Owning Custody Enables Faster Rollovers

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Kevin Busque and Steven Wu, CEO and CFO of Guideline, on hitting $120M ARR

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Soon, we won't have to rely on a third-party custodian, and we'll be able to control that experience directly.
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Owning custody turns Guideline from a software layer sitting on top of retirement accounts into the company that can actually move the money, which is where the biggest service failures still happen. Guideline already controls recordkeeping and can move assets quickly inside its own system, but external rollovers and plan conversions still get stuck on mailed checks, bad upstream data, and custodian handoffs. Bringing custody in house closes one of the last major gaps in the product.

  • Today, Guideline is already the record keeper, but it has said it is not structured to be both record keeper and custodian, so it uses a partner custodian and covers that custodian's transaction fees with its 0.08% asset fee. That means the hard customer problems around distributions and rollovers still depend on another party's rails.
  • The payoff is most obvious in rollovers. Guideline has said a Guideline to Guideline rollover can happen almost instantly because both sides sit inside its own trust and recordkeeping system, while conversions from outside providers can drag on for months because data quality is poor and the money path is outside its control.
  • This also matters competitively. Digital 401(k) providers win by replacing the old chain of custodians, TPAs, and record keepers with one cleaner workflow for SMBs. Human Interest follows the same software led playbook, but Guideline has long positioned owning more of the stack as the way to lower fees, reduce support burden, and make the participant experience feel more like moving money in a modern fintech app.

The next phase of the market is full stack retirement infrastructure. The winners will not just sell a cheaper plan to employers, they will make rollovers, IRA transfers, distributions, and adjacent products like HSAs and SEPs move through one controlled system. That is the path from a sticky SMB 401(k) product to a broader retirement account platform.