This Investment Services Brochure (the “Brochure”) provides information about the qualifications
and business practices of USAA Investment Services Company (“ISCO”), as they relate to the
provision of advice and the referral of prospective investors to certain third-party investment
providers—namely, (1) Charles Schwab & Co., Inc. (“Schwab”), an investment adviser and broker-
dealer registered in both capacities with the U.S. Securities and Exchange Commission (“SEC”) and
a member of the Financial Industry Regulatory Authority (“FINRA”), and (2) Victory Capital
Services, Inc. (“Victory Capital”), a broker-dealer registered with the SEC and a member of FINRA.
ISCO is a direct, wholly owned subsidiary of USAA Investment Corporation and an indirect,
wholly owned subsidiary of the United Services Automobile Association (“USAA”), a diversified
financial services organization. ISCO has been in the investment services and advisory business
since 1970. Prior to May 26, 2020, and under the name USAA Investment Management Company
(“IMCO”), ISCO operated a full-service broker-dealer and investment advisory business, serving retail
and institutional clients. On May 26, 2020, ISCO’s brokerage and advisory businesses, including
client accounts, were sold to Schwab Holdings, Inc., an affiliate of Schwab. ISCO no longer (1)
performs investment management services, (2) maintains client accounts, (3) offers securities or
investment products, or (4) recommends specific securities or investment products. ISCO’s business
is now limited to referring prospective investors to Schwab or Victory Capital, performing certain
referral-related marketing activities, and providing advice with respect to saving for retirement and
retirement income.
Advice
ISCO’s licensed representatives may discuss retirement investments, approach to retirement
investing, risk tolerance, asset allocation, retirement income needs, and related topics. In connection
with these discussions, a representative may provide a Retirement Income Strategy Report (“RIS”).
The RIS is a retirement-focused document that is designed to help the RIS recipient (a “Client”)
assess their particular financial goals, savings strategies, potential risks and impediments to
achieving financial goals, and income distribution planning as these pertain to retirement. The RIS
is not a comprehensive financial plan, but it is intended to facilitate a discussion about saving for
retirement and retirement income planning. The advice contained in the RIS is based on information
you share with ISCO, and, therefore, depends significantly on the accuracy and completeness of what
you supply. Since changes to your information and the assumptions used occur over time, the advice,
including the RIS, applies at the point in time that we provide it.
Because ISCO’s representatives are also licensed insurance agents and appointed by USAA-
affiliated insurance companies to offer annuities, they may discuss and offer annuities as a
retirement income solution in their capacity as, and under the standard of care applicable to,
insurance agents.
Depending upon each Client’s circumstances and preferences, ISCO’s representatives may refer
Clients to Schwab or Victory Capital for investment needs, including specific investment
recommendations. ISCO’s representatives do not make, and the RIS does not contain, any
recommendation of any particular product or service, including those offered by either Schwab or
Victory Capital.
Clients will, as part of receiving their RIS, also receive a copy of this Investment Services Brochure,
ISCO’s Form ADV Part 2B, which contains information about the five ISCO personnel most
responsible for the advice ISCO provides, and ISCO’s Form CRS Relationship Summary. These
documents contain descriptions of ISCO’s advisory business and other disclosures as required by law.
The RIS will only be provided to a Client who agrees to accept the RIS and aforementioned
accompanying disclosures via electronic delivery. If a prospective Client is unable or unwilling to
accept electronic delivery, an RIS will not be published.
Referrals
ISCO’s referral business is conducted by phone, either through licensed representatives of ISCO or
through an interactive voice response system where prospective investors respond to phone
questions but do not speak to a representative, and electronically, either through emails containing
information about Schwab or through a website and mobile platform containing information about
Schwab and Victory Capital.
Referrals
by representatives are made on the basis of information provided by each prospective
investor, including through the RIS if one is created, and the person’s preference for a particular
product or service. A referral does not constitute a recommendation of any particular product or
service offered by either Schwab or Victory Capital. ISCO does not monitor the performance of
investments at Schwab or Victory Capital, and ISCO does not consider investment performance at
either Schwab or Victory Capital when making a referral.
Referrals to Schwab
As an SEC-registered broker-dealer and investment adviser, ISCO refers prospective investors to
Schwab, as well as performs certain marketing services ancillary to such referrals. Schwab is a
dually registered investment adviser and broker dealer (holding both registrations with the SEC), as
well as a member of FINRA, which offers a variety of investment advisory and brokerage services
to its clients. ISCO’s referrals of prospective investors to Schwab are not recommendations of
specific investments or account types. Schwab, and not ISCO, works with prospective investors to
determine what types of investments, accounts, and/or advisory services, if any, are right for them.
Prospective investors must decide whether to open an account with Schwab or to engage Schwab for
advisory services. Such decisions may be guided by ISCO’s provision of information about Schwab
and its offerings. ISCO has no authority or responsibility to make such decisions or to affect any
relationship between a prospective investor and Schwab.
ISCO and Schwab are independent, separate businesses. Schwab is not an agent of ISCO and is not
affiliated, or under common ownership, with ISCO. ISCO does not supervise Schwab or its services,
does not monitor or undertake any duty to evaluate the management or performance of any Schwab
product or account, and is not obligated to provide updated information ab out Schwab subsequent to
a referral.
ISCO and Schwab have entered into a written agreement, under which Schwab pays ISCO a referral
fee that is based on the assets that prospective investors referred by ISCO invest with Schwab. ISCO
provides prospective investors who are referred to Schwab for brokerage services with a copy of
ISCO’s Form CRS Relationship Summary. For prospective investors being referred for advisory
services, ISCO provides its Form CRS Relationship Summary as well as a Referral Arrangement
Disclosure. These documents contain additional information about ISCO and are made available
either at the time of referral or, in certain situations, provided by postal mail shortly thereafter.
Referrals to Victory Capital
In its capacity as a broker-dealer registered with the SEC and a member of FINRA, ISCO also refers
prospective investors who express an interest in the USAA 529 Education Savings Plan1 to Victory
Capital and performs referral-related marketing activities for Victory Capital. Victory Capital is
itself a broker-dealer registered with the SEC and a member of FINRA that offers, among other
things, the USAA 529 Education Savings Plan to its clients. ISCO’s referrals to Victory Capital,
which are made pursuant to a written referral agreement, are not recommendations of a specific
investment or account type. Victory Capital, and not ISCO, will work with prospective investors to
determine whether the USAA 529 Education Savings Plan is right for them.
Prospective investors must decide whether to open an account with Victory Capital. Such decisions
may be guided by ISCO’s provision of information about Victory Capital and its offering. ISCO has no
authority or responsibility to make such decisions or to affect any relationship between a prospective
investor and Victory Capital. As part of making its referral to Victory Capital, ISCO provides
prospective investors with the ISCO Form CRS Relationship Summary. This document contains
additional information about ISCO and is made available either at the time of the referral or, in
certain situations, provided by postal mail shortly thereafter.
ISCO and Victory Capital are independent, separate businesses. Victory Capital is not an agent of
ISCO and is not affiliated, or under common ownership, with ISCO. ISCO does not supervise
Victory Capital or its services, does not monitor or undertake any duty to evaluate the management or
performance of any Victory Capital product or account, and is not obligated to provide updated
information about Victory Capital subsequent to a referral.