Vanguard Digital Advisor Important InformationDocuments Included:1. Vanguard Advisers, Inc. Client Relationship Summary (Form CRS)For retail account holders only2. Vanguard Digital Advisor Brochure & Supplement (Form ADV Parts 2A & 2B)For all eligible Digital Advisor account holders (retail brokerage and participants incertain employer-sponsored retirement plans)

Advisor Client Relationship Summary (Form CRS)March 30, 2021Vanguard Advisers, Inc. (VAI)Registered with the Securities and Exchange Commission (SEC) as an Investment Adviser.The services provided by an investment advisor and other financial services providers, like a broker-dealer,will differ, as well as the fees charged by such providers. It’s important to understand who can provide youwith the level of financial services and investment support you need at a price reasonable to you. The SECmakes free and simple tools and educational materials available to research firms and financial professionalsat investment services and advice can you provide me?We provide investment advisory services to retail investors through our Vanguard Personal AdvisorServices (“PAS”) and Vanguard Digital Advisor (“DA”) programs.In PAS, we provide ongoing advised account services. You’ll work with a financial advisor, agree upon afinancial plan and investment strategy, and grant us authority to trade your account(s) in accordance withthat plan. We will not implement or change your plan without your approval. Our lead recommendationswill normally be limited to certain Vanguard funds. We will monitor your accounts and rebalance, asneeded, on a quarterly basis. PAS requires a minimum of 50,000 of investable cash or securities in theadvised portfolio.In DA, we provide online financial planning tools designed to help you create and implement a personalized,goal-based investment plan. We’ll monitor your enrolled accounts frequently using an algorithm. We’ll havefull investment discretion in order to rebalance and make trades as necessary to align your account(s) withyour goal(s). We’ll generally recommend combinations of Vanguard Total Stock Market ETF, Total InternationalStock ETF, Total Bond Market ETF, and Total International Bond ETF for retail accounts. Enrollment requiresat least 3,000 in a Vanguard Brokerage Account. For taxable accounts, the entire balance must be in theaccount’s settlement fund. For IRAs, the entire balance must be in certain investment types and/or theaccount’s settlement fund.The services will require your accounts to be with Vanguard. Our lead investment recommendations willgenerally not include purchases of individual securities or bonds, CDs, options, derivatives, annuities, thirdparty mutual funds, closed-end funds, partnerships, or other non-Vanguard securities. For more informationabout the services, see the “Advisory business” and “Types of clients” sections of each brochure: PAS ADVBrochure and DA ADV Brochure Starters: Consider these questions before choosing a financial service. You can see detailsat visor-details and dvisor-details or call us at the number provided below. Given my financial situation, should I choose an investment advisory service?Why or why not? How will you choose investments to recommend to me? What is your relevant experience, including your licenses, education, and otherqualifications? What do these qualifications mean?What fees will I pay?For PAS clients, the annual advisory fee starts at 0.30% of advised assets and decreases on a tiered levelas advised assets increase. In addition, where mutual funds are held in your account (including Vanguard),there are built-in fees known as “expense ratios.” These are the costs for the fund company to run a fundand will vary by fund, so your combined fees for advice and investments will vary.For DA clients, the annual net advisory fee is approximately 0.15% of program assets, although this fee willvary based on the specific holdings in each account. The annual gross advisory fee for DA is 0.20%. Wesubtract any revenue we, or our affiliates, collect on assets held in investments in your portfolio in order tocalculate your annual net advisory fee.Fees are calculated on a rolling 90-day period based on your average daily balance in the portfolio over theentire fee period. We do not charge advisory fees on the balance of money market funds or other cash

equivalents held within your portfolio. As you invest more assets in the programs, the amount of fees wecollect will increase; therefore, there could be incentive to encourage you to increase your assets.There may be additional fees,including account service fees,and non-Vanguard fund fees,as discussed inmore detail in the“Fees and compensation” section of each program’s Form ADV Brochure.You will pay fees and costs whether you make or lose money on your investments. Fees and costs willreduce any amount of money you make on your investments over time. Please make sure you understandwhat fees and costs you are paying.Help me understand how these fees and costs might affect my investments. If I give you 10,000 to invest, how much will go to fees and costs, and how much will be invested for me?What are your legal obligations to me when acting as my investment advisor? How else does yourfirm make money and what conflicts of interest do you have?When we act as your investment advisor, we have to act in your best interest and put your interests aheadof ours. At the same time, the way we make money creates some conflicts with your interests. You shouldunderstand and ask us about these conflicts because they can affect the investment advice we provide you.Here are some examples to help you understand what this means: Our lead advice will be to invest in Vanguard funds. You will pay the funds’ expense ratios. The funds’expense ratios are received by The Vanguard Group, Inc., as revenue. DA reimburses any revenuereceived by Vanguard from the gross advisory fee. We’ll also require your advised assets to be in accounts held with our affiliates. Those accounts may besubject to additional fees, like account service fees, commissions, and other charges and processingfees. If you were to transact in non-Vanguard funds through a Vanguard Brokerage Account, another ofour affiliates, Vanguard Marketing Corporation, may receive transaction fees, front-end and back-endloads, sales charges, 12b-1 fees, and revenue-sharing payments from certain non-Vanguard funds.See the“Fees and compensation”section of each program’s Form ADV Brochure for more details on howwe and our affiliates make money and the conflicts involved.How might your conflicts of interest affect me, and how will you address them?How do your financial professionals make money?Our advisors servicing PAS are salaried employees who do not earn commissions or additionalcompensation based on the products they recommend or the amount of assets they service.Our DA service does not employ financial professionals who directly advise or manage individual clientaccounts. The professionals responsible for the service and its methodology are salaried employees who donot earn commissions or additional compensation based on the products they recommend or the amountof assets serviced.Do you or your financial professionals have legal or disciplinary history?Yes. For more information related to legal or disciplinary history disclosure go to There,you will find a free and simple search tool to research us and our financial professionals.As a financial professional, do you have any disciplinary history? For what type of conduct?For more information regarding our advisory services, obtain a copy of Form ADV or Form CRS, or contact us at 800-523-9447 to request a copy.Who is my primary contact person? Is he or she a representative of an investment advisor or abroker-dealer? Who can I talk to if I have concerns about how this person is treating me? 2021 The Vanguard Group, Inc. All rights reserved.VAICRS 032021

Vanguard Digital Advisor BrochureNovember 19, 2021Vanguard Advisers, Inc.100 Vanguard BoulevardMalvern, PA 19355877-662-7447vanguard.comThis brochure provides information about the qualifications and business practices of VanguardDigital Advisor , an advisory service offered through Vanguard Advisers, Inc. (“VAI”) (alsoreferred to herein as “we,” “us,” and “our”). This brochure also describes how VAI iscompensated for the service provided to you. You should carefully consider this information inyour evaluation of the service. If you have any questions about the contents of this brochure,please contact us at the phone number above. The information in this brochure hasn’t beenapproved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any statesecurities authority.Additional information about VAI also is available on the SEC’s website at is a registered investment advisor with the SEC. Registration doesn’t imply a certainlevel of skill or training.Material Changes: Since Vanguard Digital Advisor’s Brochure (“Brochure”) annual update onMarch 30, 2021, Digital Advisor has added or is in the process of adding the following materialchanges to its service:Previously on September 16, 2021, Digital Advisor added the ability for certain clients to planand manage towards non- retirement investment goals. For additional information, see“Methods of analysis, investment strategies, and risk of loss” on page 18. Additionally, thelist of qualified custodians was updated on page 40. Additionally, Digital Advisor updated its feestructure on June 4, 2021 to provide an introductory fee waiver for new retail Client enrollments,subject to account eligibility.For additional information, see “Fees and compensation-Feecollection” on page 13.This brochure update includes other additional non-material changes regarding the features andcapabilities available in the service including expanding non-retirement goal planningcapabilities, subject to availability.

Table of ContentsAdvisory business . 2Fees and compensation . 13Performance-based fees and side-by-side management . 19Types of clients . 19Methods of analysis, investment strategies, and risk of loss . 19Disciplinary information . 34Other financial industry activities and affiliations . 34Code of ethics, participation or interest in client transactions, andpersonal trading . 35Brokerage practices . 36Review of accounts . 38Client referrals and other compensation . 39Custody . 40Investment discretion . 40Voting client securities . 41Financial information . 41Requirements for state-registered advisors . 41Investment risks . 41Advisory businessVAI is a Pennsylvania corporation that provides clients with a wide variety of investmentadvisory services, including the following: Stable Value: discretionary investment advisory services to separate accounts that areoffered as investment options in state-sponsored education savings plans (“529 Plans”);Vanguard Institutional Advisory Services: discretionary and nondiscretionary advisoryservices and administrative services to institutional clients such as endowments,foundations, employee benefit plans and trusts, and family offices;Vanguard ETF Strategic Model Portfolios: model portfolios comprised of VanguardFunds and exchange traded funds (ETFs) (as defined below) and mutual funds andETFs managed by third party asset managers that are accessed by third partyintermediaries through third party platforms;Interactive Advice Tools: Personal Online Advisor (“POA”) is a nondiscretionary advisoryservice previously offered to certain retail clients. POA is sub-advised by EdelmanFinancial Engines Advisors L.L.C. (“FEA”), an independent investment advisoryunaffiliated with VAI;2

Vanguard Personal Advisor Services (“PAS”): ongoing advised account services andpoint-in-time advice services for certain retail clients and to participants in certainemployer-sponsored retirement plans;Vanguard Digital Advisor: discretionary advisory service offered to retail clients and toparticipants of eligible employer-sponsored retirement plans;Vanguard Situational Advisor: point-in-time, nondiscretionary advice services andfinancial planning offered to participants in certain employer-sponsored retirement plans;andVanguard Managed Account Program (“VMAP”) and POA: discretionary advisory serviceoffered to participants of eligible employer-sponsored retirement plans. POA is anondiscretionary advisory service offered to participants of eligible employer-sponsoredretirement plans. VMAP and POA are sub-advised by FEA.This Brochure provides information about the Vanguard Digital Advisor (“Digital Advisor”)program. Information about the other investment advisory programs and services offered by VAIis available through the SEC’s website at was incorporated in and has been in business since 1995. VAI is 100% owned by Goliath,Inc., a Delaware corporation. Goliath is 100% owned by The Vanguard Group, Inc.(“Vanguard”). As such, VAI is an indirect, wholly owned subsidiary of Vanguard, the sponsorand manager of the family of mutual funds and ETFs (exchange-traded funds) comprising TheVanguard Group of Investment Companies (“Vanguard Funds”), which VAI typicallyrecommends as investments for its investment advisory services. Please see the section of thisbrochure entitled “Other financial industry activities and affiliations” for more information.Vanguard Digital AdvisorVanguard Digital Advisor (“Digital Advisor”), launched by VAI in 2019, provides an automatedinvestment advisory program that offers eligible clients access to discretionary investmentadvisory services through a website and digital interface (“DA Website and Interface”). DigitalAdvisor also provides online financial planning tools designed to help clients create apersonalized, goals-based financial plan.As an SEC-registered investment advisor, VAI has a fiduciary duty to act in its clients’ bestinterests and to abide by the duties of care and loyalty under the Investment Advisers Act of1940 (“Advisers Act”). Our client relationship begins when you enter into Your ServiceAgreement for Vanguard Digital Advisor (“DA Agreement”) and the scope of our fiduciaryrelationship is defined in the DA Agreement. Goal forecasting and other financial planning toolsthat are available prior to signing the DA Agreement, are provided solely for your informationand education, but your use of those tools prior to signing the DA Agreement does notconstitute a fiduciary relationship between you and VAI under the Advisers Act.Your participation in Digital Advisor requires internet access in order to enroll and to accessprogram documents. You should not interact with Digital Advisor if you do not have consistentinternet access or do not want to accept electronic delivery of documents and disclosuresrequired to be delivered in connection with the service. You are required to maintain an activeemail address with us in order to remain enrolled in the service.3

Over time, as the DA Website and Interface evolves the new content, capabilities, or featuresmay be introduced at different times. As new capabilities are introduced they may initially beavailable to a small population of Clients. At any given time, not all Clients will have access tothe same features and services.Below is an overview of the services provided by Digital Advisor, please refer to the sections ofthis Brochure that follow under the heading entitled “Methods of analysis, investmentstrategies, and risk of loss” for more detailed information.Developing Your Investment StrategyDigital Advisor’s investment strategies are designed with a disciplined, long-term approach thatfocuses on managing risk through appropriate asset allocation and diversification. Ourmethodology uses a strategic and personalized approach by first focusing on the mix of assetclasses (i.e., stocks, bonds, cash) that aligns with your willingness and ability to take risk and isappropriate to meet your financial goals over time. As a completely digital advisory experience,Digital Advisor relies on information you provide.Across all of your goals, we will gather information about your risk/reward preferences or risktolerance to determine your personalized investment strategy. This information helps us toprovide an assessment of your risk attitude (Very Conservative, Conservative, Moderate,Aggressive and Very Aggressive) for you to consider.You must set a retirement savings accumulation goal to enroll an account into the DigitalAdvisor’s discretionary investment advisory service. Digital Advisor captures inputs around yourretirement savings accumulation goal including your expected retirement age, anticipatedspending needs, and your savings. The risk attitude you select, your current age, marital status,and the expected retirement age you provide are then used as inputs to Digital Advisor’sproprietary investment algorithm. Digital Advisor’s proprietary algorithm uses this data torecommend a particular investing track and glide path that correspond to your retirementsavings accumulation goal.In order to obtain a recommended asset allocation through Digital Advisor, you will need to opena new account or enroll an eligible existing account that is either: (i) a Vanguard brokerageaccount (“Vanguard Brokerage Account”) established with Vanguard Marketing Corporation(“VMC”), or (ii) a participant account in an eligible employer-sponsored retirement plan(“Participant Account”) for which Vanguard affiliates provide recordkeeping services. VanguardBrokerage Accounts and Participant Accounts are referred to collectively in this brochure as“Enrolled Accounts.” Once enrolled, Digital Advisor will recommend an asset allocation andspecific investments that can be maintained in your Enrolled Accounts to meet your target assetallocation. The Enrolled Accounts that we manage on a discretionary basis through DigitalAdvisor are referred to as a “Portfolio.”If you have an enrolled taxable account, Digital Advisor can manage additional non-retirementinvestment goals, subject to availability. Unlike traditional approaches, where an individualinvestment account is earmarked to a single goal, Digital Advisor’s multi-goal capability treatstaxable accounts as fungible assets and flexibly allocates those assets across goals based onthe plan4

you set. Digital Advisor determines the appropriate goal-weighted asset allocation across allgoals, dynamically managing assets and anticipated contributions within an integrated multigoal framework. This approach is designed to help you balance your retirement goal with othermajor financial goals. It is important to understand that your target asset allocation and specificinvestments may change significantly upon the inclusion of non- retirement investment goals ifa sizable portion of your taxable account balances are required to fund the goals.Goal Forecasting and Multiple GoalsIn the DA Website and Interface your inputs will enable you to use different interactiveplanningtools and visualizations (leveraging inflation and return on capital models developedby VAI andits affiliates) to help you set your financial goals. Additional data such as currentcontributions, tax filing status, various income sources (lump sum, periodic, etc.), expenses,preferred age range of retirement options, and expected Social Security inform your retirementsavings goal forecasting. Also subject to availability, if you have connected a taxable accountthat is not managed by Digital Advisor (“self-managed account” or “non-managed account”),you may plan additional non-retirement goals that you anticipate funding with your selfmanaged account for purposes of forecasting only. Projections and forecasts regarding thelikelihood of various investment outcomes are hypothetical in nature, do not reflect actualinvestment results, and are not guarantees of future results. Goal forecasts are based on youraccount types (e.g. individual, IRA, Roth IRA) and do not incorporate specific projections ofinvestments that you hold at Vanguard or elsewhere.Digital Advisor also provides projections to help you understand the tradeoffs between differentgoals that influence the success of all your goals. Additionally, if you incorporate self-managedaccounts into multiple goals, forecasting success probabilities and tradeoffs are limited byassumptions regarding those accounts.Currently, the retirement savings accumulation goal-setting experience is designed based on along-term asset allocation strategy and may not suit your needs if you are nearing (within 5years) or in retirement. Setting up additional non-retirement investment goals is subject toavailability and initially will be made available on a pilot basis to a subset of Clients that willexpand over time. You can plan a non-retirement investment goal with a single goal date that isat least eighteen months from the day you add the goal to your plan. Currently, adding financialgoals other than retirement is only available to Clients born after 1965. Additionally, DigitalAdvisor does not currently permit Clients to set goals past the age 59 1/2.Digital Advisor provides access to calculators and interactive tools to help educate Clients abouthow to save for emergencies, where to direct extra or idle cash and how to optimize debtrepayment options. These interactive tools are not integrated with the discretionary investmentadvisory and related online financial planning services offered through DA and do not impactyour recommended investment strategy.Building your Digital Advisor profileYour Digital Advisor financial goals will be specific to the inputs you set. Digital Advisor is notintended to provide comprehensive tax advice or financial planning with respect to every aspect5

of your financial situation.Digital Advisor’s ability to optimize your Portfolio allocation is dependent on the information youenter into the DA Website and Interface, including your planned savings, projections of futurespending needs and responses to visualizations of the potential financial goal planning options.We will also use the information you provide to us through the DA Website and Interface togenerate goals-based forecasting and recommendations on how to better meet your investinggoals. Any such goals-based forecasting and recommendations are point-in-time assessmentbased on your situation and goals at the time you access the DA Website and Interface. DigitalAdvisor does not update your forecasts, provide ongoing financial planning, or monitor yourprogress toward your financial goals on an ongoing basis.If you elect to include self-managed accounts in goal forecasts, these account types andbalances may be considered for purposes of goals forecasting, but will not influence or alter theinvestment recommendations provided by Digital Advisor. Digital Advisor does not makespecific recommendations or manage investments in accounts held at an entity outside ofVanguard. The processes regarding the transfer of cash and securities (described below) to andfrom the Portfolio do not apply those clients who only use the financial planning tools and decideto not enroll in the ongoing advised service.Vanguard Brokerage Account ClientsEnrollments in Vanguard Digital Advisor require at least a 3,000 balance in each eligibleVanguard Brokerage Account. Eligible Vanguard Brokerage Account types include taxableaccounts (e.g. individual or joint accounts with rights of survivorship) as well as certain taxadvantaged (e.g. traditional, Roth, or rollover IRAs). For each brokerage account you wish toenroll, the entire balance must be in the settlement fund or certain investment types (based oneligibility screening by Digital Advisor at the time of enrollment) and/or the brokerage account'ssettlement fund. If your brokerage account holds investments that are not accommodated byDigital Advisor’s breakeven analysis or trading capabilities, then such account will be ineligiblefor enrollment.In the event that an account is enrolled in Digital Advisor with pending trades, Digital Advisorreserves the right to cancel those trades as needed to allocate assets to the recommendedportfolio. We recognize that you may experience costs and tax consequences associated withselling your existing securities positions to implement our lead advice recommendations.As such, subject to eligibility screening at enrollment, we’ll weigh the costs oftransitioning the securities you hold before enrolling in the ongoing advised service usinga breakeven cost analysis. We consider your costs by estimating the capital gains taximpacts compared to the expense ratio benefits from selling securities that areinconsistent from our lead recommendation. The breakeven analysis does not accountfor any fee offsets. If the securities you held before enrolling in the ongoing advisedservice pass our breakeven cost analysis, we’llrecommend that you continue to hold allor a portion of such securities, subject to our portfolio construction guidelines. If they failthe breakeven cost analysis, we’ll recommend that you sell those positions andimplement our lead advice recommendations. Read the section below titled“Reasonablerestrictions” for additional information about imposing restrictions on our investmentstrategy. Retention of existing securities in your portfolio to minimize tax consequenceswill result in variance to the calculation of your advisory fees. For example, if a non6

Vanguard security is retained under the break-even analysis any investment costs youwould be responsible for any investment costs (e.g. expense ratios) that are notrevenues to Vanguard. See “Fees and Compensation” below for more information onfees. Even in situationswhere your Portfolio continues to hold securities you purchasedbefore enrolling in the ongoing advised service, we’ll recommend that any additionalpurchases in your advisedPortfolio be made into Vanguard ETFs.For enrolled Vanguard Brokerage accounts, Digital Advisor uses Vanguard ETFs as the corebuilding blocks investments due to their low investment minimums and expense ratios, as wellas their ability to help facilitate future investment strategies, such as tax loss harvesting, inClient’s Portfolios. Our investment recommendations for assets held in Vanguard BrokerageAccounts will not include recommendations to purchase individual securities or bonds, CDs,options, derivatives, annuities, third-party mutual funds, closed-end funds, unit investmenttrusts, partnerships, or other non-Vanguard securities. In particular, Digital Advisor will typicallyrecommend varying combinations of Vanguard Total Stock Market ETF, Vanguard TotalInternational Stock Market ETF, Vanguard Total Bond Market ETF, and Vanguard TotalInternational Bond ETF (collectively referred to as the “Four Totals”) within Vanguard BrokerageAccounts. If you hold mutual fund share classes of the Four Totals within IRA accounts whenyou enroll, Digital Advisor, subject to availability of eligibility enhancements, will complete yourtarget asset allocation around those existing mutual fund share class positions. Newinvestments will be allocated to the ETF share classes of the Four Totals. See “Fees andcompensation” below, Clients do not pay more to Vanguard and its affiliates if their investmentsare held in mutual funds vs. ETFs. Under certain circumstances (e.g., a Portfolio with ParticipantAccounts and Vanguard Brokerage Accounts), we will recommend other Vanguard index ETFs,such as Vanguard FTSE Developed Markets ETF or Vanguard FTSE Emerging Markets ETF,Vanguard S&P 500 ETF, Vanguard Extended Market ETF, Vanguard Growth ETF, VanguardValue ETF, Vanguard Short-Term Bond ETF, Vanguard Intermediate-Term Bond ETF,Vanguard Long-Term Bond ETF in order to achieve your desired asset allocation. In certaincircumstances, based on your Portfolio’s composition relative to your target asset allocation aswell as co

Mar 30, 2021 · The services provided by an investment advisor and other financial services providers, like a broker-dealer, will differ, as well as the fees charged by such providers. . subtract any revenue we, or our affiliates, collect on assets held in investments in your portfolio