Merrill Lynch Advisory Fees 2026: 1.75% Maximum in the Investment Advisory Program (Oct 30 Brochure)

Every advisory program Merrill files a brochure for

Merrill Lynch, Pierce, Fenner & Smith Incorporated (CRD 7691, SEC file number 801-14235, registered with the SEC since December 8, 1978) lists 12 brochures on the SEC's Investment Adviser Public Disclosure site, and we found a client fee line in ten of them. The ones most readers meet are the Investment Advisory Program, where a dedicated advisor sets your rate within a ceiling, and the lower-cost Guided Investing and Edge programs, where the rate is fixed. The Form CRS effective June 26, 2026 repeats the same maximums, so the two documents agree.

The other two brochures, Advice Access (1058303) and the Managed Account Advisors document for Select Portfolio Solutions (1058313), describe plan and bank-linked services, and we did not find a client fee line in them to quote. SPA is closed to new investors from July 1, 2026, and its 1.50% maximum in the Form CRS therefore applies to existing clients only. MAS carries the highest posted ceiling of any retail program, 1.80%, and its manager fee is a separate contract between you and the manager.

What the same account pays in dollars

Merrill prints a ceiling for IAP, not a rate card, so the dollar figures below show what the ceiling costs and what a lower negotiated rate would cost. The 1.25% and 1.00% rows are illustrations of a negotiated rate, not Merrill rates. Every figure is our arithmetic on the posted percentage and excludes fund expenses and any manager fee unless the row says so.

On $1,000,000 the gap between the IAP maximum and a 1.00% rate is $7,500 a year, or $75,000 over ten years with no growth assumed (our arithmetic). The MAS maximum for equity accounts up to $1 million is 1.80%, which is $4,500 on $250,000 and $9,000 on $500,000 (our arithmetic); the brochure does not say whether its higher tiers apply to the whole account or only to the slice above the breakpoint, so we show no dollar figure above $1 million. For how these numbers sit against 20 other firms read how much a financial advisor costs.

What the program fee covers, and what sits outside it

The IAP brochure says the fee covers advisory services, trade execution, clearance and settlement, custody and reporting, and that it “will not be adjusted for your use of, or failure to use, the Program Services”, including low or no trading. It is billed monthly in advance, at one twelfth of the annual rate on the prior month-end value.

The brochure then lists what the fee does not cover. In its own wording these include “Fees, expenses and charges charged by Funds or by the managers or sponsors of Funds”, margin interest, wire and transfer fees, and dealer mark-ups and mark-downs on principal trades. A manager fee for a Style Manager Strategy or a Premium Access Strategy is a separate line from the Merrill Lynch Fee.

Three mechanics change the base the percentage is applied to:

• Household value. If your rate follows a schedule, Merrill considers the assets in your account and in your designated household at Merrill and its affiliates, and says it can stop doing so at any time.
• Cash. The fee is charged on all assets, including cash and cash alternatives.
• Funds that are hard to price. For non-traded REITs, non-traded business development companies, interval funds and similar Alternative Investment Funds, the brochure says Merrill calculates the program fee on the estimated and unaudited net asset values the fund manager provides, and makes no adjustment if the value is later revised. If you hold such a fund inside an IAP account, you pay the program fee on top of the fund's own fees. We cover the fund-level costs in non-traded REIT vs publicly traded REIT.

How the rate is set, and what the brochure says about your advisor's pay

The IAP brochure says the rate “is the rate agreed to between you and your Advisor”, either as a single rate or as a schedule by asset level, and that an advisor typically weighs the size of the account, the breadth of the relationship, engagement, the strategy type, competitive considerations and how Merrill compensates the advisor. It then states the conflict in plain words: “Because the amount of compensation paid to your Advisor is based on the Merrill Lynch Fee Rate for your Account, your Advisor has a financial interest in that rate.”

Two further statements bear on negotiation:

• Advisors receive “production credits” toward their pay formula from the fee you pay. The brochure says Merrill's policies result in advisors receiving “fewer production credits (by 10% or more)” when the weighted average of a client's rates, including household accounts, falls below the levels Merrill sets for wealth tiers, and that this makes the advisor “incentivized not to offer a Merrill Lynch Fee Rate below such rate levels”.
• Merrill gives advisors “statistical information about the Merrill Lynch Fee Rates charged in the Program”, which the brochure says can encourage advisors not to agree to a lower rate.

The brochure also says an advisor can negotiate a higher Merrill fee when the account has no manager fee, and that Merrill may “waive, reduce or rebate” the fee for a period in certain cases. Guided Investing with Advisor and the Edge Advisory Account have no such negotiation: the brochures set the rate at 0.85% for everyone.

The brokerage account instead: commissions and account fees

Merrill's Form CRS says that in a brokerage account you pay “commissions and other sales fees on a per transaction basis” and that the firm does not provide ongoing monitoring of it. Its September 2026 Best Interest Disclosure Statement gives the ranges, and its fee schedules give the account charges. The schedule for advisor-assisted accounts carries a 03/2023 code; the Guided Investing with Advisor and Edge self-directed schedules carry 11/2025 codes. We read them on November 13, 2026.

As a yardstick, the IAP maximum on $1,000,000 is $17,500 a year, which equals the 5.00% top-of-range commission on $350,000 of stock purchases, or the 0.50% bottom of the range on $3,500,000 (our arithmetic). That comparison says nothing about which account suits you; it shows how many dollars of trading a year it takes before a commission account costs what the ceiling costs. The brochure itself lists the questions to weigh, including “How much trading activity you expect to take place in your Account” and “How much of your assets expected to be allocated to cash.”

Cash: the sweep rate table and who earns on it

Merrill's rate sheet, dated November 12, 2026, lists the annual percentage yield on the bank-deposit sweep by tier. The sheet says Tier 5 is assigned to accounts in the Investment Advisory Program, the Strategic Portfolio Advisor Service, the Managed Account Service, Merrill Guided Investing with Advisor and the Merrill Edge Advisory Account.

The Retirement Asset Savings Program for IRAs carries the same tier rates on the sheet. Two facts from the brochure matter together. First, the fee applies to cash: “The Program Fee is in addition to other compensation that we and our Affiliates earn on cash and cash alternatives held in your Account.” Second, the brochure warns that “you may experience a negative overall investment return with respect to cash and cash alternatives”. On $50,000 of cash at the 1.75% maximum the fee is $875 and the Tier 5 yield is $1,675, a net of $800 before tax; at a 0.85% program the net is $1,250 (our arithmetic). The same $50,000 in a brokerage account at Tier 1 earns $5 (our arithmetic).

What the brochures say Bank of America earns. The IAP brochure says Merrill “receives payments from our Bank Affiliates on a per account basis for each account that sweeps to one of our Bank Affiliates”, and the Sweep Program Guide puts the figure at “Up to $100 per year from BANA and BA-CA for each account that sweeps to the Merrill Lynch Bank Deposit Program”. On a $50,000 account that is up to 0.20%; on $500,000, up to 0.02% (our arithmetic). The banks' own earnings are described as a spread: the brochure says “The greater the amount of cash balances maintained in your Account (which could be as a result of a recommendation from your Advisor, us or a Related Style Manager) that is swept into a bank deposit account affiliated with the Cash Sweep Program and the lower the interest rate paid on the related bank deposit, the more our Bank Affiliates benefit.” We found no dollar figure for that spread in the brochures. The SEC's January 17, 2025 order, summarised below, says Merrill's banking affiliates “earned significant net interest income on the MLBD Program deposits” and that “At times the differences were almost 400 basis points” between the sweep yield and other cash options.

The rates are not fixed: the brochure says the Bank Affiliates set and reset them “in their discretion”, so the November 12, 2026 table is a snapshot.

Other revenue Merrill receives from what is in your account

Two disclosures in the brochures are new or recent and apply to the funds inside an advisory account.

• Support Fees from January 1, 2027. The September 18, 2026 update added that Merrill anticipates receiving, as of January 1, 2027, Support Fees from third-party firms that sponsor or manage mutual funds, actively managed ETFs and certain annuities. The brochure says they will be “up to 0.10% annually of the value of fund assets held in client Accounts enrolled in the Program”, up to 0.02% on Style Manager strategies, retained by Merrill and not rebated or credited to your account, and not charged on Retirement Accounts. On $500,000 in affected funds, 0.10% would be $500 a year (our arithmetic). The brochure also says the amount a firm agrees to pay is “considered as a factor by Merrill in its decision to make products available”.
• Alternative investment funds. For feeder funds sold only to Merrill clients, the brochure says Merrill receives selling-agent compensation of up to 0.85% a year of net asset value, and for other alternative funds a payment of up to 1.00% of the amount invested. Merrill also takes one-time or periodic flat payments that “generally do not exceed $500,000”.

The firm in numbers: Form ADV Part 1, Form CRS and BrokerCheck

Form ADV Part 1 is the firm's regulatory report. The version filed on November 11, 2026 is an other-than-annual amendment. The dollars are regulatory assets under management as Item 5 defines them.

Item 11 asks about the firm and every advisory affiliate, which at a firm with 25,721 advisory staff includes individuals; we report counts only. The Form CRS answers the legal-history question with “Yes. Please visit Investor.gov for a free and simple tool to search for us and our financial professionals.” The same CRS says of the advisory programs: “The more assets there are in your IA Program-enrolled account, the more you will pay in fees, giving us a financial incentive to encourage you to increase the assets in your account.”

SEC and FINRA orders against the firm

The amounts below are from the orders themselves. All were settled without admitting or denying the findings. The first column is the date of the order or agreement.

The six SEC amounts add to $55,192,815 (our arithmetic: $7,500,000 + $25,000,000 + $3,800,000 + $9,694,714 + $325,376 + $8,872,724.81), not counting the separate payments that Harvest Volatility Management LLC agreed to in its own 2024 order. The IAP brochure's disciplinary section lists the five advisory orders from 2018 to 2025 in its Item 9; the June 2026 order and the FINRA agreements come from the SEC's order and FINRA's BrokerCheck report.

What changed since our October 9 fee page

We checked our earlier page, how much a financial advisor costs, against the latest brochures. Both of its Merrill figures still stand: “We have set the maximum Merrill Lynch Fee Rate for the Program at 1.75%.” and “The program fee for MGI with Advisor and the MEAA programs is 0.85%”. What moved is the filing: the IAP brochure was refiled October 30, 2026 to describe proxy-voting changes effective January 1, 2027, and the September 18, 2026 versions added the Support Fees above.

What a client can do with this

1. Ask for your Program Report. It states the Merrill Lynch Fee Rate for each account, and the brochure says you can have a different rate on each account. Compare it with the 1.75% maximum and with any schedule.
2. Ask what manager fee, if any, is in the strategy. The Strategy Profile shows the Style Manager Rate; ask for the total of both lines in dollars at your balance.
3. Ask whether your household assets are counted and, if the rate follows a schedule, which breakpoint you are on.
4. Ask what share of the account is cash and what yield it earns, next to the fee charged on it. The rate sheet is public and changes.
5. If you hold non-traded funds inside the account, ask how the fee is calculated on them and what Merrill receives from the fund.
6. Ask for the numbers in writing, then check the brochure on adviserinfo.sec.gov (CRD 7691) and the firm's Form CRS yourself.

This is analysis of public documents, not investment, legal or tax advice.

FAQ

Sources, read and saved on November 13, 2026: Merrill Lynch, Pierce, Fenner & Smith Incorporated Form ADV Part 2A brochures on the SEC's IAPD site (CRD 7691): Investment Advisory Program (version 1062763, October 30, 2026), Merrill Guided Investing with Advisor (1058311), Merrill Edge Advisory Account (1058307), Merrill Guided Investing (1058308), Strategic Portfolio Advisor Service (1058304), Managed Account Service (1058305), Institutional Investment Consulting (1058310), the retirement-plan program (1058309), Small Business 401(k) Advisory Service (1058314), Personal Retirement Strategy (1058312), all dated September 18, 2026 except the first; Form CRS effective June 26, 2026; Form ADV Part 1A filed November 11, 2026; Merrill's Yields at a Glance rate sheet as of November 12, 2026; Sweep Program Guide (05/2026); Best Interest Disclosure Statement (September 2026); the Advisory Center schedule of miscellaneous account and service fees (03/2023), the Guided Investing with Advisor and Merrill Edge Self-Directed schedules (11/2025) and the Merrill Edge pricing page; SEC orders Release Nos. 105790, IA-6829, 101158, 97242, IA-5479 and 83886; and the FINRA BrokerCheck firm report for CRD 7691. Dollar figures marked “our arithmetic” apply the posted percentages to the balances shown and exclude fund expenses, manager fees and negotiated discounts unless a row says otherwise. Rate-sheet yields change and the November 12, 2026 table is a snapshot. The Item 11 count is our reading of the answer buttons in the filed PDF. This is analysis of public documents, not investment, legal or tax advice. Corrections: where a brochure has changed since November 13, 2026, the IAPD version governs.

Last updated: November 13, 2026.