No: U.S. Bank’s investment business is paid through commissions, markups, sales charges, direct payments from insurers, 12b-1 fees and revenue sharing on brokerage accounts, as well as wrap fees on advisory accounts. Since February 16, 2026 that business sits in U.S. Bancorp Advisors, LLC, which took over the retail brokerage, advisory and insurance work of U.S. Bancorp Investments. Its wrap program lists a maximum portfolio fee of 2.00% a year on the first $250,000.
U.S. Bancorp Advisors is registered with the SEC as both a broker-dealer and an investment adviser, which makes it a dual registrant, not a fee-only firm. Here’s what its own filings say.
How U.S. Bank is paid
U.S. Bancorp Advisors (CRD 14455) is a subsidiary of U.S. Bancorp and an affiliate of U.S. Bank. Its Form CRS is dated February 16, 2026, the day of the consolidation. The older Form CRS for U.S. Bancorp Investments (CRD 17868), dated November 14, 2025, describes the same pay model.
Brokerage. You “generally pay a commission for stock transactions,” a markup or markdown on bonds, and “a sales charge for mutual fund transactions.” On annuities, “we are paid by a direct payment from the insurance company.” The firm also receives ongoing fees from fund companies, such as 12b-1 fees, and says “we have a financial incentive when you trade more frequently and in larger amounts.” There’s no minimum, and the firm doesn’t monitor brokerage accounts unless it says so in writing.
Insurance. The wrap brochure says U.S. Bancorp Advisors is also a licensed insurance agency, doing business as USBA Insurance Services.
Advisory accounts. You pay “a negotiable wrap fee based on the value of the assets in your account (including cash),” billed quarterly. The firm says “we’re also compensated by revenue sharing arrangements,” and that it credits back the 12b-1 fees it receives on advisory accounts. It notes a wrap fee “is higher than a typical asset-based advisory fee” because it bundles trading and custody.
On its Form ADV Part 1, filed September 25, 2026, the advisory side reports being paid by a percentage of assets, and reports two other businesses: broker-dealer and insurance broker or agent.
The CFP Board’s standards allow “fee-only” only when neither the advisor nor a related party receives sales-related compensation. Commissions, sales charges, insurer payments and revenue sharing are sales-related pay, so U.S. Bank’s investment business doesn’t meet that test.
What else the filings disclose
Its own funds. Advisors may recommend First American money market funds, advised by affiliate U.S. Bancorp Asset Management. In non-retirement advisory accounts, those funds are the default cash sweep. The Form CRS says the firm and its affiliates “will receive more compensation” on proprietary products, though advisors aren’t paid more for them.
Bank-built models. Some wrap accounts use model portfolios from the Asset Management Group, a division of U.S. Bank. The brochure says there’s no separate manager fee for those models and that U.S. Bancorp Advisors pays U.S. Bank a flat yearly fee for them.
Your cash. In brokerage accounts, the default is a bank deposit program: U.S. Bank takes the cash as deposits and “pays us a fee based on the amount of such deposits.” The Form CRS adds: “Other cash management options may pay you more.”
Other payments. As a broker, the firm receives 12b-1 fees (shared with advisors), volume concessions on unit trusts and structured products, and “mutual fund and annuity support fees” from fund and annuity companies.
How advisors are paid. Brokerage advisors receive a share of commissions on a monthly payout grid. Advisory advisors receive a share of the wrap fee. Some are eligible for recruiting and retention bonuses and for referral pay when they send clients to affiliates. The Form CRS also says some advisors aren’t paid on transactions unless your combined U.S. Bank and U.S. Bancorp Advisors balances reach $100,000.
Disciplinary history. The Form CRS answers “Yes.” Details for both firms are on BrokerCheck, under U.S. Bancorp Advisors and U.S. Bancorp Investments.
What U.S. Bank costs
The Personal Portfolios Wrap Program is U.S. Bancorp Advisors’ advisory program. Its July 31, 2026 brochure lists this schedule of maximum portfolio fees, applied in tiers:
| Account size | Maximum portfolio fee |
|---|---|
| First $250,000 | 2.00% |
| Next $250,000 | 1.80% |
| Next $500,000 | 1.60% |
| Next $1,000,000 | 1.35% |
| Next $3,000,000 | 1.10% |
| Over $5,000,000 | 1.10% |
The portfolio fee pays U.S. Bancorp Advisors and your advisor, and the brochure says the advisor’s part “may be negotiable.” If you use an outside manager, model provider or tax overlay, a separate manager fee is added. The fee is charged on everything in the account, including cash, and funds charge their own expenses. Minimums run from $25,000 for most options to $150,000 for Guided UMA and the Unified Managed Portfolio, and $500,000 for U.S. Bancorp Advisors Managed Portfolios UMA; outside managers can set their own. Accounts in a household can be linked to reach lower tiers.
Financial planning has no separate fee for now. The March 31, 2026 planning brochure says “we do not charge a fee for our financial planning services,” and that you’ll pay fees or commissions on any accounts you open to carry it out.
Worked out on the maximum portfolio fee, with no manager fee:
- $500,000: $5,000 on the first $250,000 plus $4,500 on the next, or $9,500 a year (1.90%)
- $1 million: $9,500 plus $8,000, or $17,500 a year (1.75%)
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 the U.S. Bank wrap fee covers management, trading and custody. Our guides to what an advisor costs on $1 million and wrap fees vs à la carte fees go further.
The brochure also notes that similar bank-managed strategies are available directly from U.S. Bank to clients with larger balances, which “may offer qualified investors a lower rate” but a higher minimum. Our guide to private banker vs fee-only advisor covers that side of a bank.
Who U.S. Bank may suit
U.S. Bank may suit someone who banks there and wants an advisor, managed accounts and insurance in the same relationship, with planning at no extra charge. Most wrap options open at $25,000, and a self-directed brokerage account has no minimum. Someone who rarely trades may find brokerage costs less than a yearly percentage.
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 guide to independent advisor vs bank advisor covers the differences, and fee-only vs fee-based vs commission explains the pay models.
How to check it yourself
- Read the Form CRS. It’s four pages and linked from the firm’s SEC record. See what a Form CRS tells you.
- If your statements still say U.S. Bancorp Investments, ask which firm now holds your account and which agreement applies.
- Ask which role your advisor is in for each account: broker or investment adviser.
- Ask for your total fee in dollars, including the portfolio fee, any manager fee and fund expenses, and what your cash earns.
- 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 banks compare, see Is PNC fee-only? and Is Truist fee-only?.
Compare similar firms
Other banks we’ve checked against the fee-only definition: Bank of America, Truist, PNC, Citi. See all 50 firms.