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

That is just fantastic! Thank you very much!

Julie N.

LATEST NEWS AND ARTICLES

December 22, 2025
FINRA Overhauls Arbitration Rules to Rebalance Arbitrator Selection and Codify Forum Practices

The Financial Industry Regulatory Authority (FINRA) has approved significant amendments to its Codes of Arbitration Procedure designed to rebalance public arbitrator selection, increase transparency, and formalize several long-standing practices in the arbitration forum.

December 19, 2025
Industry Groups Press Senate at Advance Financial Exploitation Prevention Act

Several industry associations are urging the U.S. Senate to pass the Financial Exploitation Prevention Act, legislation that would allow mutual fund companies and their transfer agents to delay redemptions when they reasonably suspect elder financial abuse.

December 18, 2025
UBS Warns of Rising Default Risk in Private Credit

A UBS report signals that credit stress likely will intensify next year as borrowers confront inflation, elevated interest costs, and softening consumer conditions.