No: Merrill is paid through commissions, markups, sales charges and revenue sharing from product sponsors, as well as advisory fees. Merrill Lynch, Pierce, Fenner & Smith Incorporated, a Bank of America company, is registered with the SEC as both a broker-dealer and an investment adviser. With a dedicated Merrill advisor, the advisory fee is negotiated up to 1.75% a year. Through Merrill Edge, advisory accounts cost a fixed 0.45% or 0.85%.
That makes Merrill a dual registrant, not a fee-only firm. Here’s what its own filings say.
How Merrill is paid
Merrill (CRD 7691) offers three ways to work with it, and its Form CRS, effective June 26, 2026, covers all of them.
Brokerage. You “pay commissions and other sales fees on a per transaction basis.” For some products, the Form CRS says, “the product sponsor or the manager will pay the fees and costs to us based on the value of your investment.” It also says: “The more trades that you make in your brokerage account, the more we and/or your financial advisor get paid.” Merrill doesn’t monitor brokerage accounts.
Advisory programs. You pay an asset-based fee that covers advice, trade execution and custody, and “not on a per trade basis.” Merrill monitors these accounts.
Self-directed (Merrill Edge Self-Directed). You place your own trades. Merrill Edge’s pricing page lists “$0 online stock and ETF trades with no trade or balance minimums” and $0.65 per options contract.
On its Form ADV Part 1, filed October 30, 2026, the advisory side reports being paid by a percentage of assets, fixed fees and commissions. It reports two other businesses: broker-dealer and insurance broker or agent. The Form CRS names Merrill Lynch Life Agency Inc., a Bank of America insurance agency, for insurance and annuities.
The CFP Board’s standards allow “fee-only” only when neither the advisor nor a related party receives sales-related compensation. Commissions, sales charges and revenue sharing are sales-related pay, so Merrill doesn’t meet that test as a firm.
Merrill Edge vs a Merrill advisor
The two brands sit inside the same firm and file under the same Form CRS. What changes is who you work with and how the fee is set.
| Merrill Guided Investing | Merrill Edge Advisory Account | Merrill Lynch Investment Advisory Program | |
|---|---|---|---|
| Who you work with | No one; online | Financial Solutions Advisors | Your own Merrill advisor |
| Yearly fee | 0.45% | 0.85% | Negotiated, up to 1.75% |
| Negotiable | No | No | Yes |
| Minimum | $1,000 or $5,000 per strategy | $20,000 | Generally none |
Financial Solutions Advisors are paid “salary and performance-based incentive compensation,” and the Form CRS says they “are not permitted to discount or waive fees.” A dedicated advisor in the Investment Advisory Program is “primarily compensated based on the IA Program fee charged for the account.”
What else the filings disclose
Product payments. Merrill requires some product sponsors to sign distribution agreements and, in some cases, “make payments to us for revenue sharing, sub-accounting services and for compensation purposes.” The October 2026 brochure adds that from January 1, 2027, Merrill expects to receive new “Support Fees,” which it calls “a type of revenue sharing,” from some fund, ETF and annuity companies.
Your cash. The Form CRS says uninvested cash is “swept” into “bank deposit accounts affiliated with us or into money market mutual funds.” Its banking products come from Bank of America, N.A.
Trading. Some trades are executed with Merrill or its affiliate BofA Securities as principal, and the Form CRS says they “make money when executing securities transactions.”
How advisors are paid. Brokerage advisors are paid mainly on commissions, and “an Advisor will receive more compensation for selling certain products over other products.” Advisors can also earn awards for growth in banking, lending and advisory assets, and referral payments for business sent to Merrill affiliates.
Discounts. The Investment Advisory Program brochure says advisors receive fewer “production credits (by 10% or more)” when a client’s fee rates fall below levels Merrill sets for each wealth tier, so an advisor “is incentivized not to offer a Merrill Lynch Fee Rate below such rate levels.”
Disciplinary history. The Form CRS answers “Yes” and points to Investor.gov. The details are on BrokerCheck.
What Merrill costs
Merrill Edge’s two advisory programs publish one fixed rate each, set out in their September 18, 2026 brochures. Fund expenses are on top.
- Merrill Guided Investing (0.45%): $2,250 a year on $500,000, $4,500 on $1 million
- Merrill Edge Advisory Account or Guided Investing with Advisor (0.85%): $4,250 on $500,000, $8,500 on $1 million
With a dedicated advisor, the Investment Advisory Program brochure dated October 30, 2026 sets a maximum Merrill fee rate of 1.75%. The rate is negotiated, either as one rate or as a schedule that steps down by asset level, and can count assets across your household. If you pick a managed strategy, the manager’s fee is added. Merrill doesn’t publish a typical rate. At the ceiling, the Merrill fee alone would be up to $8,750 a year on $500,000 and up to $17,500 on $1 million. That’s 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. 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), whatever your balance, 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 Merrill wrap fee covers management, trading and custody. Our guides to wrap fees vs à la carte fees and robo-advisors vs financial advisors go further.
Who Merrill may suit
Merrill may suit someone who banks with Bank of America and wants investing, cash management and lending in one place. Merrill Edge’s fixed 0.45% and 0.85% programs suit someone who wants a managed portfolio at a published price, with or without a phone advisor. A dedicated Merrill advisor suits someone who wants one named person, access to outside managers and individual securities, and is ready to negotiate the fee.
Someone who wants advice from a firm paid only by them, or mainly wants planning rather than managed investments, may want to compare a fee-only planner who charges a flat or hourly fee first. Our guides to independent RIA vs wirehouse and independent advisor vs bank advisor cover the differences. For other large firms, see Morgan Stanley and Edward Jones.
How to check it yourself
- Read the Form CRS. It’s at ml.com/CRS and on the firm’s SEC record. See what a Form CRS tells you.
- Read Item 4 of your program’s brochure, which lists the fee rate and how it’s set.
- Ask which role your advisor is in for each account: broker or investment adviser.
- Ask for your total cost in dollars, including the Merrill fee, any manager fee and fund expenses.
- 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.
Compare similar firms
Other wirehouses and investment banks we’ve checked against the fee-only definition: Morgan Stanley, UBS, Wells Fargo Advisors, J.P. Morgan, Goldman Sachs. See all 50 firms.