Tr?id=566623520170033&ev=PageView&noscript=1

SEC Fines Vanguard $19.5 Million for Disclosure Failures in Advisor Compensation Program

Posted on September 30th, 2025 at 3:06 PM
SEC Fines Vanguard $19.5 Million for Disclosure Failures in Advisor Compensation Program

From the desk of Jim Eccleston at Eccleston Law

The Securities and Exchange Commission (SEC) has censured and fined Vanguard Advisers $19.5 million, alleging the firm failed to properly disclose financial incentives tied to its Personal Advisor Services (PAS) program.

According to the SEC’s cease-and-desist order, from August 2020 through December 2023, Vanguard promoted PAS advisors as salaried employees who had “no financial incentives to recommend certain products.” AdvisorHub reports that, in reality, bonuses and raises depended in part on enrolling and retaining clients in PAS, creating conflicts of interest that were not fully disclosed.

While Vanguard acknowledged some incentive structures in its Form ADV supplement, the SEC found that other disclosures—including the required customer relationship summaries and Form ADV brochure—contradicted those statements. According to AdvisorHub, those materials claimed that PAS advisors received no additional compensation. The SEC also determined that Vanguard lacked written policies and procedures reasonably designed to prevent misleading disclosures or to address conflicts arising from its compensation structure.

According to AdvisorHub, PAS blends the services of a Certified Financial Planner with a digital money management platform, offering investment recommendations to retail investors with at least $50,000 in assets. Advisors working with high-net-worth clients were eligible for discretionary bonuses, while those serving mass affluent clients could receive merit raises. Both forms of compensation, however, depended on meeting client enrollment and retention metrics, which directly influenced salary increases and bonus ranges.

Vanguard resolved the matter without admitting or denying the SEC’s findings. The firm cooperated with the investigation, updated its disclosure documents by the end of 2023, and engaged a consultant to review its conflict identification process.

 

Eccleston Law LLC represents investors and financial advisors nationwide in securities, employment, transition, regulatory, and disciplinary matters.

Tags: eccleston, eccleston law, sec, vanguard

Return to Archive

TESTIMONIALS

Previous
Next
Quotes Bigger

Thank You from the bottom of our hearts for all you have done for us. When we realized this was a very bad investment - we did not know where to turn for help. Then we received your name. When we called you - you were so kind to us and then agreed to help us. For this we are so very grateful. The world would be a much nicer place if there were more people like the two of you in it. We will always remember all the help and kindness you have shown us. Thank you so very very much for everything.

Wayne and Judy S.

LATEST NEWS AND ARTICLES

1785858278 Law
August 4, 2026
SEC Fines Former LPL Broker $125,000 for Undisclosed Conflicts in Private Securities Offerings

The Securities and Exchange Commission (SEC) has censured a former LPL Financial broker and imposed a $125,000 civil penalty after finding that he failed to disclose conflicts of interest related to private real estate securities offerings that generated nearly $1.5 million in compensation, as reported by AdvisorHub.

1785772777 Law
August 3, 2026
FINRA Launches Review of High-Risk Structured Notes Sales and Supervision

The Financial Industry Regulatory Authority (FINRA) has launched a regulatory sweep examining the sale of high-risk structured products, with particular attention on non-principal protected "worst-of" structured notes, according to AdvisorHub.

1785531573 Law
July 31, 2026
Former Alabama Financial Advisor Barred After Selling His Practice

The U.S.