Betterment Diligence Research Report
Betterment has credible public scale and brand/product breadth in digital wealth, employer retirement, advisor infrastructure, and cash/checking, but the investment case turns on whether net flows, realized fee yield, retention, compliance controls, and regulated/vendor dependencies support the 2021-era valuation (EC-002, EC-003, EC-009, EC-020).
Betterment Diligence Research Report
Eligible private-unicorn screen: public evidence supports Betterment as an active U.S./New York digital wealth company with CB Insights $1.30B last-known unicorn valuation and active website/regulatory records (EC-001, EC-002, EC-007, EC-025). Underwriting should focus on private financials, stale valuation/cap table, regulatory remediation, and customer/channel economics.
Public sources show AUM, pricing, and regulatory signals but not audited revenue, margin, burn, profitability, CAC, retention, or cash runway.
Diligence request: Obtain audited financials, monthly management accounts, ARR/revenue bridge, gross margin, burn, runway, bank/debt statements, and KPI cohorts.
The $1.30B unicorn valuation is publicly anchored to 2021; current secondary marks, liquidation preferences, and dilution are not public.
Diligence request: Request current 409A, cap table, option ledger, debt instruments, liquidation stack, recent secondary/primary marks, and investor consent rights.
The 2023 SEC order over tax-loss harvesting disclosures shows a prior control failure in a core product area.
Diligence request: Review compliance policies, advertising/TLH approvals, remediation testing, code-change controls, exam history, and complaint/incident logs.
Betterment faces incumbents and fintechs with similar or lower headline advisory fees and broader banking/brokerage ecosystems.
Diligence request: Request win/loss data, pricing elasticity, CAC/payback by channel, net flows, retention, and competitor benchmark pack.
Betterment relies on Betterment Securities, Apex Clearing, program banks, and nbkc bank for core customer experiences.
Diligence request: Review vendor contracts, concentration limits, termination rights, incident history, reconciliation controls, and disaster-recovery testing.
Product differentiation includes tax technology and increasingly complex portfolios; SEC TLH history and crypto ETF products heighten governance needs.
Diligence request: Review model governance, TLH logic, product QA, customer suitability, crypto disclosures, and roadmap risk committee materials.
Marcus Invest transfer and Makara acquisition are public signals of inorganic/partner-led expansion; migration economics and retention are private.
Diligence request: Request integration plans, migration consent/attrition data, customer support metrics, conversion economics, and post-close product performance.
Aggregate customer count is public, but top customers, B2B accounts, revenue concentration, churn, and customer cohort economics are private.
Diligence request: Request top customers by revenue/AUM/channel, contract values, renewals, churn, NPS/support metrics, and customer-reference permissions.
Public evidence supports Betterment as an active financial-services unicorn with $1.30B last-known CB Insights valuation and company-claimed $70B+ AUM; audited financials, cap table, debt terms, revenue quality, and runway remain private-data-room requests. Evidence: EC-001, EC-002, EC-014, EC-015, EC-020.
not publicly verifiable confidence: high
No public audited financial statements or management accounts were found; public proxies are AUM/customer metrics, regulatory AUM anchors, and pricing model evidence. Evidence: EC-002, EC-015, EC-020.
| metric | public value | source basis | verification status | private data needed |
|---|---|---|---|---|
| Customers | 1M+ customers | Company About page | partially_verified | Active vs funded vs checking/investing customer definitions, cohorts, churn |
| AUM | $70B+ AUM as company claim | Company About page; SEC order historical $33.8B regulatory AUM anchor | partially_verified | AUM bridge, net flows, market-return attribution, channel split |
| Pricing model | $5/month or 0.25%; Premium 0.65% | Public pricing page | verified | Realized fee yield, discounts, promotions, revenue by SKU |
| Revenue, margin, burn, runway, CAC | not_publicly_verifiable | No audited or management financials found | not_publicly_verifiable | Audited financials, management accounts, CAC/LTV, burn/runway |
AUM is not revenue.
not publicly verifiable confidence: high
Public sources disclose pricing but not three-year projections, assumptions, capex, working capital, or external-financing assumptions. Evidence: EC-003, EC-020.
partially verified confidence: medium
Public cap-structure evidence is limited to investor associations, regulatory entities, and last-known valuation; shares, liquidation preferences, options, debt, and off-balance-sheet liabilities are not public. Evidence: EC-001, EC-013, EC-025.
| stakeholder | public position | evidence | diligence caveat |
|---|---|---|---|
| Betterment Holdings / Betterment LLC / Betterment Securities | Private operating/regulatory entity structure | IAPD active Betterment adviser and active Betterment Securities BD records; company legal disclosures identify entities | Need legal entity chart, ownership, intercompany agreements |
| Bessemer Venture Partners | Investor/portfolio signal | CB Insights row and BVP Betterment company page | Need current share count and ownership percentage |
| Menlo Ventures | Investor/portfolio signal | Menlo portfolio page states Betterment is a financial robo-advisor | Need current share count and ownership percentage |
| Anthemis | Investor/portfolio signal | Anthemis Betterment company page verifies spelling; CB row typo says Anthermis | Need current share count and ownership percentage |
| Debt/credit providers and option holders | Not publicly verifiable from reviewed sources | No complete debt, warrant, option, or preference schedule was public | Request debt instruments, option ledger, warrants, SAFEs/notes, liquidation preferences |
Ownership percentages are not public.
partially verified confidence: medium
The 2021 financing/valuation headline and public regulatory/pricing sources are available, but tax positions, accounting policies, financing history detail, and current basis by investor are private. Evidence: EC-014, EC-020.
| date | round or event | amount | valuation or aum | participants | verification status | diligence request |
|---|---|---|---|---|---|---|
| 2021-09-29 | CB Insights unicorn/list entry and Betterment growth-capital headline | $160M growth capital headline; detailed split not fully rendered publicly | $1.30B CB Insights valuation | Bessemer Venture Partners, Menlo Ventures, Anthemis normalized from CB typo | partially_verified | Full Series F/growth-capital documents, debt facility terms, cap table, and use of proceeds |
| 2026-05-10 company metric | Company-reported current scale metric | not applicable | $70B+ AUM company claim | not applicable | partially_verified | AUM bridge from regulatory filings and audited asset/revenue schedules |
Current valuation after 2021 is not public.
Betterment publicly offers a broad digital wealth product set spanning automated investing, Premium CFP access, retirement, cash/checking, workplace, advisor, and newer self-directed/crypto/bond capabilities; unit economics, roadmap investment, and controls over automated tax features require diligence. Evidence: EC-003, EC-009, EC-021, EC-027.
partially verified confidence: medium
Public pages verify product breadth and headline pricing; growth rates, market share, cost structure, and profitability by product are not public. Evidence: EC-003, EC-009, EC-021, EC-027.
| product | audience | key features | evidence status | diligence gap |
|---|---|---|---|---|
| Automated Investing / Digital | Retail investors | ETF portfolios, trading, rebalancing, tax management, goal-based advice | verified | SKU revenue, retention, investment outcomes, model validation |
| Premium | Higher-balance retail households | CFP access and Premium benefits at 0.65% with $100k minimum | verified | Advisor staffing, utilization, margin, retention uplift |
| Cash Reserve / Checking | Retail cash management users | Cash sweep via program banks; checking via nbkc bank | verified | Deposit economics, bank contracts, support/incident metrics |
| Betterment at Work | Employers and plan participants | 401(k), compliance, employee education, financial wellness | verified | Employer logos, revenue, plan assets, ERISA compliance files |
| Advisor Solutions | RIAs/advisors | Portfolio construction, model marketplace, tax optimization, onboarding, billing, integrations | verified | RIA customer concentration, platform economics, custody contracts |
| Self-directed, crypto ETF, bond and SRI options | Retail/advisor clients by eligibility | Stocks/ETFs, managed Bitcoin/Ethereum ETF portfolio, Goldman/BlackRock bond investing, SRI | partially_verified | Current availability, suitability, disclosures, profitability |
| provider | headline pricing | minimum or condition | competitive note | evidence status |
|---|---|---|---|---|
| Betterment Digital | $5/month or 0.25% annually | 0.25% after $200 recurring monthly deposits/transfers or $24k+ balance; fees assessed monthly | AUM/subscription hybrid can be expensive for small balances until threshold met | verified |
| Betterment Premium | 0.65% annually | $100k eligible investments | Human CFP access competes with higher-touch digital/hybrid advice | verified |
| Wealthfront | 0.25% annual advisory fee | Public pricing page references advisory-fee calculation | Similar low-cost robo pricing | verified |
| Schwab Intelligent Portfolios | No advisory fee/no commissions | $5,000 to get started | Large incumbent can pressure fees | verified |
| Fidelity Go | No advisory fee under $25k; 0.35% $25k+ | No minimum to open | Price pressure for small balances | verified |
| SoFi Automated Investing / Acorns | SoFi 0.25%; Acorns subscription plans | SoFi robo; Acorns bundled subscription | Fintech ecosystem cross-sell and subscriptions pressure customer acquisition | verified |
Aggregate customer and AUM claims are public, but top customers, B2B accounts, concentration, revenue by customer, and severed relationships are not publicly verifiable. Partner-bank and clearing dependencies are material. Evidence: EC-002, EC-005, EC-006, EC-017, EC-024.
not publicly verifiable confidence: high
Betterment publicly claims 1M+ customers but does not publish a top-15 customer list or application-by-customer purchase history. Evidence: EC-002, EC-024.
| customer or segment | public signal | use case | verification status | follow up |
|---|---|---|---|---|
| Retail aggregate customers | 1M+ customers company claim | Investing, cash, checking, retirement | partially_verified | Define active/funded customers and customer cohorts |
| Employer customers | No named top employers captured publicly | 401(k), financial wellness | not_publicly_verifiable | Top employer logos, contracts, assets, participants, revenue |
| Advisor/RIA customers | Advisor platform public; named top RIAs not captured | Custody/platform/advice infrastructure | not_publicly_verifiable | Top advisor customers, AUM, net flows, churn |
| Any customer >5% revenue | not_publicly_verifiable | Concentration risk | not_publicly_verifiable | Revenue/AUM by customer and 5%+ concentration schedule |
partially verified confidence: medium
Public strategic relationships include regulated affiliates, partner banks, Apex/nbkc, and a 2024 Marcus Invest account-transfer event; commercial economics are private. Evidence: EC-004, EC-005, EC-006, EC-017.
| partner | relationship | public evidence | risk or gap |
|---|---|---|---|
| Goldman Sachs / Marcus Invest | Account transfer to Betterment | 2024 Betterment/Goldman press-room title | Migration retention, consent, account economics, support burden |
| Apex Clearing Corporation | Third-party clearing/custody broker-dealer | Betterment legal disclosures | Clearing contract, service levels, reconciliation controls |
| nbkc bank | Checking/debit card issuer | Betterment Checking disclosures | Bank contract, termination rights, compliance ownership |
| Program banks | Cash Sweep Program deposit banks | Cash Reserve/Cash Portfolio disclosures | Deposit concentration, bank roster changes, FDIC disclosures |
not publicly verifiable confidence: high
Customer-by-revenue and any 5%+ customer concentration are not public. Evidence: EC-024, EC-020.
not publicly verifiable confidence: medium
No severed material customer/partner/supplier relationships were publicly verified; absence of evidence is not proof of absence. Evidence: EC-026.
partially verified confidence: medium
Supplier evidence is strongest for regulated/custody/banking dependencies; cloud, KYC, market-data, data, and security vendors are not public. Evidence: EC-004, EC-005, EC-006, EC-021.
| supplier or dependency | role | public evidence | concentration risk | diligence request |
|---|---|---|---|---|
| Betterment Securities | Affiliated brokerage/custody account structure | Legal disclosures and active regulatory record | High because core investing and Cash Reserve require brokerage account | Broker-dealer financials, supervisory controls, net capital, FINRA report |
| Apex Clearing | Third-party clearing broker-dealer | Legal disclosures identify Apex | High operational dependency | MSA, SLA, incident history, reconciliation controls |
| Program banks | FDIC-insured deposit sweep | Cash Reserve/Cash Portfolio pages list program banks | Medium/high depending on deposit allocation | Bank roster, allocation, limits, economics, termination rights |
| nbkc bank | Checking/debit card issuer | Checking page | Medium/high for checking product | Bank partner agreement and compliance matrix |
| Cloud/KYC/fraud/market-data/security vendors | Technology stack | not publicly disclosed in reviewed sources | unknown | Vendor list, spend, SOC reports, penetration tests |
Betterment competes in a crowded robo-advice/digital wealth market where large incumbents and fintechs use no-fee, low-fee, subscription, and ecosystem-cross-sell models. Evidence: EC-003, EC-012.
verified confidence: high
Public competitor pricing shows Betterment has credible product breadth but faces fee pressure from Schwab, Wealthfront, Vanguard, Fidelity, SoFi, and Acorns. Evidence: EC-012.
| competitor | segment | pricing signal | product overlap | differentiator or pressure |
|---|---|---|---|---|
| Wealthfront | Independent robo-advisor/cash | 0.25% advisory fee signal | Automated investing, cash, tax features | Closest digital-advice price substitute |
| Charles Schwab Intelligent Portfolios | Brokerage incumbent robo | No advisory fee; $5,000 minimum | Robo portfolios, brokerage ecosystem | Large incumbent with no headline advisory fee |
| Vanguard Digital Advisor | Asset-management incumbent digital advice | Low-cost digital advice; minimum assets required | Goal-based digital advice and retirement | Brand/trust and low-cost index funds |
| Fidelity Go | Brokerage incumbent robo | No advisory fee under $25k; 0.35% above | Managed accounts, coaching | Fee pressure for smaller balances and broad ecosystem |
| SoFi Automated / Acorns | Fintech ecosystem/subscription | SoFi 0.25%; Acorns subscriptions | Entry-level investing, banking/cash ecosystem | Cross-sell, subscription economics, younger customers |
| axis | betterment position | competitor pressure | evidence |
|---|---|---|---|
| Price | Low-cost but not always zero: $5/month or 0.25%; Premium 0.65% | Schwab no advisory fee; Fidelity no fee under $25k; SoFi/Wealthfront around 0.25% | Betterment and competitor pricing pages |
| Product breadth | DTC, Premium, workplace, advisor, cash/checking, crypto/bonds/self-directed | Brokerage incumbents and fintechs bundle banking, brokerage, cards, lending | Betterment product pages and competitor pages |
| Trust/regulation | Active RIA/BD records but 2023 SEC order | Large incumbents have scale and compliance resources | IAPD/SEC order and public competitor status |
| Tax technology | Marketed TLH/Tax features; historical SEC TLH issue | Wealthfront and incumbents advertise tax features | Betterment investing page and SEC order |
Betterment uses DTC web/mobile, employer 401(k), advisor platform, education/content, and partner-transfer distribution; public sources do not disclose funnel conversion, CAC, quotas, or budget capacity. Evidence: EC-010, EC-011, EC-023.
partially verified confidence: medium
Public pages verify positioning across individuals, employers, advisors, and owned education; marketing ROI and budget capacity are not public. Evidence: EC-023.
| channel | target | public evidence | gap |
|---|---|---|---|
| DTC web/mobile onboarding | Retail investors/cash users | Betterment site product navigation and get-started flows | CAC, conversion, activation, churn |
| Employer / Betterment at Work | Small and mid-market businesses and employees | Betterment at Work page | Employer logos, sales cycle, plan assets, pricing |
| Advisor Solutions | RIAs/advisors | Advisor Solutions page | RIA customers, platform pricing, custody economics |
| Owned education/content | Prospects and existing users | Resources and education navigation | SEO traffic, conversion attribution, content CAC |
| Partner/account transfers | Transferred accounts/cohorts | Marcus Invest transfer title | Repeatability, retention, migration costs |
not publicly verifiable confidence: high
Major customer status, pipeline, and future growth with top accounts are not public. Evidence: EC-024.
verified confidence: high
Principal public avenues are DTC acquisition, employer 401(k), advisor platform, content/SEO, offers/referrals, and partner migrations. Evidence: EC-023.
not publicly verifiable confidence: high
Sales compensation, quotas, sales-cycle length, and new-hire plan are not public. Evidence: EC-020, EC-023.
| signal | public evidence | verification status | diligence request |
|---|---|---|---|
| App/review proof point | 4.8 rating and 78.1K reviews company claim | partially_verified | App-store analytics, complaints, support tickets |
| Promotions/offers | Site navigation references APY boost, up to $2,000 investing offer, referral offer | partially_verified | Promo economics, conversion, fraud, payback |
| Sales productivity | not_publicly_verifiable | not_publicly_verifiable | Quotas, sales comp, pipeline, sales cycle, attainment, sales headcount |
| Marketing budget capacity | not_publicly_verifiable | not_publicly_verifiable | Marketing budget and forecast tied to cash runway |
not publicly verifiable confidence: high
Budget capacity cannot be assessed publicly because financials, marketing spend, and projections are private. Evidence: EC-020.
Public R&D evidence consists of product pages, advisor roadmap labels, tax technology, and acquisition/product-expansion signals; staffing, cost, model governance, and product pipeline economics are private. Evidence: EC-011, EC-018, EC-019, EC-021, EC-027.
partially verified confidence: medium
Betterment publicly refers to in-house investing and product capabilities but does not publish detailed R&D organization, staffing, or spend. Evidence: EC-009, EC-019, EC-021.
| role or function | public signal | verification status | gap or request |
|---|---|---|---|
| In-house investing/product team | Investing page says in-house Investing Team monitors/analyzes/updates portfolios | partially_verified | Team roster, governance charter, model committee minutes |
| Engineering/product/careers | Careers page confirms active employer brand/open roles link | partially_verified | Engineering/product headcount and open roles by function |
| Compliance/product risk | SEC order indicates need for policies/procedures around TLH and disclosures | verified | Current compliance testing and model governance |
| Security/infrastructure | not_publicly_verifiable beyond legal/security links | not_publicly_verifiable | Architecture diagrams, cloud vendors, SOC 2, pen tests, incident log |
partially verified confidence: medium
Advisor Solutions lists coming-soon securities lending and direct indexing; public pages also show self-directed investing, crypto ETF portfolios, bond investing, and tax features. Evidence: EC-011, EC-018, EC-027.
| project | status | expected date | evidence | risk or follow up |
|---|---|---|---|---|
| Advisor securities lending | Coming soon on Advisor Solutions page | not public | Advisor page navigation | Regulatory, custody, suitability, revenue-share review |
| Advisor direct indexing | Coming soon on Advisor Solutions page | not public | Advisor page navigation | Model/IP/tax-methodology diligence |
| Self-directed investing | New in public navigation | launched/available per nav; details not verified | Betterment product navigation | Brokerage supervision and conflict controls |
| Crypto investing / Makara legacy | Crypto ETF managed portfolio marketed; Makara acquisition headline in 2022 | current product status requires confirmation | Betterment navigation and Makara press title | Crypto regulatory/disclosure/custody risk |
| Tax-loss harvesting / tax-saving technology | Core marketed feature with historical SEC issue | ongoing | Investing page and SEC order | Current controls and substantiation |
Betterment publicly identifies leadership and active careers presence, but full biographies, headcount by function/location, compensation, stock plans, employee-relations issues, and turnover data are private. Evidence: EC-019, EC-022, EC-028.
partially verified confidence: medium
A public org chart is not available; company About page confirms leadership section and key roles. Evidence: EC-022.
| name | role | public evidence | tenure or prior roles | diligence request |
|---|---|---|---|---|
| Sarah Levy | Chief Executive Officer | About page leadership section and CEO quote | Full tenure/prior roles not fully extracted from current page | Biography, employment agreement, board role, regulated responsibilities |
| Peter Lorimer | President (public role label visible with leadership section) | About page leadership section extraction | Not public in captured evidence | Biography, responsibilities, employment agreement |
| CFO/CPO/CTO/CMO/Chief People Officer/General Counsel | Executive roles visible but names not cleanly captured | About page role labels | not_publicly_verifiable | Full executive roster and bios |
| Board/advisors | Board governance | not_publicly_verifiable from reviewed sources | not public | Board roster, committees, investor directors, observer rights |
Role labels are public, but reporting lines and full names should be confirmed.
not publicly verifiable confidence: medium
Careers page supports active recruiting, but historical/projected headcount by function and location is not public. Evidence: EC-019.
| function or location | public signal | verification status | diligence gap |
|---|---|---|---|
| All company headcount | not publicly disclosed in reviewed pages | not_publicly_verifiable | Monthly headcount by function/location and forecast |
| Engineering/product/R&D | Careers page links to open roles but count not captured | partially_verified | Engineering/product roster, open roles, attrition |
| Compliance/legal/regulated operations | Active RIA/BD and SEC order indicate need for compliance resources | partially_verified | Compliance staffing, exam history, policies, training |
| Customer support/operations | not_publicly_verifiable | not_publicly_verifiable | Support headcount, ticket volume, SLAs, complaints |
partially verified confidence: medium
Partial public management roster is available; full biographies, tenure, ages, and current regulated roles require direct confirmation. Evidence: EC-022.
not publicly verifiable confidence: high
Executive employment agreements, benefits detail, and compensation arrangements are not public. Evidence: EC-028.
not publicly verifiable confidence: high
Stock-option/equity incentive plans are not public. Evidence: EC-028.
not publicly verifiable confidence: medium
No significant employee relations problems were verified from public sources; this requires HR/counsel review. Evidence: EC-028.
not publicly verifiable confidence: medium
Personnel turnover data for the last two years is not public. Evidence: EC-019, EC-028.
| item | public evidence | verification status | request |
|---|---|---|---|
| Executive transitions | Sarah Levy CEO and Peter Lorimer leadership evidence; historical founder/professional CEO transition should be verified separately | partially_verified | Executive-transition history and succession plan |
| Personnel turnover last two years | not_publicly_verifiable | not_publicly_verifiable | Monthly attrition and regrettable attrition by function |
| Employee relations problems | not_publicly_verifiable | not_publicly_verifiable | HR/counsel claims log and investigation summary |
| Retention/benefit plans | Careers page benefits navigation but no plan detail | partially_verified | Benefits, retention plans, equity refresh policy |
Betterment has active regulated adviser/broker-dealer records and a material 2023 SEC order; pending litigation, full IP registration, insurance, material contracts, and environmental/employee safety matters require counsel/data-room verification. Evidence: EC-004, EC-007, EC-008, EC-016, EC-026, EC-028.
not publicly verifiable confidence: medium
No verified pending material lawsuit against Betterment was identified in reviewed sources, but docket searches were incomplete. Evidence: EC-026.
| case or search | court or forum | filed date | status | evidence or gap |
|---|---|---|---|---|
| SEC administrative order IA-6288 | SEC administrative proceeding | 2023-04-18 order | Settled/sanctioned order | Verified regulatory matter; not a pending civil lawsuit |
| Civil lawsuits against Betterment entities | PACER/state/FINRA arbitration | not_publicly_verifiable | not_publicly_verifiable | No verified pending material lawsuit identified; docket search incomplete |
| Consumer class/action or arbitration matters | State/federal/FINRA | not_publicly_verifiable | not_publicly_verifiable | Requires counsel exports and claims logs |
not publicly verifiable confidence: medium
No pending lawsuits initiated by Betterment were publicly verified; counsel confirmation is required. Evidence: EC-026.
| defendant or matter | court or forum | filed date | status | diligence request |
|---|---|---|---|---|
| Company-initiated litigation | not_publicly_verifiable | not_publicly_verifiable | No verified matter from reviewed sources | Counsel litigation schedule and docket exports |
| IP enforcement matters | not_publicly_verifiable | not_publicly_verifiable | No public verified matter found | IP enforcement and takedown logs |
not publicly verifiable confidence: medium
As a software/financial-services company, no material environmental or employee-safety liabilities were identified publicly; workplace, remote-work, and employment compliance data are private. Evidence: EC-028.
partially verified confidence: medium
Betterment lists several marks and claims platform copyrights; live USPTO/patent/assignment/license status requires verification. Evidence: EC-016.
| asset | jurisdiction or type | status public | source | follow up |
|---|---|---|---|---|
| Betterment® | Trademark/brand | Listed by Betterment as mark | Company IP policy | Verify USPTO registration, owner, classes, assignments, live/dead status |
| Betterment Speedometer® | Trademark/product mark | Listed by Betterment as mark | Company IP policy | Verify USPTO status and product use |
| Betterment for Business® | Trademark/workplace mark | Listed by Betterment as mark | Company IP policy | Verify USPTO status and assignments |
| Betterment Advisor Solutions℠ | Service mark/advisor platform | Listed by Betterment as mark | Company IP policy | Verify USPTO/TM and licensing |
| Patents, code, open-source, data/model IP | Patent/copyright/trade secret/license | not_publicly_verifiable | No complete public schedule reviewed | Patent Center/assignment search, SBOM, repository/license review, invention assignment audit |
not publicly verifiable confidence: high
Insurance coverage is not publicly verifiable. Evidence: EC-028.
| category | public evidence | verification status | diligence request |
|---|---|---|---|
| Insurance | No public insurance schedule found | not_publicly_verifiable | D&O, E&O, cyber, crime, fiduciary/ERISA, broker-dealer, excess policies and claims |
| Apex/clearing/custody contract | Apex identified in legal disclosures | partially_verified | MSA/SLA, termination, incident history, fees, reconciliation controls |
| nbkc and program-bank contracts | nbkc and program banks identified publicly | partially_verified | Bank agreements, deposit economics, limits, compliance matrix |
| Employer/advisor/material customer contracts | Channels public; contracts private | not_publicly_verifiable | Top contracts, change-of-control, pricing, termination, service levels |
| Cloud/KYC/security/vendor contracts | not publicly disclosed | not_publicly_verifiable | Vendor list, SOC reports, DPIAs, incident logs, SLAs |
not publicly verifiable confidence: high
Material contracts with banks, Apex, vendors, employers, advisors, and partners are not public. Evidence: EC-004, EC-005, EC-006, EC-028.
partially verified confidence: high
Betterment has verified active RIA/BD records and a material SEC order; broader exam, complaint, CFPB, FINRA, and state-regulator history needs direct diligence. Evidence: EC-007, EC-008.
| agency | action or record | date | status | risk note |
|---|---|---|---|---|
| SEC / IAPD | Betterment active SEC-registered investment adviser record; CRD/IARD 149117, SEC 801-70171 in API result | current database accessed 2026-06-15 | active | Fiduciary, advertising, disclosure, custody, exam, and compliance-program obligations |
| FINRA / BrokerCheck | Betterment Securities active broker-dealer record, CRD 47788 / SEC 8-51906 in IAPD search result | current database accessed 2026-06-15 | active | Broker-dealer supervision, complaints, clearing/custody, net-capital, and FINRA obligations |
| SEC | Order IA-6288 regarding TLH disclosures, contract notices, books/records, compliance policies | 2023-04-18 | Censure/order; remediation details private | Core disclosure/control red flag |
| CFPB/state/ERISA/IRS/DoL/other agencies | not_publicly_verifiable in reviewed sources | not_publicly_verifiable | requires search | 401(k), cash/checking, consumer, privacy, tax, and employment obligations require broader review |
| ID | Claim | Status | Sources |
|---|---|---|---|
| EC-001 | CB Insights listed Betterment as a United States/New York Financial Services unicorn valued at $1.30B with a 2021-09-29 join date. | verified high | SRC-001 |
| EC-002 | Betterment publicly presents itself as an active scaled digital wealth company with 1M+ customers and $70B+ AUM. | partially verified medium | SRC-002 |
| EC-003 | Betterment charges $5/month or 0.25% annually for investing accounts and 0.65% annually for Premium with a $100,000 minimum. | verified high | SRC-004SRC-005 |
| EC-004 | Betterment uses a multi-entity regulated structure: Betterment LLC for advisory services, Betterment Securities for brokerage/custody, Apex Clearing, Betterment Financial for checking, and Betterment for Business for 401(k) administration. | verified high | SRC-006 |
| EC-005 | Cash Reserve relies on Betterment Securities brokerage accounts and FDIC-insured program banks, not Betterment as a bank. | verified high | SRC-007SRC-008 |
| EC-006 | Betterment Checking is issued by nbkc bank through Betterment Financial LLC; Betterment affiliates are not banks. | verified high | SRC-009 |
| EC-007 | SEC/IAPD search returns active Betterment adviser and active Betterment Securities broker-dealer records at the New York office address. | verified high | SRC-010SRC-011 |
| EC-008 | SEC sanctioned Betterment LLC in 2023 for tax-loss harvesting disclosures and compliance failures. | verified high | SRC-012 |
| EC-009 | Betterment offers automated investing, portfolios, retirement accounts, tax features, Premium advice, cash/checking, self-directed, crypto ETF portfolios, bond investing, and SRI options. | verified high | SRC-002SRC-003 |
| EC-010 | Betterment at Work sells scalable 401(k), compliance, rollover, employee, and financial wellness offerings to employers. | verified high | SRC-013 |
| EC-011 | Betterment Advisor Solutions targets RIAs with portfolio construction, model marketplace, tax optimization, cash, SBLOC, 401(k), onboarding, billing, integrations, and coming-soon securities lending/direct indexing. | verified high | SRC-014 |
| EC-012 | Public competitor pricing indicates Betterment faces direct robo-advisor fee pressure from Schwab, Wealthfront, Vanguard, Fidelity, SoFi, and Acorns. | verified high | SRC-021SRC-022SRC-023SRC-024SRC-025SRC-026 |
| EC-013 | Investor associations with Menlo Ventures and Anthemis are independently verified; Bessemer has a Betterment company page. | partially verified medium | SRC-017SRC-018SRC-019 |
| EC-014 | Betterment announced a 2021 $160M growth-capital financing at a $1.3B valuation. | partially verified medium | SRC-020SRC-001 |
| EC-015 | SEC order described Betterment as a New York registered investment adviser since 2009 with automated, software-based portfolio management and $33.8B regulatory AUM at that filing time. | verified high | SRC-012 |
| EC-016 | Betterment publicly lists Betterment, Betterment Speedometer, Betterment for Business, and Betterment Advisor Solutions as marks. | partially verified medium | SRC-016 |
| EC-017 | Betterment announced a Goldman Sachs Marcus Invest account transfer to Betterment in 2024. | partially verified medium | SRC-027 |
| EC-018 | Betterment announced it acquired Makara in 2022. | partially verified medium | SRC-028SRC-002 |
| EC-019 | Betterment careers page confirms active recruiting/employer-brand presence but does not publicly provide audited headcount by function. | partially verified medium | SRC-015 |
| EC-020 | Detailed financial statements, revenue, margin, burn, cap table, debt terms, customer concentration, and sales productivity are not publicly verifiable from the reviewed sources. | not publicly verifiable high | SRC-001SRC-002SRC-004SRC-010 |
| EC-021 | Betterment product architecture depends on ETFs, affiliated RIA/broker-dealer entities, Apex Clearing, program banks, and nbkc bank. | verified high | SRC-003SRC-006SRC-007SRC-008SRC-009 |
| EC-022 | Betterment About page identifies Sarah Levy as CEO and shows Peter Lorimer among leadership; full current executive biographies and compensation are not public in reviewed sources. | partially verified medium | SRC-002 |
| EC-023 | Betterment operates owned web/mobile, employer, advisor, education/content, and partner-transfer distribution channels. | verified high | SRC-002SRC-013SRC-014SRC-027SRC-029 |
| EC-024 | No named top customers or customer-by-revenue concentration data were publicly verifiable; aggregate customer count is public as a company claim. | not publicly verifiable high | SRC-002SRC-013SRC-014 |
| EC-025 | Betterment has not shown public evidence of IPO, acquisition of the company, or shutdown in reviewed sources, while active website and active regulatory records support continued private-company eligibility. | partially verified high | SRC-001SRC-002SRC-010 |
| EC-026 | Public legal/litigation search was incomplete; no verified pending material company lawsuit was identified from reviewed sources. | not publicly verifiable medium | SRC-006SRC-010SRC-012 |
| EC-027 | Betterment investing page makes tax-loss harvesting benefit claims while SEC order documents historical TLH disclosure failures. | partially verified medium | SRC-003SRC-012 |
| EC-028 | Insurance coverage, material contracts, employee safety matters, and compensation/stock-plan details are not publicly verifiable from reviewed sources. | not publicly verifiable high | SRC-006SRC-015 |
This report is a public-evidence diligence snapshot, not investment advice. Important financial, legal, technical, and contractual facts remain non-public and should be verified directly with management and primary documents before any investment decision.