Vanguard Advisers, Inc.

• A percentage of assets under your management
• Fixed fees (other than subscription fees)

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

See the firm's brochure (dated August 20, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$344,619,578,214 as of October 2026, filing dated September 24, 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.

• Financial planning services
• Portfolio management for individuals and/or small businesses
• Portfolio management for pooled investment vehicles (other than investment companies)
• Portfolio management for businesses (other than small businesses) or institutional clients
• Selection of other advisers (including private fund managers)

Registration

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

Registered since

1995 (31 years)

Employees

Total: 2,208. Performing investment advisory functions: 1,903.

Wrap fee program participation

No.

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

The Vanguard Group Inc · affiliatedVanguard Fiduciary Trust Company · affiliatedVanguard Marketing Corporation · affiliated

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)

5 other offices, as of the October 2026 filing

Charlotte, NCMalvern, PANewtown Square, PAPlano, TXScottsdale, AZ

States registered or notice-filed

53 states or jurisdictions

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

9 Reports 9 disclosure items on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Criminal matters Items 11.A and 11.B

• 11.A(1) In the past ten years, has the firm or an advisory affiliate been convicted of, or pleaded guilty or no contest to, a felony?
• 11.A(2) In the past ten years, has the firm or an advisory affiliate been charged with a felony?

Regulatory matters Items 11.C to 11.G

• 11.C(2) Has the SEC or the CFTC ever found that the firm or an advisory affiliate was involved in a violation of SEC or CFTC regulations or statutes?
• 11.C(4) Has the SEC or the CFTC ever entered an order against the firm or an advisory affiliate in connection with investment-related activity?
• 11.C(5) Has the SEC or the CFTC ever imposed a civil money penalty on the firm or an advisory affiliate, or ordered the firm or an advisory affiliate to cease and desist from an activity?
• 11.D(2) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
• 11.D(4) In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?
• 11.E(2) Has a self-regulatory organization or a commodities exchange ever found that the firm or an advisory affiliate was involved in a violation of its rules, other than a minor rule violation under a plan the SEC approved?

Civil court matters Item 11.H

• 11.H(1)(c) Has a domestic or foreign court ever dismissed, under a settlement agreement, an investment-related civil action brought against the firm or an advisory affiliate by a state or foreign financial regulator?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $276,525,412,785 in the October 2021 data and $344,619,578,214 in the October 2026 data, up 25%.

Total employees: 1,866 in October 2021 and 2,208 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. October 2026
   • Updated its list of owners and control persons (Schedule A).
2. August 2026
   • Updated its list of owners and control persons (Schedule A).
3. April 2026
   • Its Item 11 disclosure answers changed (now yes: 11.H(1)(c); now no: 11.H(2)).
   • Employees performing advisory functions went from 1567 to 1903.
   • Regulatory assets under management went from $300,434,933,763 to $344,619,578,214 (+15%).
   • Added an office in Malvern, PA.
   • Updated its list of owners and control persons (Schedule A).
4. March 2026
   • Updated its list of owners and control persons (Schedule A).
5. December 2025
   • Item 11 disclosure answers changed: 9 yes answers, previously 7 (now yes: 11.A(1), 11.A(2)).

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