National Advertising Division Finds Certain Vestwell “Annual Recurring Revenue” Disclosures Sufficient; Recommends Modification to Disclose Methodology
New York, NY – May 18, 2026 – In a Fast-Track SWIFT challenge brought by Human Interest Inc., BBB National Programs’ National Advertising Division found that Vestwell Holdings Inc. provided sufficient information regarding its recent acquisition of Accrue 401k, but recommended that certain claims regarding its Annual Recurring Revenue (ARR) be modified to include a clear and conspicuous disclosure of the methodology used to calculate that figure.
Fast-Track SWIFT is an expedited process for single-issue advertising cases reviewed by the National Advertising Division (NAD).
Vestwell and Human Interest compete in the workplace savings market, offering 401(k) plans and other products to businesses and their employees. At issue for NAD was whether Vestwell’s ARR claims in its press release require disclosure of the methodology used to calculate ARR and the extent to which the reported ARR includes ARR from a recent acquisition.
NAD found that, in the context of the press release, it was not necessary to require any specific disclosure of the extent to which the ARR figure is attributable to the recent acquisition. The press release includes a reference to the Accrue acquisition, with a bullet point stating “Nearly 30,000 plans added through the Accrue 401k acquisition,” a hyperlink to the press release announcing the acquisition. Thus, there was sufficient information in the press release to inform consumers that the reported ARR figure is inclusive of growth through acquisition.
However, regarding the ARR claims, NAD determined that the press release may be relied upon by potential customers to compare providers, as with any other advertising format, and that a succinct disclosure describing the method used to calculate ARR allows those potential customers to assess the claimed revenues for comparative purposes.
Therefore, NAD recommended Vestwell modify the claims “The Series E doubles Vestwell’s valuation as the company surpasses 2 million active savers, $50 billion in assets, and $200 million in annual recurring revenue,” and “Vestwell has surpassed $200 million in annual recurring revenue and continues to grow profitability” to include a clear and conspicuous disclosure of the methodology used to calculate the reported ARR.
In its advertiser statement, Vestwell stated that though it disagrees with certain elements of the decision, it will “comply with NAD’s recommendations.”
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. This press release shall not be used for advertising or promotional purposes.
Fast-Track SWIFT is an expedited process for single-issue advertising cases reviewed by the National Advertising Division (NAD).
Vestwell and Human Interest compete in the workplace savings market, offering 401(k) plans and other products to businesses and their employees. At issue for NAD was whether Vestwell’s ARR claims in its press release require disclosure of the methodology used to calculate ARR and the extent to which the reported ARR includes ARR from a recent acquisition.
NAD found that, in the context of the press release, it was not necessary to require any specific disclosure of the extent to which the ARR figure is attributable to the recent acquisition. The press release includes a reference to the Accrue acquisition, with a bullet point stating “Nearly 30,000 plans added through the Accrue 401k acquisition,” a hyperlink to the press release announcing the acquisition. Thus, there was sufficient information in the press release to inform consumers that the reported ARR figure is inclusive of growth through acquisition.
However, regarding the ARR claims, NAD determined that the press release may be relied upon by potential customers to compare providers, as with any other advertising format, and that a succinct disclosure describing the method used to calculate ARR allows those potential customers to assess the claimed revenues for comparative purposes.
Therefore, NAD recommended Vestwell modify the claims “The Series E doubles Vestwell’s valuation as the company surpasses 2 million active savers, $50 billion in assets, and $200 million in annual recurring revenue,” and “Vestwell has surpassed $200 million in annual recurring revenue and continues to grow profitability” to include a clear and conspicuous disclosure of the methodology used to calculate the reported ARR.
In its advertiser statement, Vestwell stated that though it disagrees with certain elements of the decision, it will “comply with NAD’s recommendations.”
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. This press release shall not be used for advertising or promotional purposes.