A. General Description of Advisory Firm SigFig Wealth Management, LLC (“SigFig”) is a limited liability company that was founded in 2011 and is an investment adviser registered with the SEC. SigFig is a wholly-owned subsidiary of Nvest, Inc (“Nvest”).
Advisory services are provided by SigFig, while Nvest and its affiliates provide other non-advisory services and products.
B. General Description of Advisory Services Offered 1. Investment Advisory Services SigFig provides free portfolio tracking service to individuals (“Users”) by allowing them to link their external brokerage accounts to SigFig’s web-based platform.1 Utilizing its proprietary web-based technology, SigFig also provides discretionary investment advisory and portfolio management services to individuals who open an investment management account with SigFig (the “Clients”) and enter into an investment advisory agreement (“Investment Advisory Agreement”). Clients also include individuals that open investment advisory accounts with SigFig through a co-branded program with another partner institution, where SigFig acts as the sole investment adviser. SigFig’s rebalancing rules and trading logic generate investment recommendations based on such Client’s risk profile, trading patterns and existing individual portfolio investments, if any, as provided by the Client. SigFig’s advisory services are made available to Clients through its website at www.sigfig.com (www.sigfig.com/site/#/home/am), mobile apps and through co-branded pages and widgets on its partners’ websites (collectively the “Website”). In all of these cases, including those where the services are made available to Clients through a co-branded partner website, SigFig’s web-based platform directs the investment advisory services and hosts certain Client data.
SigFig’s online platform allows Users and Clients to: ● Sync portfolio data from the existing brokerage accounts and review it holistically in an easily accessible interface; ● Track and analyze holdings; ● Receive real-time and delayed market data and news on securities in their portfolios; ● Calculate portfolio performance and other analytics; ● Receive analysis and/or recommendations on their trading style and trading behaviors; and ● Create and edit mock portfolios and watch lists.
1It should be noted that Users do not enter into an investment agreement with, nor do they pay fees to, SigFig. Further, SigFig does not have any discretion over Users’ brokerage accounts, nor does SigFig provide recommendations to Users to purchase or sell any specific securities. For the aforementioned reasons, Users are not considered advisory clients of SigFig.
In addition, Users who are also Clients of SigFig can: ● Use tax-loss harvesting feature (optional);2and ● Receive analysis and/or recommendations of mutual funds and exchange-traded funds (“ETFs”) based on their answers to a risk profile questionnaire, existing investment portfolio and transaction history, if any.
As noted above, SigFig’s technology enables Users and Clients to import their external accounts data onto SigFig’s platform. Users and Clients then have the ability to see their synced portfolio in one place, irrespective of which and how many SigFig-supported brokerage firms they use. Users must make an independent determination as to whether to follow any guidance provided through the SigFig Website and must make their own arrangements for execution of any desired transactions, the hiring of any investment adviser or the use of any broker-dealer. As noted, SigFig does not provide investment advisory services to Users.
SigFig currently provides investment advice only with respect to model portfolios that include predominantly mutual funds and ETFs, and to a lesser extent, individual stocks and other holdings (collectively, “Securities”) and provides tax-loss harvesting services. As part of its services, SigFig works with certain broker-dealers that provide custodial and execution services to Clients. SigFig’s advice is currently intended to be limited to the foregoing.
2Tax-loss harvesting is a process that, if activated and applicable, is designed to realize losses to offset gains made within taxable accounts managed by SigFig and/or a partner financial institution. SigFig does not provide tax or legal advice. Please see additional information below in Item 8.B.
2. Sub-Advisor, Portfolio Manager and Service Provider Services to Partners Additionally, SigFig and its parent company enter into partnerships with various Financial Institutions that may be registered investment advisers, banks, broker-dealers or other financial institutions (the “Financial Institution(s)” or “Partner(s)”). Under these arrangements, we license proprietary web-based technology to the Financial Institutions acting as a service provider to the respective Partner and, depending on the nature of the partnership, SigFig may serve as the sole adviser to the Clients referred by the Partner (as noted above and described further in Item 14 of this Brochure), or as a co-adviser or sub-adviser to the Partner. In these sub-advisory arrangements with the Partner, SigFig provides certain portfolio management services to the Partner for the benefit of its clients or possibly directly to the Clients depending on the nature of the partnership and relationship with the client.
The sub-advisory and portfolio management services are provided by SigFig primarily through the use of its proprietary technology, and a website operated and hosted by or on behalf of SigFig by the respective Financial Institution for the benefit of joint clients or those clients of the Financial Institutions (“Digital Advice Investors”) who

elect to receive such investment advisory services (the “Digital Advice Program”). In the case of such sub-advisory and portfolio management services, SigFig generates and implements investment recommendations based on the information and specifications provided to it by the prospective Digital Advice Investors and/or the Financial Institution.
In this capacity, SigFig’s services are generally limited to the following, depending on the nature of the partnership: ● Provide to prospective Digital Advice Investors a risk profile questionnaire (as prepared by the Partner, or as developed by SigFig and approved by the Partner) that will serve as the basis for the development of the Digital Advice Investors’ risk profile and investment objectives, from which investment recommendations are provided; ● Generate and/or present investment recommendations to each prospective Digital Advice Investor as provided to SigFig from the Financial Institution or based on the parameters determined or approved by the Financial Institution; ● Implement, on a discretionary basis, such recommendations after the prospective Digital Advice Investor has opened a Digital Advice Program account by executing an Investment Advisory Agreement with the Financial Institution; ● Oversee and monitor Digital Advice Investor accounts in accordance with the investment portfolios developed or approved by the Financial Institution; ● Rebalance and generate trade orders to align Digital Advice Investors with their recommended portfolio based on the rules and parameters configured and approved by SigFig’s Partners for Investors’ accounts; ● Implement tax-loss harvesting strategies in the accounts of Digital Advice Investors who opted to turn on this capability based upon preset criteria and specifications determined or approved by the Financial Institution; and ● Where agreed, evaluate, engage and perform ongoing monitoring of third party investment managers (“Model Providers”) that provide SigFig with model portfolios approved by the Financial Institution that will be recommended to Digital Advice Investors (“Model Portfolios”).
The Financial Institution sponsoring and offering its Digital Advice Program determines which services of SigFig to utilize with the Digital Advice Investors and may utilize the services of other third-party or affiliated service providers in conjunction with the Digital Advice Program. Digital Advice Investors should therefore consult the Financial Institution’s Brochure for a fuller description of the specific use of SigFig’s services and any other important information about the respective Digital Advice Program.
C. Nature of Advisory Services and Client-Imposed Restrictions SigFig provides guidance as part of portfolio-tracking services to Users based on their existing portfolio data (as provided to SigFig by the User via the accounts effectively linked onto SigFig’s User Platform) and answers to a risk profile questionnaire.
With respect to advisory and sub-advisory services, SigFig tailors such services to the Clients’ and Digital Advice Investors’ respective investment objectives and risk tolerance, as communicated to SigFig by the Clients’ and Digital Advice Investors’ or, in case of certain Digital Advice Programs, generates and implements investment recommendations based on the information and specifications provided to it by the Financial Institution.
Clients and Digital Advice Investors are responsible for updating the information provided to SigFig (and the Financial Institutions in the context of Digital Advice Programs) in the event there are changes to their investment objectives, risk tolerance or any other information provided through the risk profile questionnaire.
SigFig bases its advisory services to Clients and Digital Advice Investors on the investment objectives and restrictions set forth in the information provided thereby, applicable Investment Advisory Agreement, digital advisory services schedules and terms of use, as the case may be. In addition, in formulating the investment recommendations for Clients and Digital Advice Investors’ accounts or implementing the investment recommendations provided and communicated to SigFig by the Partner, the Financial Institutions and SigFig will seek to comply with reasonable restrictions imposed by the Clients and Digital Advice Investors, which may include the designation of securities that should not be purchased or held in the Clients’ or Digital Advice Investors’ accounts.
● If SigFig, in management of its Client accounts or in consultation with the Financial Institution (in case of Digital Advice Programs), believes that the restrictions requested by a Client or Digital Advice Investor are unreasonable or inappropriate, SigFig will notify the Client or the Financial Institution will notify the Digital Advice Investor that, unless the restrictions are modified, the account will be removed from the respective program.
● Clients and Digital Advice Investors will not be able to impose restrictions that prohibit or restrict the purchase of ETFs.
Clients and Digital Advice Investors are strongly encouraged to consider their individual circumstances, risk tolerance and needs prior to following any investment recommendation.
The Digital Advice Programs offered through SigFig’s partnerships with certain Financial Institutions may be offered as a wrap fee program for which more information can be found in the relevant Financial Institution’s Brochure.
D.Assets Under Management As of December 31, 2023, SigFig managed approximately $2,797,084,452 of Client and Digital Advice Investors’ assets on a discretionary basis. SigFig does not currently manage any assets in a non-discretionary capacity.