurance while such cash balance awaits investments. FDIC insurance is not provided, and interest is not earned, until the funds arrive at the partner banks. In addition, Wealthfront Brokerage offers a margin lending product called Portfolio Line of Credit ("PLOC"), which is offered to Clients who meet the required minimum balance in a taxable investment account advised by Wealthfront Advisers, in addition to other minimum account thresholds. Wealthfront Brokerage charges interest on the funds borrowed under a PLOC for the time that the loan is outstanding although it is not due until the loan is repaid. Wealthfront Advisers, Wealthfront Brokerage, and Wealthfront Software are wholly owned subsidiaries of Wealthfront Corporation, which is a privately held company headquartered in Palo Alto, California.
Wealthfront Advisers, Wealthfront Brokerage, and Wealthfront Software are wholly owned subsidiaries of Wealthfront Corporation, which is a privately held company headquartered in Palo Alto, California. Additional information about Wealthfront Advisers’ products, structure and directors is provided on Part 1 of Wealthfront Advisers’ Form ADV which is available online atwww.adviserinfo.sec.govor atwww.wealthfront.com. We encourage visiting our websitewww.wealthfront.comfor additional information.
B. Summary of Investment Advisory Services Wealthfront Advisers offers an automated investment advisory service that makes it possible for anyone who enters into a Wealthfront Advisers Advisory Client Agreement (the “Advisory Client Agreement”), to access state-of-the-art investment advisory and portfolio management services. Clients can choose between portfolios we recommend and the ability to customize our recommendation. As provided in separate Advisory Client Agreements, advisory clients (“Clients”) may grant Wealthfront Advisers either (1) full discretionary authority to manage Client assets; or (2) limited discretionary authority regarding time, price, number of securities, and units or dollar amounts in such securities, while Client retains general investment discretion regarding the specific securities to buy or sell in an Account. Client accounts (“Client Accounts” or “Accounts”) are opened and maintained at Wealthfront Brokerage (and in the case of the 529 college savings plan (“529 Accounts”), the sponsoring state trust fund account) pursuant to the Wealthfront Brokerage Customer Brokerage and Custody Agreement (the “Brokerage Agreement”).
Automated Investing Account Wealthfront Advisers may manage a Client Account on a fully discretionary basis (“Automated Investing Account”). This means that Wealthfront Advisers is authorized to trade our Clients’ ETFs or other investments in an Automated Investing Account to maintain the Client’s target investment allocation. Wealthfront Advisers utilizes software to conduct this trading to invest Client deposits, fund Client withdrawals, perform rebalancing to maintain target portfolio allocations, and execute tax-loss harvesting strategies.
Clients may open an Automated Investing Account that is either: (1) an individualized taxable account or an individual retirement account (“IRA”) that allows Clients to choose between portfolios we recommend and the ability to customize our recommendations; or (2) 529 Accounts. Our Automated Investing Account is a diversified, automated portfolio designed to maximize returns for a Client’s individual risk tolerances and other preferences.
Wealthfront Advisers creates an investment plan and manages a Client’s taxable or IRA portfolio by identifying: 1) optimal asset classes in which to invest, 2) efficient ETFs or other investments to represent each of those asset classes, and 3) an ideal mix of asset classes based on the Client’s specific risk tolerance. Clients may also choose to customize certain of our recommendations and make adjustments to our recommended investment allocations, increasing or decreasing the target percentage of a particular ETF or investment. Clients can also choose from a list of additional ETFs or other investments and request specific allocations to each.
For 529 Accounts, Wealthfront Advisers constructs an individual portfolio based on the Client’s individual risk tolerances that uses up to nine of the 529 plan’s separate municipal fund securities (each a “MFS”), of which each MFS contains a single underlying ETF. Using the Client’s risk score, Wealthfront Advisers assigns the Client’s individual portfolio to one out of 20 glide paths, each of which determines how the Client’s individual portfolio’s allocations of designated portfolios will change over time. Each glide path gradually shifts the asset allocations of the MFSs in the Client’s individual portfolio to progressively decreasing levels of expected risk as the beneficiary’s expected matriculation date approaches. The Client’s starting point along the specific glide path is determined by the beneficiary’s expected time to matriculation.
We do not support Client-customized portfolio allocations for 529 Accounts.
For the taxable Automated Investing Account, Wealthfront Advisers offers tax-loss harvesting (“TLH”) strategies. TLH is a technique designed to help lower your taxes while maintaining the expected risk and return profile of your portfolio. TLH harvests previously unrecognized investment losses to offset taxes due on your other gains and income by selling a security at a loss to accelerate the realization of capital loss and investing the proceeds in a security with closely correlated risk and return characteristics. The realized loss can be applied to lower your tax liability and the tax savings can be reinvested to grow the value of your portfolio.
Wealthfront Advisers’ basic TLH strategy harvests tax losses on a Client’s ETFs by selling an ETF at a loss and replacing it with an alternative ETF that tracks a different, but highly correlated index to maintain the risk and return characteristics of the Client’s portfolio.
Wealthfront Advisers also offers more advanced versions of TLH strategies—available to Clients with larger account sizes—that involve allocating a portion of the Client’s portfolio to a range of individual US stocks, which increases the Client’s opportunity to harvest tax losses. Clients with taxable accounts that have between $100,000 and $500,000 in assets can choose our US Direct Indexing service as an enhanced form of TLH that looks for movements in individual stocks to harvest more tax losses. Instead of using a single ETF or index fund to invest in US stocks, US Direct Indexing purchases the largest individual stocks in the US equity market (the number of such individual stocks purchased depends on account size) on a market-weighted basis to increase the opportunity for tax-loss harvesting presented by the movement of individual stocks.
Clients with a taxable Automated Investing Account that has at least $500,000 qualify for our no-fee Smart Beta service, which serves as an enhancement to our US Direct Indexing service.
Clients who signed up for our US Direct Indexing service may specify US stocks they choose to restrict, but may not customize the portfolio allocations in those accounts. Customization is also not supported in our Automated Bond Portfolio and Automated Bond Ladder offerings.
Further, our Automated Investing Account, Automated Bond Portfolio, and Automated Bond Ladder (described below) are subject to Rule 3a-4 of the Investment Company Act of 1940. This means: (1) Wealthfront Advisers manages each Client’s account based on the Client’s individual financial situation and investment objectives, which information is obtained at account opening; (2) Wealthfront Advisers contacts Clients via email on a quarterly basis to request whether there have been any changes to the Client’s financial situation or objectives; (3) as noted in Item 7.3, Clients may, at account opening or anytime thereafter, impose reasonable restrictions on how their Account is managed by customizing our recommended portfolios or by updating their settings to restrict investments in certain US stocks, (4) Clients may contact Product Support team members (who are Wealthfront Advisers personnel who are knowledgeable about the Accounts and their management) to ask questions relating to their Account; (5) Clients receive monthly statements of all activity in their Account; and (6) Clients retain rights of ownership in the underlying securities in their accounts.
Automated Bond Portfolio Clients may open an “Automated Bond Portfolio,” which is personalized to a Client’s individual tax situation, based on their state of residence and stated,

taxable income. The Automated Bond Portfolio is managed on a fully discretionary basis and includes a diversified mix of bond ETFs.
Wealthfront Advisers utilizes software to invest Client deposits and dividends, fund Client withdrawals, perform rebalancing to maintain target portfolio allocations, and execute tax-loss harvesting strategies where appropriate. For Clients that use Wealthfront Advisers’ Automated Bond Portfolio, Wealthfront Advisers buys or sells securities consistent with a Client’s portfolio allocation, which is designed to seek yield and is personalized to the Client’s individual tax situation.
Automated Bond Ladder Clients may open an “Automated Bond Ladder,” which is a portfolio of US Treasury securities, including Treasury Bills, Treasury Notes, or Treasury Bonds (collectively, “Treasuries”) designed to provide a tax-advantaged means of preserving capital and generating yield with an extremely low risk of principal loss for clients who hold their Treasuries to maturity. The Automated Bond Ladder also seeks to reduce exposure to interest rate fluctuations. The Automated Bond Ladder allows clients to configure a “ladder” of Treasuries with a maximum length that can range from 6 months to 6 years. Wealthfront Advisers manages Automated Bond Ladders on a fully discretionary basis, utilizing software that seeks to invest in Treasuries that mature on a monthly basis through the length of the ladder (assuming Treasuries with the required monthly maturities are available in the market for the entirety of the client’s selected ladder length). As Treasuries mature or interest is paid, Wealthfront Advisers will automatically reinvest the proceeds to purchase new Treasuries with later maturity dates in the Client’s ladder in a way that seeks to maintain as close as possible to equally weighted investment in Treasuries with monthly maturities through the Client’s desired ladder length.
Stock Investing Account Clients may also open a “Stock Investing Account,” which is a taxable account that allows Clients to invest in certain exchange-traded securities, including stocks. In a Stock Investing Account, Clients grant Wealthfront Advisers limited discretion, with Wealthfront Advisers exercising discretion over the specifics of the transaction, including the time, price, number of shares, and units or dollar amounts in the transaction. The Client retains general investment discretion over other matters, including the ultimate decision as to which securities to include in the account. Upon opening a Stock Investing Account, Clients who do not have an active Wealthfront Cash Account must open a separate Wealthfront Cash Account.
Automated Savings In addition to investment advisory and portfolio management services, Wealthfront Advisers offers a service called Automated Savings to Clients, free of charge. Clients may opt into this service and can stop or restart its use at any time at no cost to them. With Automated Savings, Wealthfront Advisers monitors a Client’s checking account or Wealthfront Cash Account for excess cash over the maximum balance set by the Client. If the monitored account has exceeded the Client’s prescribed maximum balance by at least $100, Wealthfront Advisers will schedule transfers of the excess cash from the monitored account to one or more of the Client’s Wealthfront accounts of choice. The Client will receive an email notification when these transfers have been scheduled and will have 24 hours to cancel the transfers before they occur.
Financial Planning Through Software In addition to investment advisory and portfolio management services, Wealthfront Advisers, through its affiliate Wealthfront Software, provides certain software-based financial planning tools and services (the “Financial Planning Service”) to its Clients. The Financial Planning Service is a product offered, free of charge, by Wealthfront Software and is made available to Wealthfront Advisers’ Clients free of charge through a contractual arrangement between Wealthfront Advisers and Wealthfront Software.
Advisory Fees for the Automated Investing Account, Automated Bond Portfolio, and Automated Bond Ladder The Automated Investing Account, Automated Bond Portfolio, and Automated Bond Ladder are “wrap accounts,” meaning they are a professionally managed investment account in which all expenses, including brokerage commissions (if any), management fees, and administrative costs, are “wrapped” into a single charge. Wealthfront Advisers is compensated for its advisory services by charging an annual wrap account fee of 0.25% on the net market value of this type of a Client’s Account. In some cases, Clients can have a portion of their assets managed for free.
Wealthfront Advisers’ fees are charged on a monthly basis and they are not charged in advance.
Fees are charged utilizing the following calculation: Wealthfront Advisers calculates a daily advisory fee, which is equal to the fee rate multiplied by the net market value of the Client’s Account as of the close of trading on the New York Stock Exchange (“NYSE”) (herein, “close of markets”) on such day, or as of the close of markets on the immediately preceding trading day for any day when the NYSE is closed, and then divided by 365 (or 366 in any leap year). The advisory fee for a calendar month is equal to the total of the daily fees calculated during that month (less any deductions or fee waivers) and is deducted from an Automated Investing Account, Automated Bond Portfolio, or an Automated Bond Ladder no later than the tenth business day of the following month.
For 529 Accounts, Wealthfront Advisers waives its investment advisory fees on the first $25,000 it manages for Nevada residents who open a 529 Account, and this fee waiver applies to the aggregate of all of the Nevada residents’ Wealthfront Advisers account assets. This advisory fee is separate from the fees and expenses of the MFSs in which a Client invests in the 529 Account, which include the fees and expenses of the ETFs underlying such securities, the fees of the 529 Account recordkeeper and the fees of the state trust that issues the MFSs (“Plan Administration Fees”). Plan Administration Fees may change without prior notice.
Advisory Fees for the Stock Investing Account In a Stock Investing Account, Clients grant Wealthfront Advisers limited discretion, with Wealthfront Advisers exercising discretion over the specifics of the transaction, including the time, price, number of shares, and units or dollar amounts in the transaction. The Client retains general investment discretion over other matters, including the ultimate decision as to which securities to include in the portfolio. A Stock Investing Account is not a wrap account. As such, a wrap account fee does not apply to them. Instead, Wealthfront Brokerage pays Wealthfront Advisers a percentage of the net interest margin it earns on deposits in Clients’ required Wealthfront Cash Accounts. As a result, Clients pay no out of pocket advisory fees, nor does this reduce the rate of interest clients receive from cash maintained in their Wealthfront Cash Accounts. Proceeds from the sale of securities held in a Stock Investing Account are automatically swept to the Client’s Wealthfront Cash Account. See Item 5 of Wealthfront Advisers’ Form ADV Part 2A brochure for more details on the advisory fee paid in relation to the Stock Investing Account.
Fee Changes Wealthfront Advisers reserves the right, in its sole discretion, to negotiate, reduce or waive the advisory fee for certain Client Accounts for any period of time determined solely by Wealthfront Advisers. In addition, Wealthfront Advisers may reduce or waive its fees for the Accounts of some Clients without notice to, or fee adjustment for, other Clients. For Clients who had opened accounts prior to April 1, 2018, Wealthfront Advisers waived its investment advisory fees for the first $10,000 of assets in any Wealthfront Advisers investment advisory account(s). However, this benefit is no longer available for new Clients who opened their initial account on or after April 1, 2018.
Additional Fees for Optional Brokerage Services In addition to the advisory fees, Clients may also pay other fees or expenses to third parties, as well as to an affiliate of Wealthfront Advisers. The fees discussed in this section are detailed in the Brokerage Agreement and summarized in this section for the Client’s convenience.
Wealthfront Brokerage charges $10 per outgoing wire transfers from a Wealthfront Cash Account. This charge is not collected until the Client has initiated the wire transfer. There are no charges for incoming wire transfers. Currently, outgoing wire transfers are not supported for Investment Accounts.
Other Product Fees The issuers of certain investments we purchase for Clients (such as ETFs, investment trusts, or other investments) may charge Clients separate product fees. Wealthfront Advisers does not charge these product fees to Clients, nor does it benefit directly or indirectly from any such fees.
Product fees typically include embedded fund expenses that may reduce an investment fund's net asset value, and therefore directly affect the fund's performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Fund expenses may include management fees, custodian fees, brokerage commissions, and legal and accounting fees. Fund expenses may change from time to time at the sole discretion of the fund issuer. Wealthfront Advisers discloses current information for the investments we purchase for Clients, including product fees, on the Site. Investments in Wealthfront’s Risk Parity Fund (the “Risk Parity Fund”) are subject to such a product fee. The Risk Parity Fund is managed by Wealthfront Strategies LLC (“Wealthfront Strategies”), an SEC-registered investment adviser and an affiliate of Wealthfront Advisers. Additional information regarding the Risk Parity Fund and related fees and expenses can be found on the Site. In addition, Clients who use the PLOC offered by Wealthfront Brokerage to obtain a loan secured by the assets of their taxable Accounts will be charged interest on the outstanding balance.