National Advertising Division Finds Certain Guideline 401(k) Claims Supported; Recommends Others Be Modified or Discontinued
New York, NY – January 7, 2026 – In a challenge brought by Human Interest Inc., BBB National Programs’ National Advertising Division reviewed advertising claims made by Guideline, Inc. for its 401(k) plans, finding that certain claims related to ease of use, time savings, customer support, and expertise were supported, while recommending that other fee and comparative claims be modified or discontinued.
Guideline is a 401(k) provider that offers retirement savings plans designed to help small and medium-sized businesses manage plans for their employees. Human Interest is also an online employee retirement benefits provider that similarly specializes in 401(k) plans for small and medium-sized businesses. In November 2025, Guideline was acquired by Gusto.
At issue for the National Advertising Division (NAD) was a series of claims on Guideline’s website and on its blog, including comparative fee savings, ease of platform use, customer satisfaction, and other performance claims.
Regarding the claim “4x Lower Asset Fees” than Human Interest, NAD concluded that this claim conveys the broad message that customers of all types will realize significant savings by choosing Guideline over Human Interest, but due to different pricing models is not an “apples-to-apples” comparison.
Accordingly, NAD recommended that Guideline discontinue the challenged fee claims.
NAD found that Guideline had a reasonable basis for the claim when made in a monadic context, but recommended Guideline discontinue the claim in a comparative context.
NAD found that Guideline provided reliable support for each of these claims, citing customer surveys, internal workflow analysis, and service response data. Accordingly, NAD determined that Guideline had a reasonable basis for the time savings representations.
NAD also found that the claim “Your new 401(k) could be 100% covered” was substantiated, as it was presented with appropriate disclosures that the claim did not convey investment advice.
During the proceeding, Guideline modified these claims to “More QuickBooks Online Payroll customers use Guideline” and “2x as many businesses use Guideline instead of Human Interest.” NAD determined that the modified claims were supported.
During the inquiry, Guideline informed NAD that they were permanently discontinuing certain claims. Guideline also indicated that it would modify the comparative claim “Easier to Use” to “Easy to Use.” NAD determined Guideline had a reasonable basis for the modified claim. Therefore, NAD did not review the claims on their merits and will treat the discontinued and modified claims, for compliance purposes, as though NAD recommended they be discontinued and Guideline agreed to comply.
In its advertiser statement, Guideline stated it will “comply with NAD’s decision” though it “respectfully disagrees that any reasonable consumers could be confused by its fee savings claims.”
All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.
Guideline is a 401(k) provider that offers retirement savings plans designed to help small and medium-sized businesses manage plans for their employees. Human Interest is also an online employee retirement benefits provider that similarly specializes in 401(k) plans for small and medium-sized businesses. In November 2025, Guideline was acquired by Gusto.
At issue for the National Advertising Division (NAD) was a series of claims on Guideline’s website and on its blog, including comparative fee savings, ease of platform use, customer satisfaction, and other performance claims.
Fee Claims
NAD found Guideline’s “Up to 6x less in fees” claim to be a broad claim that communicates the message that customers will pay much less in fees versus all competitors, regardless of the fee structure. NAD concluded that this claim is not supported by evidence submitted by Guideline. NAD also found the claim “The estimated total cost for our managed portfolios can be under 0.15%,” to be a message of broad applicability not supported by the record.Regarding the claim “4x Lower Asset Fees” than Human Interest, NAD concluded that this claim conveys the broad message that customers of all types will realize significant savings by choosing Guideline over Human Interest, but due to different pricing models is not an “apples-to-apples” comparison.
Accordingly, NAD recommended that Guideline discontinue the challenged fee claims.
Customer Satisfaction Claim
Human Interest challenged the claim that Guideline’s “Annual plan sponsor customer satisfaction score (CSAT) is 93%.” Guideline’s support for the claim was a survey conducted through AskNicely, a third-party customer experience measurement platform. NAD found that Guideline had a reasonable basis for the claim in a monadic context, referring to its own customers’ experiences with live customer support. To the extent, however, that the 93% customer satisfaction claim appears in a comparative context, NAD found that the AskNicely survey was not sufficient support.NAD found that Guideline had a reasonable basis for the claim when made in a monadic context, but recommended Guideline discontinue the claim in a comparative context.
Time Savings Claims
NAD considered several time savings claims made by Guideline, including “9 out of 10 customers have saved time on 401(k) admin since switching to Guideline,” “Meet the state requirement mandate in ~9 minutes,” “Manage your team’s 401(k) in as little as 30 minutes a month,” and “We average a 4 business hour response time.”NAD found that Guideline provided reliable support for each of these claims, citing customer surveys, internal workflow analysis, and service response data. Accordingly, NAD determined that Guideline had a reasonable basis for the time savings representations.
Expertise Claims
NAD reviewed Guideline’s claim that customers have access to “Expert Built Portfolios.” NAD found that the claim did not reasonably convey that Guideline itself provides investment advice, and that Guideline Investments, LLC employs a team of qualified experts. NAD determined that the claim was supported.NAD also found that the claim “Your new 401(k) could be 100% covered” was substantiated, as it was presented with appropriate disclosures that the claim did not convey investment advice.
Popularity Claims
Human Interest challenged Guideline’s popularity claims, including “See why more QuickBooks clients choose Guideline 401(k) than any other integrated 401(k) provider” and “Twice as many businesses choose Guideline than Human Interest.”During the proceeding, Guideline modified these claims to “More QuickBooks Online Payroll customers use Guideline” and “2x as many businesses use Guideline instead of Human Interest.” NAD determined that the modified claims were supported.
Blog Post Claim
NAD reviewed a blog post authored by Guideline’s CEO stating, “Research shows that one in two employees would turn down a job offer from a company that does not offer a retirement benefit.” NAD found that the claim was substantiated, based on reliable third-party survey data.During the inquiry, Guideline informed NAD that they were permanently discontinuing certain claims. Guideline also indicated that it would modify the comparative claim “Easier to Use” to “Easy to Use.” NAD determined Guideline had a reasonable basis for the modified claim. Therefore, NAD did not review the claims on their merits and will treat the discontinued and modified claims, for compliance purposes, as though NAD recommended they be discontinued and Guideline agreed to comply.
In its advertiser statement, Guideline stated it will “comply with NAD’s decision” though it “respectfully disagrees that any reasonable consumers could be confused by its fee savings claims.”
All BBB National Programs case decision summaries can be found in the case decision library. For the full text of NAD, NARB, and CARU decisions, subscribe to the online archive. Per NAD/NARB Procedures, this release may not be used for promotional purposes.