Gusto Investment Services, LLC

• A percentage of assets under your management

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

The brochure lists different fees for different services or strategies. See the firm's brochure (dated August 18, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$12,698,442,351 as of October 2026, filing dated August 18, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Portfolio management for individuals and/or small businesses
• Pension consulting services

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2015 (10 years)

Employees

Total: 3. Performing investment advisory functions: 2.

Wrap fee program participation

No.

Custodians (Schedule D, Section 5.K(3))

Benefit Trust Company

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

Other offices (Schedule D, Section 1.F)

1 other office, as of the September 2026 filing

Burlingame, CA

States registered or notice-filed

51 states or jurisdictions

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SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

None Reports no disclosure items on Form ADV Item 11. View on IAPD.

Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $3,445,503,395 in the October 2021 data and $12,698,442,351 in the October 2026 data, up 269%.

Total employees: 174 in October 2021 and 3 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. June 2026
   • Regulatory assets under management went from $16,494,894,029 to $12,007,444,821 (-27%).
2. May 2026
   • No longer lists the business name Guideline.
   • Changed its legal name from Guideline Investments, LLC to Gusto Investment Services, LLC.
   • Added an office in Burlingame, CA.
   • No longer lists an office in Solana Beach, CA.
   • Updated its list of owners and control persons (Schedule A).
3. February 2026
   • Employees performing advisory functions went from 3 to 2.
   • Updated its list of owners and control persons (Schedule A).
4. January 2026
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.