No: Bank of America is paid through commissions, sales charges and payments from product sponsors at Merrill, its broker-dealer, as well as advisory fees, and through the investment management, trust, lending and deposit business of its Private Bank. Brokerage and advisory accounts that Bank of America customers open are held at Merrill Lynch, Pierce, Fenner & Smith, which is registered with the SEC as both a broker-dealer and an investment adviser. Its lowest-cost advised option, Merrill Guided Investing, charges 0.45% a year.
That means neither of Bank of America’s investment channels is fee-only. This page covers the bank’s own channels. For Merrill’s full-service advisors, see Is Merrill fee-only?
How Bank of America is paid
Bank of America Corporation’s 2025 Form 10-K, filed February 25, 2026, says its wealth business “consists of two primary businesses: Merrill Wealth Management and Bank of America Private Bank.” A bank customer usually meets one of them.
Merrill accounts for bank customers. Merrill’s Form CRS, effective June 26, 2026, lists three ways to work with it: a dedicated advisor, Financial Solutions Advisors by phone or in some wealth management centers, or on your own. In brokerage accounts, including self-directed Merrill Edge accounts, “you pay commissions and other sales fees on a per transaction basis.” For certain products, “the product sponsor or the manager will pay the fees and costs to us.” In advisory programs you pay an asset-based fee instead. Insurance and annuities are offered through Merrill Lynch Life Agency, an affiliate.
Bank of America Private Bank. The Private Bank is “a division of Bank of America, N.A.,” and its disclosures say “trust, fiduciary and investment management services” are provided by the bank itself. The 10-K describes it as serving high net worth and ultra high net worth clients with “wealth structuring, investment management, trust and banking needs.” It also says certain Private Bank associates are registered representatives of Merrill and can offer Merrill’s investment products.
Federal law leaves banks out of the definition of an investment adviser, so the Private Bank’s investment management has no Form ADV brochure or Form CRS. We found no SEC adviser record for Bank of America, N.A. That’s normal for a bank, but it means there’s no public fee schedule to read.
The CFP Board’s standards allow “fee-only” only when neither the advisor nor a related party receives sales-related compensation. Merrill’s commissions and sponsor payments are sales-related pay, and Merrill and the Private Bank are both owned by Bank of America, so the bank doesn’t meet that test.
What else the filings disclose
Your cash. Merrill’s Cash Sweep Program moves uninvested cash “into bank deposit accounts affiliated with us or into money market mutual funds.” In Merrill Guided Investing, the brochure says cash is swept to deposits at Bank of America, N.A. and other affiliated banks, and that this “benefits Merrill and benefits our Bank Affiliates.” Cash in the account is also charged the program fee.
Payments from product companies. Merrill requires some product sponsors to sign distribution agreements and, in certain cases, “make payments to us for revenue sharing, sub-accounting services and for compensation purposes.”
Referrals between bank and broker. Merrill’s advisory brochures say its employees may refer clients to the bank, “including its private bank,” and bank employees may refer clients to Merrill, and that “these referrals may involve the payment of referral fees.”
Banking discounts. The Merrill Guided Investing brochure says Bank of America may offer “Program Fee discounts, rebates or credits” to its banking clients who also use Merrill. Merrill’s Form CRS says Financial Solutions Advisors are not permitted to discount or waive fees.
How advisors are paid. Merrill’s Form CRS says its financial professionals are paid on brokerage transactions, advisory program services “and making referrals to Affiliates.”
Disciplinary history. Merrill’s Form CRS answers “Yes.” The details are on BrokerCheck and the SEC’s adviser record.
What Bank of America costs
The two advised programs most bank customers are offered publish flat rates, from their September 18, 2026 brochures:
| Program | Yearly program fee | Minimum |
|---|---|---|
| Merrill Guided Investing (online, self-guided) | 0.45%, not negotiable | $1,000 or $5,000 for growth strategies; $50,000 for income strategies |
| Merrill Guided Investing with Advisor | 0.85% | $20,000 |
Merrill’s Form CRS lists the same 0.85% for the Merrill Edge Advisory Account. The program fee covers advice, trading and custody at Merrill. The funds in the portfolio charge their own expenses on top.
Worked out on the published rates:
- $500,000: $2,250 a year in Merrill Guided Investing, or $4,250 with an advisor
- $1 million: $4,500 a year, or $8,500 with an advisor
These programs give you Merrill-managed portfolios rather than a full planning relationship, so the fairer comparison is with other automated or hybrid services, not a full planning relationship. Fee-only firms that publish a percentage fee charge a median 1% of assets, and flat-fee planners charge a median $4,500 a year (middle half $2,400 to $7,200) for ongoing planning, or $2,000 for a one-time plan. A flat-fee planner may not manage your investments for that price. Our guide to robo-advisor vs financial advisor covers the trade-off.
The Private Bank doesn’t publish what it charges. A relationship there can include an investment management fee, trust fees, loan interest and the spread the bank earns on your deposits. Our guide to private banker vs fee-only advisor explains each one and what to ask.
Who Bank of America may suit
Bank of America may suit someone who wants investments next to their checking account with one login. Merrill Guided Investing is a low published price for a managed portfolio, and banking clients may get it for less. A wealthy family that needs large loans, a professional trustee or trust administration may value the Private Bank, where those services sit in one relationship.
Someone who wants advice from a firm paid only by them, or a planning relationship priced before they meet anyone, may want to compare an independent fee-only advisor first. Our guide to independent advisor vs bank advisor covers the differences, and many households use a bank for lending and a fee-only advisor for the plan.
How to check it yourself
- Ask which entity you’re dealing with for each account: Merrill as broker, Merrill as adviser, or Bank of America, N.A. as trustee or investment manager.
- For Merrill accounts, read the Form CRS linked from Merrill’s SEC record. See what a Form CRS tells you.
- For Private Bank accounts, ask for the investment management agreement and fee schedule, since there’s no Form ADV to read.
- Ask what your cash earns in the sweep and what the bank earns on it.
- Look up the person on BrokerCheck; Private Bank associates who are Merrill representatives appear there.
Our guide to telling whether an advisor is fee-only walks through each check, and questions to ask a financial advisor gives you the rest. For how other banks compare, see Is Citi fee-only? and Is Truist fee-only?.
Compare similar firms
Other banks we’ve checked against the fee-only definition: Truist, PNC, U.S. Bank, Citi. See all 50 firms.