Vanguard Advisers Inc

Fees and compensation
Clients are subject to a gross advisory fee but pay to VAI a net advisory fee. As detailed and computed below,
the fee is designed to mitigate conflicts of interest for any revenues that Vanguard receives on assets held
in the underlying investments (for example, revenues from Vanguard Funds). Each Service will reduce your
gross advisory fee by the amount of revenue that Vanguard (or a Vanguard affiliate) collects on your Portfolio
in order to calculate the net advisory fee. The net advisory fee is expected to be approximately 0.15%-

0.16% or 0.30%-0.31% across your Portfolio for a total market all‐ index investment option for Digital
Advisor and Personal Advisor, respectively, although actual expenses will vary based on the specific
holdings and investment settings in each Enrolled Account. Your net advisory fee can also vary by Enrolled
Account type. The combined annual costs of enrolling in a Service and investing in Vanguard Funds or
collective investment trusts will vary for Participants within a particular plan. As described in more detail
below, the gross advisory fees do not include investment expense ratios—such as fees paid to the funds'
third‐party managers, which aren't credited because they are not Vanguard revenues.

Gross Advisory fee
The gross advisory fee compensates us for the ongoing discretionary management of the Enrolled
Accounts and is inclusive of the services described in this brochure. The gross advisory fee will be
calculated across all securities in your Enrolled Accounts, except for money market fund securities (or
other cash equivalent assets like assets held in a bank sweep settlement account) held in the settlement
fund within your Enrolled Accounts.

The gross advisory fee does not include the expenses that you incur to invest in the underlying funds,
collective investment trusts, or ETFs in your Enrolled Accounts. You will be responsible for paying
underlying fund, collective investment trust, or ETF expenses charged at the individual holding levels
within your Enrolled Accounts. These underlying funds, collective investment trust, or ETF expenses vary by
fund and share class, and are expenses that all fund and ETF shareholders and collective investment trust
holders pay. Details of fund and ETF expenses can be found in each fund’s or ETF’s prospectus. These
expenses are not itemized or billed separately. The gross advisory fee is rounded to the nearest whole
penny using standard rounding for the purpose of calculating the net fee amount to be charged.

        Enrolled Vanguard Brokerage Accounts
        Your enrolled Vanguard Brokerage Accounts will be subject to an annual gross advisory fee based
        on your average daily balance of the assets held in your account.

        Digital Advisor’s annual gross advisory fee for each Vanguard Brokerage Accounts is 0.20% for its all‐
        index investment options or 0.25% for the exclusive active/index mix. Personal Advisor’s annual
        gross advisory fee for Vanguard Brokerage Accounts is 0.35% for its all‐index investment options
        and 0.40% for the exclusive active/index mix.

        Enrolled Participant Accounts
        Your enrolled Participant Accounts will be subject to an annual gross advisory fee based on your
        average daily balance of funds and collective investment trusts held in your account. Digital
        Advisor’s and Personal Advisor’s annual gross advisory fees for your Participant Account varies
        by plan, investment setting, and Service. Please see your plan fee disclosure notices for the
        applicable annual gross advisory fees that apply to your plan assets.

Net Advisory Fee (Credit Amount)
The annual gross advisory fee applied to each Enrolled Account is reduced by a credit of the actual revenue
Vanguard (or a Vanguard affiliate) accrues and retains from expense ratios of Vanguard Funds or other
Vanguard revenues received from Portfolio investments (e.g., 12b‐1 or revenue sharing fees) in each
Enrolled Account. Revenue sharing fees as well as certain other affiliated broker dealer fees are credited
manually and are not automated.

We will not credit de minimis amounts of revenue sharing or other affiliated revenues identified
through manual reviews less than $1.00 that we receive in the event you erroneously transfer securities

into a managed account, or, for Participant Accounts, securities added to the account in relation to
investments held prior to management of the account. Assets held in a Vanguard Brokerage Account’s
settlement fund (either money market or bank sweep) are not strategic allocations. Net advisory fees
will not be a negative amount.

Your resulting net advisory fee calculated for each account will be the actual fee collected. These actual
amounts will vary based on your unique asset allocation and fund investments within the Portfolio and
the holdings in each Enrolled Account. The credit amount will be rounded to the nearest whole penny
using standard rounding for the purpose of calculating the net advisory fee.

Account specific credit information

        Enrolled Vanguard Brokerage Accounts
        Enrolled Vanguard Brokerage Accounts will be primarily composed of ETF shares and Vanguard
        mutual funds that trade commission‐free through VMC, doing business as Vanguard Brokerage
        Services, ® a registered broker‐dealer that’s a wholly owned subsidiary of Vanguard and an
        affiliate of VAI. Expected net advisory fees will vary based on your selected investment setting.
        A total market all‐index investment setting comprised of the Four Totals ETFs will be credited
        approximately 0.04% as of the date of this brochure resulting in a net advisory fee of
        approximately 0.16% for Digital Advisor and approximately 0.31% for Personal Advisor. For the
        ESG all‐index investment setting, approximate net advisory fees are expected to range from
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Types of clients
Certain officers, directors, and substantial shareholders, including any employees subject to Rule 144 of
the Securities Act of 1933, as amended, or Section 16 of the Securities Exchange Act of 1934, as amended
are not eligible for either Service (including both Participant Accounts and Vanguard Brokerage
Accounts). Additionally, clients of certain other VAI retail advisory service (e.g., Select,) are not eligible to
enroll. Clients may not be enrolled in both Digital Advisor and Personal Advisor at the same time. Clients
are required to maintain permanent residence in the 50 United States, the District of Columbia, and the
US Virgin Islands or have an APO/FPO/DPO mailing address in order to enroll and stay enrolled in a
Service.

Vanguard Brokerage Accounts
Digital Advisor is made available to retail clients with a minimum of $100 in each eligible Vanguard
Brokerage Account. Enrollments in Personal Advisor require an aggregate $50,000 balance or greater in
eligible Vanguard Brokerage Accounts. For each brokerage account you seek to enroll, all assets in the
brokerage account's settlement fund or in certain investment types (based on eligibility screening by a
Service at the time of enrollment) and/or the brokerage account's settlement fund are eligible to enroll.

Eligible clients include those with individual accounts (including IRAs), revocable living trusts (subject to
trustee authorization), and joint accounts with rights of survivorship. Other account types may be
considered for purposes of goals forecasting, but we won’t invest or reallocate assets in those ineligible
accounts. If you enroll a revocable living trust we assume you intend to use those funds towards your
goals. We do not review any of the related trust documents.

Participant Accounts
Participants enrolled in eligible 401(k), or Roth 401(k), 401 (a), or 403 (b) employer‐sponsored
retirement plans, whose employers have approved Digital Advisor or Personal Advisor, are eligible to
use that Service. Other account types may be considered for purposes of goals forecasting, but the
Service won’t invest or reallocate assets in those other employer‐ sponsored accounts.

A Participant may enroll their account(s) in Personal Advisor if their eligible Participant Account meets the
$250,000 minimum. For Participants, eligible account types include 401(k), or Roth 401(k), 401(a), or
403(b).

Alternatively, a Participant may enroll Vanguard Brokerage Accounts and Participant Accounts if (in all
circumstances Participants must enroll their Participant Account):
      • They elect to enroll Vanguard Brokerage Accounts that total $50,000 or more then they may also enroll
        their Participant Account at any asset level; or
      • Their eligible Vanguard Brokerage Accounts combined with an eligible Participant Account satisfy the
        $250,000 minimum.

Methods of analysis, investment strategies, and risk of loss
VAI’s investment methodology incorporates our own investment philosophies and beliefs, such as the
benefits of having clear and appropriate investment goals, developing a suitable asset allocation using
broadly diversified funds (in other words, balance), minimizing costs, and maintaining perspective and long‐
term discipline. Our methodology, which is approved and periodically reviewed by VAI’s Advice Policy
Committee, is based on Vanguard’s own fundamental research, as well as research obtained from a wide
variety of external sources, both public and private. Our methodology is driven by long‐term financial goals,
not by market timing or short‐term investment performance. Rather than attempting to predict which
investments will provide superior performance at any given time, VAI believes that it can provide the best
opportunity for success by maintaining a broadly diversified Portfolio— including investments from a variety
of market sectors and asset classes. Additionally, we believe dependent on your appetite for financial risk,
an asset mix that balances a chance for higher returns from actively managed concentrated funds with the
broad diversification of index fund could be appropriate.

We periodically review our investment methodology which may result in modifications that impact your
Portfolio’s asset allocation, security selection, or other aspects. Each Service supports the goal of investing
for retirement savings and additional financial goals. The objective of the retirement goal is to build
sufficient wealth to cover expected income needs through retirement. You may also set up multiple
financial goals after enrollment and prior to enrollment subject to availability in your onboarding flow.
This multi‐goal capability helps you balance your retirement goal with other financial goals. We apply
an overall long‐ term investment philosophy to the multi‐goal capability that allocates investable assets
to near‐ term goals first to ensure the funds needed to cover expenses when goals reach maturity.

We also treat accounts as fungible (or interchangeable) assets and allocates assets in those accounts across
goals based on the financial goal‐ based plan you set.

Investment strategy for the Portfolio
Our investment strategies are designed with a disciplined, long‐term approach that focuses on
managing risk through appropriate asset allocation and diversification. Our methodology uses a
strategic approach by first focusing on the mix of asset classes (i.e., stocks, bonds, cash) that aligns with your
willingness and ability to take risk and is appropriate to meet your financial goals over time regardless
of your investment setting. Subject to availability, you may be able to further customize your Portfolio
through certain elections. Regardless of the customization, we require that your Portfolio remains
diversified by asset class and within each asset class to ensure that no single security or class of securities
will impose an unreasonable level of risk.
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