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Is TD Wealth a Fiduciary? What Its Own Form CRS Says (2026)

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Updated September 24, 2026. Quick answer: It depends which hat TD Wealth is wearing. As your investment adviser, TD Wealth owes you a fiduciary duty under the Investment Advisers Act of 1940. As your broker-dealer, TD Wealth owes you Regulation Best Interest, a real and enforceable standard, but not a fiduciary duty. TD Wealth’s own Form CRS states: “When we provide you with a recommendation as your broker-dealer or act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours.”

How it’s registered

From TD Private Client Wealth LLC Form CRS (June 15, 2026): “TD PRIVATE CLIENT WEALTH LLC (“TDPCW,” “we,” “us,” or “our”) is registered with the U.S. Securities and Exchange Commission (“SEC”) as both a broker-dealer and investment adviser and is a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”).”

TD Wealth is the brand name; the SEC-registered entity is TD Private Client Wealth LLC (TDPCW), a wholly owned subsidiary of TD Bank, N.A. Its single Form CRS document covers all of TDPCW’s advisory programs together, including traditional managed-account programs and a separate digital Automated Investing robo-adviser program; this page extracts only the firm-level registration, conduct-standard and compensation sentences, not program-specific fee tiers.

The standard of conduct, in its own words

“When we provide you with a recommendation as your broker-dealer or act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours.”

On commissions: Our TDPCW financial professionals are compensated, in part, based on the account type and relationship you have with us. For brokerage services, your financial professional will be compensated from the commissions we charge, and a conflict of interest arises based on the type and frequency of transactions effected in your brokerage account. For investment advisory services, your financial professional receives compensation based on a percentage of the assets under management in your account, and a conflict of interest arises based on the compensation we make due to your enrollment in a fee-based program and the addition of assets to your account.

Fiduciary status by capacity

CapacityRegistrationStandard you’re owedCan earn commissionsSource
As your broker-dealerSEC-registered broker-dealerRegulation Best Interest (not a fiduciary duty)YesTD Private Client Wealth LLC Form CRS, June 15, 2026
As your investment adviserSEC-registered investment adviserFiduciary duty (Investment Advisers Act of 1940)No (asset-based advisory fee: $5,500 a year, 1.10% on a $500,000 account)TD Private Client Wealth LLC Form CRS, June 15, 2026

What this means for what you pay

Fiduciary status is one input, not the whole picture. TD Wealth discloses a published fee that runs $5,500 a year on a $500,000 account; see the full dollar breakdown from TD Wealth’s own fee disclosure before deciding whether the standard of conduct here changes your answer.

If the answer above changes your mind about staying, read the general mechanics of switching financial advisors, or use a dated termination letter once you decide.

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Sources

Methodology. This page was built September 24, 2026, quoting directly from TD Wealth’s own current Form CRS, with the source linked above; any distinction we could not independently confirm this session is named as an honest gap rather than presented as verified. Nothing here is personalized financial, tax, legal, or investment advice, and it is not a substitute for reading the firm’s own Form CRS. See our Editorial Policy, Corrections, Affiliate Disclosure, and Disclaimer.

Weighing whether to move ahead? Read the full TD Wealth review, including its fiduciary status and what it costs to leave.

Comparing TD Wealth against other options? See TD Wealth alternatives, including a lower-fee full-service firm, a flat-fee route, and a robo/hybrid.

How does this compare? See how 127 advisory firms are registered, from each firm’s own SEC record.

Already with TD Wealth and weighing a move? How to leave TD Wealth covers what it costs to transfer out.