No: Citi is paid through commissions, loads, markups, sales charges and revenue sharing from product sponsors on its brokerage business, plus fees from its own products, as well as advisory fees. Citi Personal Wealth Management offers investments through Citigroup Global Markets Inc., which is registered with the SEC as both a broker-dealer and an investment adviser. Its advisory programs charge a negotiated fee of up to 2.00% a year.
That makes Citi’s investment business a dual registrant, not a fee-only firm. Here’s what its own filings say.
How Citi is paid
Citigroup Global Markets (CRD 7059), often shortened to CGMI, serves clients of Citi Personal Wealth Management, Citi Private Bank and Citi Global Wealth at Work. Its Form CRS is dated September 30, 2026. It notes that “bank-managed investment advice is offered through Citibank, N.A.,” which the Form CRS doesn’t cover.
Brokerage. You typically pay “a transaction-based expense each time you buy or sell”: a commission on stocks, ETFs, options and agency bonds, a “load” on mutual funds, a placement fee on alternative funds, and a markup or markdown on bonds traded from Citi’s inventory. The Form CRS says “the more investment transactions (‘trades’) you make, the more transaction-based revenue we earn.” Citi isn’t required to monitor brokerage accounts.
Advisory programs. You pay “an ongoing fee based on the assets in your account,” monthly or quarterly. “That fee is negotiable.” If an outside manager runs the account, you pay that manager a separate fee. A unified managed account program “expected to launch later this year or early 2027” will add a platform fee.
Insurance. The advisory brochure says insurance is offered through Citigroup Life Agency LLC, an affiliate “through which CGMI representatives can function as insurance representatives.”
On its Form ADV Part 1, as filed October 2, 2026, the advisory side reports being paid by a percentage of assets and by fixed fees, and reports a broker-dealer business.
The CFP Board’s standards allow “fee-only” only when neither the advisor nor a related party receives sales-related compensation. Commissions, loads and revenue sharing are sales-related pay, so Citi doesn’t meet that test as a firm.
What else the filings disclose
Its own products. Citi may recommend products “issued, sponsored, managed, or sub-advised by us or our affiliates,” and earns from them.
Payments from product companies. Citi may receive a sales load or upfront fee and ongoing distribution and shareholder servicing fees, which it shares with advisors. It also receives revenue sharing. The advisory brochure says that from January 1, 2026, Citi expanded these arrangements for products held in advisory accounts, receiving up to 0.12% a year on mutual fund holdings, or up to 20% of the management fee on funds, separately managed accounts and models, excluding retirement accounts. The Form CRS names BlackRock and iCapital as paying Citi more when certain thresholds are reached.
Your cash. Under its arrangement with Pershing, the clearing firm, Citi receives revenue when brokerage cash is swept into the bank deposit program or money market funds.
Account fees. The Form CRS says service fees such as wire and transfer fees “are set at amounts higher than the amount that Pershing charges us.” The brochure gives one example: Pershing charges Citi $25 for an outgoing account transfer, and Citi charges clients $95.
How advisors are paid. Citi’s financial professionals “earn a salary and typically receive variable compensation” tied to revenue and new assets. Citi Personal Wealth Management advisors also earn credits for mortgage referrals and securities-based loans, and the Form CRS says recruiting pay can include loans repaid through asset-based bonuses.
Disciplinary history. The Form CRS answers “Yes.” The details are on BrokerCheck.
What Citi costs
Citi publishes a ceiling for its advisory programs, not a schedule of typical rates. The March 25, 2026 brochure says the negotiable fee can be “lower than the maximum fee of 2.00%,” and adds: “CGMI and its financial advisers have an incentive NOT to negotiate fees below 2%.”
| Program (Citi Personal Wealth Management) | Yearly fee | Minimum |
|---|---|---|
| Advisory programs (such as Citi Advisor, Citi Portfolio Manager and Dynamic Allocation Portfolios) | Up to 2.00% (negotiable), plus any outside manager fee | $25,000 to $100,000, by program |
| Citi Wealth Builder (automated) | 0.25% | $5,000 to $10,000 |
| Citi Wealth Builder Plus (automated, with advisor access and a plan) | 0.60% | $25,000 |
Outside manager fees depend on the program and strategy: the brochure gives typical ranges such as 0.05% to 0.60% a year in the Fiduciary Services and Manager Selection programs, and 0.20% to 1.00% for non-bond strategies in Consulting and Evaluation Services. Fund and ETF expenses are on top in every program. Citi Personal Wealth Management’s financial planning brochure says “no fee is charged” for its Financial Planning Program.
At the published ceiling, the CGMI fee comes to:
- $500,000: up to $10,000 a year
- $1 million: up to $20,000 a year
In Citi Wealth Builder, the published rate is $1,250 a year on $500,000, or $3,000 in Wealth Builder Plus.
The ceiling is a maximum, not a quote, so ask for your rate in writing. For comparison, fee-only firms that publish a percentage fee charge a median 1% of assets, or $5,000 on $500,000 and $10,000 on $1 million at that rate. Fee-only planners who charge a flat fee for ongoing planning charge a median $4,500 a year (middle half $2,400 to $7,200), and a one-time plan has a median of $2,000. A flat-fee planner may not manage your investments for that price, while a Citi advisory fee covers management and, in wrap programs, most trading. Our guides to what an advisor costs on $1 million and robo-advisor vs financial advisor go further.
Who Citi may suit
Citi may suit someone who banks with Citi and wants investments, lending, insurance and an advisor connected to the same relationship. Someone who mainly wants a low-cost managed portfolio can start in Citi Wealth Builder at 0.25%, and someone who wants a plan can get one through the planning program without a separate fee. A wealthier client may value access to outside managers and alternative funds.
Someone who wants advice from a firm paid only by them, or a fee they can compare before meeting anyone, may want to talk to an independent fee-only advisor first. Our guides to independent advisor vs bank advisor and private banker vs fee-only advisor cover the differences, and independent RIA vs wirehouse covers large brokerage firms.
How to check it yourself
- Read the Form CRS. It’s linked from the firm’s SEC record. See what a Form CRS tells you.
- Ask which entity is advising you: Citigroup Global Markets as broker or adviser, or Citibank, N.A., whose bank-managed advice has no Form ADV.
- Ask for your fee in dollars, including any manager fee, fund expenses and account service fees.
- Ask whether any fund or manager you’d hold pays Citi revenue sharing.
- Look up your advisor on BrokerCheck.
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 large firms compare, see Is Morgan Stanley fee-only? and Is Bank of America fee-only?.
Compare similar firms
Other banks we’ve checked against the fee-only definition: Bank of America, Truist, PNC, U.S. Bank. See all 50 firms.