PUBLIC SUBMISSION

As of: 7/20/15 11:24 PM

Received: July 20, 2015

Status: Pending_Post

Tracking No. 1jz-8k3c-9ey5

Comments Due: July 21, 2015

Submission Type: Web

Docket: EBSA-2010-0050

Definition of the Term ‘‘Fiduciary’’; Conflict of Interest Rule—Retirement Investment Advice; 

Notice of proposed rulemaking and withdrawal of previous proposed rule.

Comment On: EBSA-2010-0050-0205

Definition of Fiduciary; Conflict of Interest Rule-Retirement Investment Advice and Related 

Proposed Prohibited Transaction Exemptions; Hearing and Comment Period Extension

Document: EBSA-2010-0050-DRAFT-2568

Comment on FR Doc # 2015-14921

Submitter Information

Name: Adam Nash

Organization: Wealthfront

General Comment

Dear Secretary Perez,

I am writing to you as the President and Chief Executive Officer of Wealthfront, an SECregistered investment advisor based in Palo Alto, CA. Wealthfront is a relatively new company, 

having launched its service just over three years ago in December 2011. We were built from the 

ground up to operate under the full fiduciary standard despite serving small accounts and 

charging incredibly low fees. Thankfully, our effort to serve the small investor has been 

rewarded with unprecedented growth, as we now manage over $2.5 billion in client assets.

At Wealthfront, we're proud of our ability to offer our clients high quality investment 

management at an incredibly low cost. Our firm does not charge any management fees for 

accounts under $10,000 because we do not believe we need to make money on those in the 

beginning stages of saving and investing. We charge 0.25% for accounts over $10,000, a fraction 

of what traditional investment advisors charge. Our portfolios are based on low-cost, third party 

ETF products, without commissions or conflicts.
Thanks to our investment in modern software technology, all our client accounts receive daily 

monitoring and management, rather than quarterly or annual reviews typical of traditional 

advisors. Our combination of low cost and automated service has gained traction and we have 

clients in all 50 states, Washington D.C. as well as active-duty military families.

Dr. Burton Malkiel, the leader of our investment team and author of A Random Walk Down 

Wall Street, has worked tirelessly throughout his career to spread the benefits of low-cost, 

passive investing to individual investors. We believe that technology can not only improve the 

quality of service offered to small investors, but also lower the barriers and costs that have 

limited their access in the past.

We know there has been significant debate recently about ways to increase the protections and 

requirements around providing high quality fiduciary service to small investors. We believe 

technology can dramatically aid in this front. Wealthfront is living proof that not only is it 

possible to provide fiduciary service at low cost to small investors nationwide, but also that the 

market greatly rewards those efforts. Charles Schwab, a firm who has hundreds of branches 

across the U.S. now offers this type of service to small accounts as well, giving tens of thousands 

access to fiduciary investment advice. We are confident our industry leading automated 

investment service will grow to serve a very large number of small investors.

Respectfully,

Adam Nash

President & CEO, Wealthfront Inc.

www.wealthfront.com