Fee-Only Financial Advisor: What 17,210 SEC Filings Show (2026)

Fee-only, fee-based, commission: the three labels in plain words

There are three ways the person advising you can be paid, and the labels for them sound almost the same.

• Commission-based. You pay when something is bought or sold. The SEC's investor site puts it this way: “Typically, you pay a broker a fee called a commission or markup every time you buy or sell an investment.” The professional earns more when you transact, or when you buy the product that pays more.
• Fee-only. You are the only one who pays. The SEC's investor site describes the usual adviser fee: “Typically you pay an adviser an ongoing asset-based fee based on the total value of your account.” A fee-only adviser may also bill by the hour, a flat fee per plan, or a yearly retainer, but no product company pays them anything when you buy.
• Fee-based. Fees and commissions. The same firm, often the same person, bills an advisory fee on one account and earns a commission on an annuity or a fund sale in another. CFP Board's rulebook avoids the phrase on purpose: “CFP Board uses the term ‘fee and commission’ to describe the compensation method of those who receive both fees and Sales-Related Compensation.” A CFP professional who uses “fee-based” must say plainly that they are not fee-only.

The two written definitions of fee-only come from private bodies, not from the law. NAPFA, the association of fee-only planners, states in its membership standards:

“NAPFA defines a Fee-Only financial advisor as one who is compensated solely by the client with neither the advisor nor any related party receiving compensation that is contingent on the purchase or sale of a financial product.”

It also names arrangements that fail: “‘Fee-offset’ arrangements, 12b-1 fees, insurance rebates or renewals and wrap fee arrangements that are transaction based are examples of compensation arrangements that do not meet the NAPFA definition of Fee-Only practice.”

CFP Board lets a CFP professional say “fee-only” only if neither they nor their firm receive Sales-Related Compensation, and related parties receive none in connection with the services. Its list of what counts as Sales-Related Compensation is the useful part: “commissions, trailing commissions, 12b-1 fees, spreads, transaction fees, revenue sharing, referral or solicitor fees, or similar consideration.”

Both standards look past the adviser to related parties: an affiliated broker-dealer, an insurance agency, the firm's owners. That is why the counts below look at more than one box on the form.

How SEC-registered advisers say they are paid (Form ADV Item 5.E)

Form ADV Part 1A, Item 5.E, asks every registered adviser to check all that apply after the words “You are compensated for your investment advisory services by”. Seven boxes: a percentage of assets under management, hourly charges, subscription fees, fixed fees, commissions, performance-based fees and other. We counted each box in the SEC's October 2026 file, for all firms and for two retail slices: firms that report any individual clients in Item 5.D, and firms whose regulatory assets come mostly (more than half) from individuals and high net worth individuals, which is the closest match to an adviser a household would hire.

The combinations say more than the single boxes:

Two things stand out. First, the percentage-of-assets fee is close to universal: 97.8% of the retail-heavy firms charge it. Second, performance fees are mainly a fund-manager habit: 35.7% of all advisers, but 8.2% of firms mostly serving individuals.

The commission box versus the sales links

If you stopped at Item 5.E, you would conclude that 97% of retail-heavy advisers are fee-only. That reading is wrong, because Item 5.E asks how the firm is paid for advisory services. A financial professional can work for an advisory firm and also be a registered representative of a broker-dealer, or a licensed insurance agent, and earn commissions through those other hats. Form ADV records those hats in other items. We counted nine of them.

Read the last column top to bottom. 270 retail-heavy firms admit to commissions in Item 5.E, but 2,074 employ broker-dealer representatives and 4,346 employ insurance agents. Split the links in two and 2,341 (25.4%) have a securities-sales link (commissions, a broker-dealer of their own or an affiliate, or registered representatives on staff), while another 2,490 (27.0%) have only an insurance link.

None of these answers proves a firm is paid commissions on your account. An employee can keep an insurance license and never use it; a related broker-dealer may only execute trades. But under the NAPFA and CFP Board standards the question is whether anyone in the chain earns sales pay from your business, so each of these answers is a question you are entitled to ask before you sign.

Where the clients and the money are

Most clients do not sit at the small, clean firms. Item 5.D gives each firm's number of individual clients and the regulatory assets attributable to them, and the firms with a sales link are the big ones.

So, as of October 2026, about one in fifteen individual clients of these firms is at a firm with no broker-dealer, insurance or commission link on its Form ADV, against 86.2% at firms with broker-dealer representatives on staff (our arithmetic, in the saved script output). Firms that check the commissions box hold 27.8% of the group's individual-client assets ($6,720.8 billion), far more than their 2.9% share of firms suggests. If you want a fee-only adviser, you are shopping in the smaller half of the market, and you have to look for it.

Advice-only firms: hourly and flat fee, no percentage of assets

The model that best fits a household with six figures and a simple portfolio, paying for a plan or an hour of advice without handing over the account, is the rarest one in the registry. 170 of the 9,221 retail-heavy SEC-registered firms (1.8%) check hourly and/or fixed fees with no percentage of assets and no commissions; 84 check fixed fees and nothing else. Across all SEC-registered advisers the figure is 429 (2.5%).

One caveat makes this count a floor, not a census: SEC registration is built for firms with $100 million or more of regulatory assets (Form ADV Item 2.A; 8,543 of the 9,221 retail-heavy firms, 92.6%, register on that basis), so most smaller advisers register with their state instead, and many hourly and flat-fee planners are that small. They are not in this file. Their Form ADV is still on the same public search site, adviserinfo.sec.gov.

What changed in a year

The SEC posted no file for October 2025 (its placeholder says no report was generated because of the government shutdown), so the comparison is with September 2025.

The number of SEC-registered advisers grew from 16,359 to 17,210 (851 more, or 5.2%, our arithmetic), and the retail-heavy group by 556 firms (6.4%). The mix barely moved: the share with no sales link is 47.1% in both files. The one clear shift is that firms with no sales link now report 6.6% of individual clients, up from 5.5%.

What Form ADV can prove, and what it cannot

It can prove a negative claim is false. If an adviser says “fee-only” and its own Form ADV shows commissions in Item 5.E, a broker-dealer in Item 6.A or 7.A, or registered representatives in Item 5.B(2), the claim needs an explanation, and under NAPFA's standard most of those answers disqualify it.

It cannot prove a positive claim is true, for four reasons:

1. Item 5.E is about the firm's advisory pay. Commissions an employee earns as a broker or insurance agent are booked elsewhere. The plain-English brochure (Part 2A) is where they must be disclosed. Its Item 5.E instruction says: “If you or any of your supervised persons accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds, disclose this fact”.
2. Some sales pay has no box. 12b-1 fees, revenue sharing and insurance renewals, all excluded by NAPFA, are not separate checkboxes in Part 1A. Item 8.I (referral compensation, checked by 709 retail-heavy firms) catches only part of it.
3. The data is self-reported. The SEC's data page says: “Neither the SEC nor the state securities authorities have approved the information filed on Form ADV, and we can not guarantee its accuracy.”
4. It is a snapshot. Each row is the firm's latest Form ADV, which the form itself expects to be refreshed by an annual updating amendment; in the October 2026 file, 9,145 of the 9,221 retail-heavy firms (99.2%) last filed in 2026.

And fee-only itself does not guarantee good or cheap advice. The SEC's investor site says that “Investment advisers are required to act in your best interest and not put their interest ahead of yours. At the same time, the way advisers make money creates some conflicts with your interests.” A percentage-of-assets fee rises as your account grows, so it pays the adviser to gather assets and to discourage you from paying off a mortgage or buying a rental with cash. Fee-only removes the product commission. It does not remove that pull, and it says nothing about competence or price. What a fiduciary owes you is covered in our fiduciary financial advisor guide, and what the fees come to in dollars in how much a financial advisor costs.

How to check a fee-only claim in 15 minutes

1. Find the firm on adviserinfo.sec.gov (the SEC's Investment Adviser Public Disclosure site) and open its Form ADV. Check Item 5.E (boxes checked), Item 5.B(2) and 5.B(5) (brokers and insurance agents on staff), Item 6.A (other businesses) and Item 7.A (related broker-dealers and insurance agencies). Any “yes” is a question to ask, not an automatic no.
2. Read Part 2A, Item 5, “Fees and Compensation”. It must give the fee schedule and say whether fees are negotiable. If Item 5.E of the brochure describes anyone accepting compensation for selling securities or other products, the firm is not fee-only under NAPFA's or CFP Board's standard.
3. Read Part 2A, Item 10, “Other Financial Industry Activities and Affiliations”. It must disclose if the firm or its management persons are registered as a broker-dealer or a broker-dealer's representative, and describe material arrangements with related insurance companies or agencies.
4. Read the Form CRS (the relationship summary). The SEC's investor site says it tells you about “the fees and costs you will have to pay for those services” and “conflicts of interest a broker or adviser may have”.
5. Check the individual, not only the firm. The same search site shows whether the person is also registered as a broker. If so, ask which hat they wear for each account; the SEC's investor site notes that “Many firms are registered as both a broker and an adviser and offer both advisory and brokerage services and accounts.”
6. Ask one question in writing: “Will you, your firm or any related company receive any payment other than my fee because of anything I buy, hold or are referred to?” A fee-only adviser can answer “no” in one line.

Verdict: what you can do with this

• Treat “fee-only” as a claim to check, not a credential. On the registry, 4,341 retail-heavy SEC firms show no sales link; that is the pool where the claim is plausible. Outside it, the claim needs an explanation.
• Decide the fee model before the firm. If you need a plan, a second opinion on a 1031 exchange or a rental purchase, or a one-off review, the hourly or flat-fee model is the cheapest fit, and only 170 SEC-registered retail-heavy firms offer it alone. Smaller state-registered planners widen the pool.
• If you will pay a percentage of assets, ask what it comes to in dollars on your balance, and whether it applies to assets they do not manage, such as real estate or a 401(k).
• If an adviser recommends a non-traded REIT, an interval fund or a DST, ask which share class and who is paid what; our advisor cost page for real estate investors and the NAV REIT share-class fee drag show how large that difference can be.

This is analysis of public records, not investment, legal, lending or tax advice. We do not rate or recommend any adviser.

FAQ

Sources: U.S. Securities and Exchange Commission, “Information About Registered Investment Advisers and Exempt Reporting Advisers”, files “Registered Investment Advisers, October 2026” (17,210 rows) and “Registered Investment Advisers, September 2025” (16,359 rows), plus the October 2025 placeholder; SEC Form ADV Part 1A and Part 2 instructions; Investor.gov pages on investment advisers, Form CRS, fees and expenses, and choosing an investment professional; NAPFA's Standards of Membership and Affiliation and “What is Fee-Only Advising”; CFP Board Code of Ethics and Standards of Conduct; all retrieved October 9, 2026. Only rows with Firm Type “Registered” are counted; exempt reporting advisers and state-registered advisers are not included. Segments, shares, combinations, sums and year-over-year changes are our arithmetic, produced by a script published with the data. “Mostly serving individuals” means regulatory assets attributable to individuals and high net worth individuals (Item 5.D(3)(a) and (b)) exceed half of total regulatory assets (Item 5.F(2)(c)). This is analysis of public records, not investment, legal or tax advice.