# Gusto Investment Services, LLC

> Gusto Investment Services, LLC is an SEC-registered investment advisory firm in San Francisco, CA, registered since 2015, reporting over $5 billion in regulatory assets under management in its Form ADV filing dated August 18, 2026.

- CRD: 281515
- Filed as: GUSTO INVESTMENT SERVICES, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: San Francisco, CA
- Filing period: October 2026
- Form ADV filing dated: August 18, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/281515
- AdvisorCensus page: https://advisorcensus.com/firm/gusto-investment-services-llc-san-francisco-ca-281515

## Quick answers

**How is Gusto Investment Services, LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Gusto Investment Services, LLC reports these compensation arrangements: a percentage of assets under its management. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Gusto Investment Services, LLC located?**
Gusto Investment Services, LLC's principal office is in San Francisco, CA, according to its Form ADV; the September 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Gusto Investment Services, LLC registered with the SEC or a state?**
Gusto Investment Services, LLC is an SEC-registered investment advisory firm, registered since 2015. Status as filed: Approved. CRD 281515.

**How much does Gusto Investment Services, LLC manage?**
Gusto Investment Services, LLC reports $12,698,442,351 in regulatory assets under management in its Form ADV filing dated August 18, 2026 (72% discretionary).

**How have Gusto Investment Services, LLC's assets and staff changed since 2021?**
In the Form ADV data for Gusto Investment Services, LLC: 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. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Gusto Investment Services, LLC serve?**
By number of clients on Form ADV Item 5.D: pension and profit sharing plans (but not the plan participants or government pension plans) (50,388); other (27,676).

**Which custodians does Gusto Investment Services, LLC use?**
Gusto Investment Services, LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Benefit Trust Company as a custodian holding 10% or more of its separately managed account assets.

**Does Gusto Investment Services, LLC report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/281515

**What changed in Gusto Investment Services, LLC's recent Form ADV filings?**
In the June 2026 filing data: Regulatory assets under management went from $16,494,894,029 to $12,007,444,821 (-27%).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management

### 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.

### Regulatory assets under management (Item 5.F)
- Total: $12,698,442,351
- Discretionary: $9,108,834,416
- Non-discretionary: $3,589,607,935

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 50,388 | $12,303,056,955 |
| Other | 27,676 | $395,385,396 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Pension consulting services

### Firm details
- Registered since: 2015 (10 years)
- Employees: 3 total, 2 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AK, AL, AR, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, RI, SC, SD, TN, TX, UT, VA, VT, WA, WI, WV, WY
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the September 2026 filing
- Burlingame, CA

### Websites listed on Form ADV (Item 1.I)
- [retirement.gusto.com](https://retirement.gusto.com)
- LinkedIn @guideline

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $3,445,503,395 | 174 | September 1, 2021 |
| October 2022 | $5,890,135,888 | 317 | September 21, 2022 |
| October 2023 | $7,263,423,988 | 413 | October 2, 2023 |
| October 2024 | $11,710,165,540 | 380 | July 1, 2024 |
| October 2025 | $16,494,894,029 | 8 | March 27, 2025 |
| October 2026 | $12,698,442,351 | 3 | August 18, 2026 |

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.

## Changes in the filing (last 12 months)

### June 2026
- Regulatory assets under management went from $16,494,894,029 to $12,007,444,821 (-27%).

### 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).

### February 2026
- Employees performing advisory functions went from 3 to 2.
- Updated its list of owners and control persons (Schedule A).

### January 2026
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Gusto Investment Services, LLC (CRD 281515): Form ADV filing data as of October 2026.