F Or M Adv P Ar T 2a We Al Th Fron T Ad Vi S E R S Cl I E N T B

Summary

261 Hamilton Avenue
Palo Alto, California 94301
www.wealthfront.com
Form ADV Part 2A
Wealthfront Advisers
Client Brochure
October 29, 2021
Item 1 Cover Page
This brochure (“Brochure”) provides information about the qualifications and business
practices of Wealthfront Advisers LLC (“Wealthfront Advisers”), an investment adviser
registered with the United States Securities and Exchange Commission (“SEC”)

Registration does not imply a certain level of skill or training but only indicates that
Wealthfront Advisers has registered its business with state and federal regulatory
authorities, including the SEC (our SEC number is 801-69766). The information in this
Brochure has not been approved or verified by the SEC or by any state securities
authority

If you have any questions about the contents of this Brochure, please contact us at
844-995-8437 or [email protected] Additional information about Wealthfront
Advisers is also available on the SEC’s website at www.adviserinfo.sec.gov and on
Wealthfront Advisers’ website, www.wealthfront.com (the “Site”)

Item 2 Material Changes
Since the last updating amendment to Wealthfront Advisers’ Form ADV Part 2 brochure on
April 28, 2021, there have been no material changes to this Brochure

Item 3 Table of Contents
Item 1 Cover Page 1
Item 2 Material Changes 2
Item 3 Table of Contents 3
Item 4 Advisory Business 4
Item 5 Fees and Compensation 8
Item 6 Performance-Based Fees and Side--by--Side Management 9
Item 7 Types of Clients 10
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 11
Item 9 Disciplinary Information 22
Item 10 Other Financial Industry Activities and Affiliations 23
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 23
Item 12 Brokerage Practices 24
Item 13 Review of Accounts 25
Item 14 Client Referrals and Other Compensation 26
Item 15 Custody 26
Item 16 Investment Discretion 27
Item 17 Voting Client Securities 27
Item 18 Financial Information 28
Item 4 Advisory Business
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 (See Wealthfront Advisers Program
Brochure attached). 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, 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 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 have at least $25,000
invested in a taxable investment account advised by Wealthfront Advisers. 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, CA. As of October 21, 2021,
Wealthfront Corporation oversaw, through its wholly owned subsidiaries Wealthfront Advisers
and Wealthfront Brokerage, approximately $27.67 billion in assets for 462,619 clients

Additional information about Wealthfront Advisers’ products, structure and directors is provided
on Part 1 of Wealthfront Advisers’ Form ADV which is available online at
www.adviserinfo.sec.gov or at www.wealthfront.com. We encourage visiting our website
www.wealthfront.com for 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. As provided in the Advisory Client Agreement, advisory clients (“Clients”) grant
Wealthfront Advisers discretionary authority to manage Client assets in accounts (“Client
Accounts” or “Accounts”) opened and maintained at Wealthfront Brokerage (and in the case of
the 529 college savings plan, the sponsoring state trust fund account) pursuant to the Wealthfront
Brokerage Customer Brokerage and Custody Agreement (the “Brokerage Agreement”)

Wealthfront Advisers’ investment objective is to seek maximum long-term, risk-adjusted,
after-tax, net of fee returns

Taxable Accounts and Individual Retirement Accounts (“IRAs”)
Each individualized taxable or IRA account allows Clients to choose between portfolios we
recommend and the ability to customize our recommendations. Our recommended portfolios are
designed to maximize returns for Clients’ individual risk tolerances and other preferences

Wealthfront Advisers creates an investment plan and manages a Client’s portfolio by identifying:
1) optimal asset classes in which to invest, 2) efficient exchange traded funds (“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 who choose to customize our recommendations can
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. Wealthfront
Advisers may limit Client allocations to certain investments or groups of investments

Wealthfront Advisers manages Client Accounts on a discretionary basis. This means that
Wealthfront Advisers is authorized to trade our Clients’ ETFs or other investments 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

For taxable accounts, 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 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 taxable Investment Accounts that have at least $500,000 qualify for our
no-fee Smart Beta service, which serves as an enhancement to our US Direct Indexing service

College Savings Accounts
Wealthfront Advisers also serves as the Client’s automated investment adviser for 529 college
savings accounts (which consist of an account with the sponsoring state trust fund and a related
brokerage account at Wealthfront Brokerage) (“529 Accounts”). Once again, Wealthfront
Advisers’ investment objective is to seek maximum, long-term, risk-adjusted, after-tax, net of fee
returns. Based on the Client’s individual risk tolerances, Wealthfront Advisers constructs an
individual portfolio for the Client using up to nine of the 529 plan’s separate municipal fund
securities (each a “MFS”), of which each MFS contains a single underlying ETF. Wealthfront
Advisers designs the Client’s individual portfolio to provide a diversified asset allocation. 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

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 Service Through Software
In addition to investment advisory and portfolio management services, Wealthfront Advisers,
through its affiliate Wealthfront Software, also provides certain software-based financial
planning tools and services (the “Financial Planning Service”) to its Clients. The Financial
Planning Service is a product offered by Wealthfront Software and is made available to
Wealthfront Advisers’ Clients free of charge through a contractual arrangement between
Wealthfront Advisers and Wealthfront Software. The Financial Planning Service allows Clients
to explore potential future financial scenarios, including retirement, college funding and
purchasing a home, and provide recommendations for reaching their financial goals. The
Financial Planning Service allows Clients to link their external financial accounts, including
bank, brokerage, retirement, college savings, loan and credit card accounts and mortgages, in
order to eliminate the need for the traditional financial planner interview that is usually required
to acquire the necessary inputs to build a financial plan

Wealthfront Advisers and Wealthfront Software do not represent that the Financial Planning
Service is meant to replace a comprehensive evaluation of a Client's entire financial plan
considering all the Client’s circumstances. Should a Client choose to implement any
recommendation made by the Financial Planning Service, the Client should consult with their tax
advisor regarding the Client’s personal circumstances. Implementation of a financial plan
recommendation is entirely at the Client’s discretion, and currently information Clients enter into
the financial planning model, or obtained by linking other accounts, does not automatically change
their risk scores. Clients can only change their risk scores by changing their personal financial
information through the Site. While the data from third parties used in the financial models of the
Financial Planning Service is believed to be reliable, Wealthfront Advisers or Wealthfront
Software cannot ensure the accuracy or completeness of data provided by clients or third parties

C. Tailored Services and Investment Restrictions
Wealthfront Advisers tailors its software-based investment advisory service to the individual
needs of each of its Clients, in accordance with the portfolio allocation chosen by Clients, and
subject to certain account limitations that prospective investors should consider, as described
further below and in Item 7. Wealthfront Advisers uses its software to determine an investor’s
risk tolerance. Wealthfront Advisers asks each prospective Client a series of questions to evaluate
both the individual’s objective capacity to take risk and subjective willingness to take risk. We
ask subjective risk questions to determine both the level of risk an individual is willing to take
and the consistency among the answers. For example, if an individual is willing to take a lot of
risk in one case and very little in another, then the individual is deemed inconsistent and is
therefore assigned a lower risk tolerance score than the simple weighted average of their
answers. We ask objective questions to estimate with as few questions as possible whether an
individual is likely to have enough money saved at retirement to afford their likely spending
needs. The greater the excess income, the more risk the Client is able to take. As noted in Item
7.3, Clients who signed up for our US Direct Indexing service may specify US stocks they
choose to restrict

D. Wealthfront Advisers Program
Client assets at Wealthfront Advisers are managed as part of the Wealthfront Advisers Program
(See Wealthfront Advisers Program Brochure attached). A Wealthfront Advisers Program
account for Clients (technically known as a “wrap account”) is a professionally managed
investment plan in which all expenses, including brokerage commissions (if any), management
fees, and administrative costs, are “wrapped” into a single charge. The Wealthfront Advisers
Program provides Clients with investment plans, portfolio management, and necessary brokerage
services for one comprehensive fee based on a percentage of the Clients’ respective account
assets

For Clients that use Wealthfront Advisers’ recommended portfolio allocation, Wealthfront
Advisers may buy or sell securities consistent with a Client’s investment plan, which is designed
to seek an investment return suitable for the goals and risk profile of each distinct Client
Account. For Clients that customize our recommended portfolio allocation, Wealthfront Advisers
may buy or sell securities consistent with a Client’s target portfolio allocation. Wealthfront
Advisers determines when to buy or sell securities by reviewing each Client’s individual account
and Client-provided data. This review may include type of account, goals, overall financial
condition, income, assets, risk tolerance, Client instructions or preferences, and other factors
unique to the individual Client’s situation. Wealthfront Advisers manages each Client Account
on an individualized basis

In order to implement Wealthfront Advisers’ continuous investment advice, Wealthfront
Advisers provides investment advisory and portfolio management services under the Wealthfront
Advisers Program only on a fully discretionary basis

E. Discretionary and Nondiscretionary Assets
Wealthfront Advisers manages approximately $24,868,743,770 in client assets through our
software-based investment advisory service on a discretionary basis. This total is calculated
using the closing US market prices from October 21, 2021. Wealthfront Advisers does not
manage any Client assets on a non-discretionary basis

Item 5 Fees and Compensation
A. Advisory Fees
Wealthfront Advisers is compensated for its advisory services by charging an annual fee of
0.25% on the net market value of a Client’s Account. This fee applies whether Clients choose
portfolios we recommend or choose to customize our recommendations. 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

Automated Savings
Wealthfront Advisers offers the free service Automated Savings as described above in Item 4

Financial Planning Service
Through its affiliate Wealthfront Software, Wealthfront Advisers offers the Financial Planning
Service, as described above in Item 4, to all Clients free of charge

Taxable Accounts and IRAs
Wealthfront Advisers’ software-based investment advisory service charges an annualized fee of
0.25% on a Client’s assets under management. In some cases, Clients can have a portion of their
assets managed for free. Annual fees are charged on a monthly basis as explained below

Wealthfront Advisers’ fees are not charged in advance and are calculated on a continuous basis
and deducted from Clients’ Accounts each month as follows: 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 Client Accounts no
later than the tenth business day of the following month

College Savings Accounts
Wealthfront Advisers also charges an annual fee of 0.25% on the net market value of a 529
Account for its investment advisory services in connection with the account. 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 resident’s Wealthfront Advisers account assets. This waiver continues to be available to
Nevada residents who opened a 529 Account after April 1, 2018

This advisory fee is separate from the fees and expenses of the MFSs in which a Client invests in
the Client’s colleges savings 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

B. Other Account Fees
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 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

Item 6 Performance-Based Fees and Side--by--Side Management
Wealthfront Advisers does not charge performance-based fees. Clients are only charged an
annual advisory fee as disclosed in Item 5 above

Item 7 Types of Clients
The minimum amount required to open and maintain an account with Wealthfront Advisers is
$500. As a result of the automation associated with offering its services online, Wealthfront
Advisers makes it possible for retail investors, as well as retirement accounts and trusts, to access
its service with much lower account minimums than normally available in the industry. Clients
have access to their Accounts through the Site. Additional requirements for opening an Account
with Wealthfront Advisers are described in Item 4 above

At any time, a Client may terminate an Account, withdraw all or part of an Account (provided
the Account balance does not fall below $500 because of the withdrawal), update their
investment profile (i.e. risk score), or customize our recommended portfolio allocation
(including adding or removing specific ETFs or other investments from their designated
allocation). These actions may initiate an adjustment in the Account’s holdings. In such cases,
unless otherwise directed by the Client, Wealthfront Advisers will sell the securities in the Client
Account (or portion of the Account, in the case of a partial withdrawal or update) at market
prices in a reasonable and timely manner. However, Wealthfront Advisers does not represent or
guarantee that Wealthfront Advisers will respond to any such Client actions or requests
immediately or in accordance with a set time schedule. See Item 16 for a description of
Wealthfront Advisers’ discretionary investment authority, including the timing of Wealthfront
Advisers’ placement of Client trade orders

Investors evaluating Wealthfront Advisers’ software-based investment advisory service should
be aware that Wealthfront Advisers’ relationship with Clients is likely to be different from the
“traditional” investment advisory relationship in several aspects:
1. Wealthfront Advisers is a software-based investment adviser which means each Client
must acknowledge their ability and willingness to conduct their relationship with
Wealthfront Advisers on an electronic basis. Under the terms of the Advisory Client
Agreement and the Brokerage Agreement, each Client agrees to receive all Account
information and Account documents (including this Brochure and the Wealthfront
Advisers Program Brochure), and any updates or changes to same, through their access to
the Site and Wealthfront Advisers’ electronic communications. Unless noted otherwise on
the Site or within this Brochure, Wealthfront Advisers’ investment advisory service,
Wealthfront Brokerage’s brokerage services, the signature for the Advisory Client
Agreement and the Brokerage Agreement, and all documentation related to the advisory
services are managed electronically. Wealthfront Advisers does make individual
representatives available to discuss servicing matters with Clients

2. To provide its investment advisory services and tailor its investment decisions to each
Client’s specific needs, Wealthfront Advisers collects information from each Client,
including specific information about their investing profile such as financial situation,
investment experience, and investment objectives. Wealthfront Advisers maintains this
information in strict confidence subject to its Privacy Policy, which is provided on the
Site. Although Wealthfront Advisers contacts its Clients periodically as described further
in Item 13 below, a Client must promptly notify Wealthfront Advisers of any change in
their financial situation or investment objectives that might require a review or revision of
their portfolio

3. Clients can choose a portfolio Wealthfront Advisers recommends, which includes
allocations to preselected ETFs or customize our recommended portfolios by increasing
or decreasing portfolio allocations to the ETFs or investments in our recommended
portfolio or by choosing from a list of available ETFs or other investments and requesting
specific allocations to each. Wealthfront Advisers allows Clients to restrict Wealthfront
Advisers from investing in the stocks of public companies designated by the Client. The
Risk Parity Fund may also be included for taxable Client Accounts with a minimum
account size of $100,000 if the Client so chooses

4. Clients may not place orders to purchase or sell securities on a self-directed basis

Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
A. Modern Portfolio Theory (“MPT”)
Wealthfront Advisers offers two types of recommended, diversified, automated portfolios to
clients: Classic portfolios and Socially Responsible portfolios. Classic portfolios include
allocations to preselected ETFs designed to provide a tradeoff between risk and long-term,
after-tax, net-of-fee return through a diversified set of global asset classes. Socially Responsible
portfolios are designed to offer similar risk-adjusted returns as our Classic portfolios with a focus
on socially responsible investing (“SRI”). Although SRI does not have a single, agreed-upon
definition, it may be described as an investment strategy that evaluates companies based on their
benefit and/or detriment to society, rather than profits or intrinsic value alone. This concept
comes from an ethical framework called “social responsibility,” in which individuals and
corporations have an obligation to cooperate with others to benefit greater society. Some
investors may take up SRI strategies due to a long-term belief in its investment value, and others
may decide to use this strategy purely due to ethics

The composition of Classic and Socially Responsible portfolios is based on Modern Portfolio
Theory (“MPT”). MPT attempts to maximize a portfolio’s expected return for a given amount of
portfolio risk, or equivalently minimize risk for a given level of expected return, by selecting the
proportions of various asset classes rather than selecting individual securities. Historically,
rigorous MPT-based financial advice has been available primarily through certain high-end
financial advisors. Wealthfront Advisers’ goal is to enable anyone with at least $500 to access the
benefits of MPT

Prior to the launch of the Wealthfront Advisers software-based investment advisory service, it
was not practical to offer rigorous and complete MPT to everyone because delivering a complete
solution was too complex. Specifically, the number of calculations required to identify an
optimized asset allocation, the ideal securities to represent each asset class, and an individual’s
true risk tolerance are beyond the scope of free, web-based tools. The job becomes even more
difficult when considering the importance of periodically rebalancing a portfolio to maintain a
desired risk level

To employ MPT properly, one must start with an accurate determination of an individual’s
objective and subjective tolerance for risk. Achieving accuracy requires sophisticated software
applied to more detailed questions than are typically asked by advisers. Based on this risk
analysis, Wealthfront Advisers seeks to create an individualized investment plan using the
optimal asset classes in which to invest, the most efficient and inexpensive ETFs to represent
each of those asset classes, and the ideal mix of asset classes based on the Client’s specific risk
tolerance. Wealthfront Advisers uses Mean Variance Optimization to rigorously evaluate every
possible combination of the following twelve asset classes: US equities, foreign developed
markets equities, emerging markets equities, dividend growth equities, real estate, natural
resources, treasury inflation protected securities (TIPS), municipal bonds, corporate bonds,
emerging markets bonds, risk parity and US government bonds. Mean Variance Optimization
uses the expected return and volatility for each asset class and the covariance among asset classes
to find the combination that delivers the highest possible return for any given standard deviation
of a portfolio’s returns. Wealthfront Advisers, however, must limit the number of assets classes
for very small portfolios. Further, the risk parity asset class is only available to taxable Client
Accounts with a minimum account size of $100,000

Wealthfront Advisers periodically reviews the entire population of more than 1,000 ETFs to
identify the most appropriate ETFs to represent each asset class in our recommended portfolios

We look for ETFs that minimize cost and tracking error and offer market liquidity. Many
investors do not realize that ETFs do not exactly track the indexes they were created to mimic

Choosing an ETF with a low expense ratio that does not track the asset class recommended by
our service runs the risk of sub-optimizing a Client’s portfolio’s performance. We choose ETFs
that are expected to have sufficient liquidity to allow Client withdrawals at any time. Finally, we
select ETFs that have conservative and shareholder-friendly securities lending policies

In addition to choosing what we believe to be the best ETFs at the time, we explain in white
papers on our website why we chose each one. We provide a detailed analysis of how the
selected ETF stacked up against the second and third best choice for each asset class on the
dimensions described in the paragraph above

Wealthfront Advisers continuously monitors our Clients’ portfolios and periodically rebalances
them back to the Clients’ target mix in an effort to optimize returns for the intended level of risk

Wealthfront Advisers may consider tax implications and the volatility associated with each of the
chosen asset classes when deciding when and how to rebalance, however no assurance can be
made by Wealthfront Advisers that Clients will not incur capital gains, and in certain instances
significant capital gains, when Client portfolios are rebalanced periodically. Wealthfront
Advisers assumes no responsibility to its Clients for any tax consequences of any transaction,
including any capital gains that may result from the rebalancing of Client Accounts

B. Tax-Loss Harvesting (“TLH”)
TLH is a technique designed to help lower your taxes while maintaining the expected risk and
return profile of your portfolio. It 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

Item 1 Cover Page This brochure (“Brochure”) provides information about the qualifications and business practices of Wealthfront Advisers LLC (“Wealthfront Advisers”), an investment adviser 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,

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Frequently Asked Questions

What is form adv part 2a brochure?

The new Form ADV Part 2A, or Brochure, shall take the place of an investment adviser’s old ADV Part II and Schedule F. The Brochure shall be the investment adviser’s primary disclosure document. The ADV Part 2A contains eighteen (18) disclosure items, each to be included in the investment adviser’s Brochure.

What is form adv and how does it work?

Form ADV is the uniform form used by investment advisers to register with both the SEC and state securities authorities. The form consists of two parts, both of which are available to the public on the SEC’s Investment Adviser Public Disclosure (IAPD) website.

How many disclosure items are in the adv part 2a?

The ADV Part 2A contains eighteen (18) disclosure items, each to be included in the investment adviser’s Brochure. Each disclosure item is to receive a narrative, plain English response. There is significant overlap between the required content of the new ADV Part 2A and the content that was required by the old ADV Part 2 and Schedule F.

Where can i find the advisers form adv part 1a?

Additional information about JPMIM, including a copy of the Adviser's Form ADV Part 1A, is also available on the SEC’s website at www.adviserinfo.sec.gov