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Updated September 28, 2026. Quick answer: Mostly yes, with one carve-out. Frost Investment Services is registered with the SEC only as an investment adviser, so on your advisory account it owes you a fiduciary duty under the Investment Advisers Act of 1940. Its own Form CRS states: “When we provide investment advisory services, we act as a fiduciary, meaning we are legally required to put your interests ahead of our own at all times. This fiduciary duty applies to all our recommendations, portfolio management and account oversight services.” A limited number of Frost Investment Services’ financial professionals are separately licensed to sell brokerage products in a different capacity, where the weaker Regulation Best Interest standard, not a fiduciary duty, applies instead.
How it’s registered
From Frost Brokerage Services, Inc. & Frost Investment Services, LLC, Form CRS (joint Relationship Summary) (March 2026): “Frost Brokerage Services, Inc. is a registered broker-dealer with the U.S. Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Frost Investment Services, LLC is a registered investment adviser with the SEC. Both firms are affiliates and wholly owned subsidiaries of Frost Bank.”
The standard of conduct, in its own words
“When we provide investment advisory services, we act as a fiduciary, meaning we are legally required to put your interests ahead of our own at all times. This fiduciary duty applies to all our recommendations, portfolio management and account oversight services.”
On commissions: “Brokerage representatives may be compensated based on commissions and fees generated by transactions made in your account, or they may be paid a salary. Regardless of how they are compensated, they have an opportunity to earn incentive compensation if they meet goals tied to total sales generated from commissions and fees, although incentives cannot be based on the sale of specific securities or types of securities within a limited period of time. However, our policies prohibit financial professionals from recommending transactions solely to generate fees, and we review transactions to ensure that recommendations align with your investment goals. Investment adviser accounts Your investment adviser is compensated through fees charged for managing your advisory account. These fees are based on the total value of cash and assets in your account.”
Fiduciary status by capacity
| Capacity | Registration | Standard you’re owed | Can earn commissions | Source |
|---|---|---|---|---|
| As your investment adviser (most clients) | SEC-registered investment adviser | Fiduciary duty (Investment Advisers Act of 1940) | No (asset-based advisory fee: $4,900 a year, 0.98% on a $500,000 account) | Frost Brokerage Services, Inc. & Frost Investment Services, LLC, Form CRS (joint Relationship Summary), March 2026 |
| As a dually licensed representative (limited) | Also FINRA-registered broker-dealer representative, separate capacity | Regulation Best Interest (not a fiduciary duty) | Yes | Frost Brokerage Services, Inc. & Frost Investment Services, LLC, Form CRS (joint Relationship Summary), March 2026 |
What this means for what you pay
Fiduciary status is one input, not the whole picture. Frost Investment Services discloses a published fee that runs $4,900 a year on a $500,000 account; see the full dollar breakdown from Frost Investment Services’ own fee disclosure before deciding whether the standard of conduct here changes your answer.
If the answer above changes your mind about staying, see what it costs to leave Frost Investment Services, or read the general mechanics of switching financial advisors.
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- Frost Brokerage Services, Inc. & Frost Investment Services, LLC, Form CRS (joint Relationship Summary) (March 2026): https://reports.adviserinfo.sec.gov/crs/crs_286129.pdf
- SEC Investment Adviser Public Disclosure, Frost Investment Services, LLC (CRD #286129): https://adviserinfo.sec.gov/firm/summary/286129
- Frost Investment Services, LLC, SEC Form ADV filing: https://reports.adviserinfo.sec.gov/reports/ADV/286129/PDF/286129.pdf
Methodology. This page was built September 28, 2026, quoting directly from Frost Investment Services’ 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.