On June 16-17, 2025, Coinbase Advisors, LLC officially entered the financial landscape as an SEC-registered Investment Adviser and a CFTC/NFA-registered Commodity Trading Adviser. The firm’s offering, Coinbase Advisor, provides guidance across digital assets, equities, and derivatives to US Coinbase One premium subscribers. It is, by design, a non-discretionary AI-powered advisory. The firm explicitly states in its Form CRS that it does not manage client accounts, requiring the user to confirm every trade.
The core tension is simple to state but difficult to resolve: Can a machine satisfy the rigorous requirements of fiduciary duty while simultaneously disclaiming its own reliability? Under the Investment Advisers Act of 1940, an adviser is bound by a duty of care and a duty of loyalty. Yet, Coinbase includes a disclaimer stating: “Outputs are limited and may be inaccurate or incomplete and should not be your only source of information.”
The industry is not moving in lockstep. Robinhood has adopted a markedly different strategy. Rather than deploying an autonomous agent, Robinhood positions its AI as a tool for human Registered Investment Advisers. Jordan Baldwin, head of Robinhood RIA, has been explicit: “RIAs aren’t allowed to hire an AI agent to manage money for customers at this point in time, because it doesn’t suit the rules currently.”
The FINRA 2026 Annual Regulatory Oversight Report identified autonomous AI agents as a top investor risk, specifically citing concerns over autonomy, scope creep, auditability, and misaligned reward functions. Whether the existing 1940s-era statutes can accommodate an AI agent that disclaims its own accuracy remains to be seen. The technology has outpaced the case law, leaving both firms and investors to navigate a landscape defined by uncertainty.