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Finance · Multi-product consumer-finance platform · What does “free” cost?

Robinhood Markets, Inc.Brokerage · Cash · Gold · Retirement · Crypto · Transfers · Menlo Park, California

Evidence reviewed through 1 October 2026 · Special Investigation · No numerical score

What “free” cost in 2016–2019 was a regulator’s finding.What it costs today is a set of disclosed conditions — the clearest of them on cash.

Robinhood’s zero-commission offering benefited retail investors, and its current visible prices can be highly competitive. A historical SEC finding quantified a different price, paid through poor execution on certain orders in 2016–2019. In the current product, the defensible finding is about conditions attached to value: Robinhood offered a non-Gold cash yield, reduced it, and ended the self-directed non-Gold sweep, while reserving its published high-yield cash program for Gold subscribers. Other documented conditions govern the IRA match, outgoing transfers and crypto routing. This page describes each one precisely, credits what customers receive, and never presents the historical conduct as current behaviour.

1.5%Non-Gold sweep APY · 15 Nov 2023
0.01%Non-Gold APY · effective 8 May 2024
EndedNon-Gold self-directed sweep · Nov 2025
3.6%Gold & managed Strategies · 17 Sep 2026
● Estimated read 20 min

Historical conduct periods 2015–2021

Regulator findings about dated conduct, settled without admission.

The SEC found that Robinhood left payment for order flow out of certain retail explanations of how it made money from 2015 to September 2018, and that on certain orders from October 2016 to June 2019 customers lost about $34.1 million in price improvement after allowing for the roughly $5 commissions they would have paid elsewhere. FINRA separately found defective displays, options-approval failures and the March 2020 outage.

These are findings about past periods. None of them is used on this page as evidence of how Robinhood operates today.

PFOF omitted · 2015–2018 Execution · 2016–2019 Displays & approvals Outage · Mar 2020

Current product terms reviewed 1 Oct 2026

Competitive visible prices, with disclosed conditions attached to value.

Self-directed customers now reach Robinhood’s published high-yield cash rate only through Gold, after the non-Gold self-directed sweep ended in November 2025. Managed Robinhood Strategies accounts are the exception. Separate published conditions govern the IRA match, a $100 outgoing transfer fee and default crypto routing.

Nothing in this column is a finding of deception. The August Rule 605 reports show mixed execution measures in one shared order category; they do not establish an overall ranking.

Cash yield via Gold Strategies exception IRA-match conditions $100 exit fee

The changeover is dated, and every item on this page carries its own date. CHI does not let later remediation erase conduct a regulator found. It also does not let that conduct be reported as though it were still happening. The historical findings appear lower down, in their own clearly marked section.

Current finding · product terms reviewed 1 October 2026

Today, in three facts.

The current finding rests on Robinhood’s own dated statements. Read the three together: the rule for self-directed Gold customers, the change for self-directed non-Gold customers, and the managed-account exception.

Fact 1 · November 2025

The non-Gold self-directed cash sweep ended

Company statementRobinhood reported that its Non-Gold Cash Sweep program ended in November 2025 and that approximately $700 million moved to customer free-credit balances. That figure is a balance that moved, not a customer loss. [S4]

Fact 2 · 17 September 2026

Gold is the route to the published rate for self-directed accounts

Company statementThe High-Yield Cash Program pays 3.6% APY on eligible cash in self-directed taxable investing accounts of Gold subscribers. Gold costs $5 a month or $50 a year. Robinhood says the rate can change at any time. [S5] [S29]

Fact 3 · 17 September 2026

Managed Strategies accounts earn it without Gold

Company statementAccounts managed by Robinhood Strategies get the same 3.6% APY on eligible cash swept to program banks in the Cash Sweep Program, whether or not the owner subscribes to Gold. In Robinhood’s investor tables, the balances still labelled “Non-Gold Cash Sweep” are these managed-adviser (RIA) balances. [S5] [S4]

Rate and cash location, by customer segmentAs of 17 Sep 2026
Self-directed · Gold subscriber

Eligible

3.6% Gold required
Rate
3.6% base APY on eligible cash in self-directed taxable accounts (individual, joint, custodial, trust). The rate is the same wherever the eligible cash sits. [S5]
Where the cash sits
Eligible uninvested cash up to and including $10,000 (counted in aggregate across multiple individual investing accounts) stays at Robinhood as free-credit balances in the Brokerage-Held Cash Program, and earns interest there. Amounts above $10,000 go to the Cash Sweep Program and are swept to banks. Cash held as options collateral can also earn the rate. [S5] [S28]
Price
Gold costs $5/month or $50/year. [S29]
Self-directed · no Gold

Sweep ended November 2025

No interest Outside High-Yield Cash
Return
Robinhood’s Customer Agreement §27 says free-credit balances outside the High-Yield Cash Program do not earn interest. The program is offered to self-directed Gold subscribers; managed Strategies accounts are the exception. This is the current term, not the historical 0.01% APY. [S15] [S5]
Where the cash sits
At Robinhood as free-credit balances. When the non-Gold sweep ended, about $700m moved there. That figure is a balance that moved, not a loss. [S4]
Managed · Robinhood Strategies

Eligible without Gold

3.6% Exception to the Gold rule
Rate
3.6% APY, whether or not the owner subscribes to Gold. Enrollment is automatic for managed accounts. [S5] [S28]
Where the cash sits
The stated rate applies to eligible cash swept to program banks in the Cash Sweep Program. These are the balances still reported as “Non-Gold Cash Sweep”. [S4]
In text: the published 3.6% APY as of 17 September 2026 applies to two groups. The first is eligible cash of self-directed Gold subscribers: up to $10,000 held at Robinhood as interest-earning free-credit balances, anything above that swept to banks, and eligible options collateral. The second is eligible swept cash in managed Strategies accounts, with no Gold needed. The rate and the location of the cash are separate: brokerage-held does not mean unpaid. Under the Customer Agreement reviewed 1 October, self-directed customers without Gold hold free-credit balances that do not earn interest outside the High-Yield Cash Program. Sources: High-Yield Cash Program page [S5]; High-Yield Cash Program interest-rate page [S28]; Customer Agreement §27 [S15]; Gold billing page [S29]; November 2025 operating data [S4]. Terms checked 1 October 2026.

The cash transition · four dated milestones

A published non-Gold yield, reduced, then ended.

Each row relies only on what the dated source says. Taken together they show one transition, 2023–2025, for self-directed customers without Gold. It is one fact pattern, and CHI counts it once.

15 Nov 2023Robinhood newsroom 1.5%Non-Gold APY

Company statementRobinhood said enrolled non-Gold customers could receive 1.5% APY on swept brokerage cash, while Gold members were offered 5.0% APY.

Source: [S1] · applies to eligible, enrolled brokerage cash on that date
8 May 2024effective; disclosed 21 May 2024 0.01%Non-Gold APY

Company statementA Robinhood post dated 21 May 2024 put the non-Gold APY at 0.01% effective 8 May 2024. The same figure appeared again in a 25 July 2024 Robinhood post; when it was last published is not known.

CHI analysisThe federal funds target range was 5.25%–5.50% throughout, from before November 2023 until September 2024. The non-Gold cut did not follow a change in the Fed’s policy rate.

Sources: [S2] [S3] [S27] · a historical dated figure, not the October 2026 position
November 2025reported 10 Dec 2025 EndedNon-Gold self-directed sweep

Company statementRobinhood’s operating-data release says it ended the Non-Gold Cash Sweep program in November 2025, moving approximately $700 million to customer free-credit balances. It separately says RIA cash sweep balances remained in Non-Gold Cash Sweep.

Source: [S4] · ~$700m is a balance moved, not a loss
17 Sep 2026current help page 3.6%Gold & Strategies

Company statementThe High-Yield Cash Program pays 3.6% APY to eligible self-directed Gold accounts. It also pays 3.6% on eligible cash swept to program banks in accounts managed by Robinhood Strategies, which do not need Gold. Under the current Customer Agreement §27, free-credit balances outside the program do not earn interest. [S15]

Sources: [S5] [S15] · rate dated 17 Sep; agreement checked 1 Oct 2026

What the timeline establishes

  • Self-directed customers without Gold were offered a published cash yield (1.5% on 15 November 2023).
  • For existing enrolled customers, that yield was cut to 0.01%, effective 8 May 2024, while the Fed’s target range stayed the same.
  • The self-directed non-Gold sweep then ended in November 2025, and about $700m moved to free-credit balances.
  • Since then, self-directed customers reach the published high-yield cash rate through Gold. Managed Strategies accounts are the stated exception.

What it does not establish

  • Why the program ended, or what notice customers received.
  • How many customers were affected, or what any individual earned after the change.
  • Any loss. The ~$700m is a balance transfer. CHI does not estimate damage from it.
  • That the $700m balance moved represents customer loss, or that every cash product at Robinhood has the same return. Neither claim is made.

Litigation · unverified termsThe cash-sweep class action. Plaintiffs’ counsel reports a class-wide settlement in principle. A joint court filing of 8 September said material terms were still being finalized and requested an 8 October deadline to present an agreement for preliminary approval. [S24] [S39] As checked 1 October, CHI has not verified an agreement, amount, class period, remedy, admission or court approval. The allegations are not findings, and CHI does not suggest the settlement caused the November 2025 change.

On where cash sits and how it is protected. Where cash is held and what it earns are separate questions. Free-credit balances stay with the broker. That includes a self-directed Gold subscriber’s eligible cash up to $10,000, which earns the program rate in the Brokerage-Held Cash Program, and the balances of self-directed customers without Gold, which under the Customer Agreement do not earn interest outside the program. Swept balances are held at program banks. The two carry different kinds of protection, with different legal triggers. [S28] [S15] CHI does not say Robinhood removed deposit protection for all customers or that brokerage-held cash is always unpaid.

What Robinhood gives customers

The value is real. It belongs in the main text, not in a footnote.

A Special Investigation that only listed conditions would misdescribe the product. What follows is the customer-favourable case, with a date and a stated boundary on every figure.

Zero commissions reduced a visible cost

Robinhood offered zero-commission stock trading before Charles Schwab announced $0 online stock and ETF commissions effective 7 October 2019. This sequence does not establish why Schwab made its decision. The SEC’s historical harm estimate is calculated after allowing for commissions of about $5 a trade, and it covers certain orders. It is not a finding that small customers as a whole were worse off. [S16] [S35]

Low published margin rates, on a dated comparison

Published ratesRobinhood’s first margin tier (up to $50,000) is 5.25%, per its fee schedule dated 16 September 2026. Fidelity’s rate for debit balances under $25,000 is 12.075%, effective 18 September 2026. On a $10,000 balance held for a year, that is roughly $525 against $1,208 before compounding and day-count differences. [S6] [S7]

One named peer on one date. This illustrates a price gap. It is not a market ranking.

The IRA match is actual money

Published termsRobinhood adds 1% to eligible IRA contributions for all customers and 3% for Gold subscribers. On a $5,000 contribution that is $50, or $150 with Gold. The conditions attached to it are set out below. They can remove the match. They do not take the customer’s own contributions or investment gains. [S8] [S9]

A crypto routing choice, with the economics disclosed

Published termsRobinhood publishes how much it receives on default market-maker crypto orders, with a worked example. In the mobile app, customers can switch supported coins to exchange routing, where Robinhood takes no rebate and published volume-based fee tiers apply. Exchange routing is not offered on classic web or to North Carolina residents. [S10] [S11]

The product range has grown

One customer can now hold brokerage, retirement, managed accounts, cash and crypto on one platform. Breadth is not proof of value, but it is part of why customers use Robinhood. CHI records it without scoring it.

Peer defaults are mixed

CHI analysisSome large brokers pay very little on default sweep cash. Others offer high-yield cash options without a subscription. Robinhood’s Gold program is opt-in, and customers can use other cash products or move. CHI does not put a number on the cost of switching, because no evidence for one was established.

When Gold pays for itself — with the assumptions shown

Gold’s annual plan costs $50, per Robinhood’s billing page. [S29] For cash alone, that fee is covered when the extra interest earned beats it: break-even balance = $50 ÷ (3.6% − the rate the customer could earn elsewhere).

Customer’s alternative rate on the same cashAverage idle balance needed to cover $50 a year
0%≈ $1,389
1.0%≈ $1,923
2.0%≈ $3,125
3.0%≈ $8,333

Assumptions. Annual plan at $50, as charged at the start of each billing cycle [S29]. Gold APY held at 3.6% for twelve months, although Robinhood can change it at any time. Balance averaged over the year, before tax, eligible self-directed taxable accounts only. The same 3.6% applies whether the cash is brokerage-held or swept, so the $10,000 threshold does not change the arithmetic. Other Gold benefits and costs are ignored. The “alternative rate” is whatever the customer could earn elsewhere; the 0% row is also the current contractual interest treatment of free-credit balances outside the High-Yield Cash Program under Customer Agreement §27 [S15]. Not every customer without Gold would keep the same idle balance, so this shows when Gold can pay for itself, not what any customer lost.

Current conditions beneath the headline

Each condition, stated precisely, dated, and limited to what the source says.

These are published, lawful terms. CHI records where the conditions sit. None of the items below is a finding of concealment, and none comes with a loss calculation.

High-yield cash → GoldSelf-directed accounts · as of 17 Sep 2026

3.6% APY for eligible self-directed Gold accounts. Managed Strategies accounts earn it without Gold. The self-directed non-Gold sweep ended in November 2025. [S5] [S4]

Customer Agreement §27 says free-credit balances outside the High-Yield Cash Program do not earn interest. This applies to self-directed non-Gold cash held there, while eligible Gold brokerage-held cash inside the program earns interest. [S15]

Not claimed: a 0.01% current rate, any loss calculation, or that all brokerage-held cash is unpaid.

IRA match → one-year Gold and five-year funds conditionsPublished terms · checked 1 Oct 2026

A subscriber who cancels Gold within a year of receiving a Gold match loses two-thirds of that 3% match. The remaining third, like the standard 1% match, stays subject to a five-year condition: if matched principal leaves early, a proportional early-removal fee applies, subject to the exceptions in the terms. The fee schedule refers to the match terms for how this fee is calculated. It does not state a fixed amount. [S9] [S8] [S6]

Not claimed: that principal or gains are forfeited, or that any change to this fee has been announced. The 15 October 2026 date on the fee schedule belongs to a professional-options fee.

Gold-linked productsProduct structure

Gold is also the membership tied to Robinhood’s Gold-branded financial products. CHI records the linkage. Current eligibility and rate terms for those products were not re-verified for this page, so no figure is printed.

Not claimed: any specific cancellation sequence or benefit list. Neither has been observed in a live account.

$100 outgoing ACATS transferRHF fee schedule · Sep 2026

The Robinhood Financial fee schedule lists a $100 fee for an outgoing ACATS transfer. [S6] Pattern: Exit Resistance, meaning a price on leaving that the customer does not pay to join.

Not claimed: how the fee applies to partial as opposed to full transfers. The current schedule does not make that distinction, so this page does not either.

Crypto default routingSince 15 Jun 2026

Company statementFor default market-maker routing, Robinhood says it receives $0.95 per $100 of executed crypto notional since 15 June 2026. Its example: on a $100 buy with a 0.96% spread, Robinhood receives $0.95 of the $0.96. In the app, exchange routing is available instead, with no rebate and published fee tiers. [S10] [S11]

Not claimed: that $0.95 is a measured loss on every customer trade, or any fixed one-way or round-trip customer cost. The rebate is revenue to Robinhood within a spread that varies with quotes and market movement. Rebates before June 2026 have not been established, so CHI makes no claim that the take rate rose.

Dispute resolution (brokerage)Customer Agreement §39 · checked 1 Oct 2026

The Robinhood Financial / Robinhood Securities Customer Agreement sends covered disputes to FINRA arbitration. Its §39.C keeps a putative class claim already pending in court out of arbitration until class certification is denied, the class is decertified, or the customer is excluded. [S15]

Not claimed: that brokerage customers waive all class actions. The separate crypto customer agreement has its own terms and is not assessed here.

Event contracts — pricing omittedSource conflict, unresolved

Robinhood’s event-contract help page and a 4 June 2026 release describe a commission cap of one cent per contract. Its derivatives fee schedule prints the commission formula without that cap. Exchange charges are additional. [S12] [S14] [S13]

Omitted until Robinhood reconciles the sources: any event-contract fee calculation.

Current equity execution — narrow comparisonAugust 2026 Rule 605 summaries · checked 1 Oct

The first amended monthly summaries are published. For S&P 500 market orders of $1,000–$5,000, Robinhood reports faster execution; Fidelity and Schwab report more price improvement and lower average effective spread. These are one matched reporting category, not identical orders or an overall result. [S30] [S31] [S32] [S33]

Reporting entityShares with price improvementShare-weighted average price improvementAverage effective spreadShare-weighted execution speed
Robinhood Financial (CRFN)88.84%0.0257%0.0136%160 ms
Robinhood Securities (HOOD)88.84%0.0258%0.0137%160 ms
Fidelity (FIBS)95.25%0.0383%−0.0060%430 ms
Schwab (CHAS)97.09%0.0316%0.0052%3,946 ms

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Not claimed: an overall ranking, a measured customer loss, or four independent customer populations. CRFN and HOOD are related Robinhood reporting entities and must not be added together. Order and stock mixes differ even inside this category; the summary does not control for them. The SEC defines these share-weighted measures and covered-order categories. [S34]

Historical findings · conduct periods 2015–2021

What regulators found about the earlier product.

Historical record Each finding carries its own conduct period. The date an order was issued is not the date of the conduct. Nothing in this section describes the current product.
Settled regulator finding Without admitting or denying

SEC order 33-10906 · issued 17 December 2020 · conduct 2015–June 2019

01

Revenue explanations. The SEC found that from 2015 to September 2018 certain Robinhood retail communications left payment for order flow out of its explanations of how it made money. The order also records an instruction to customer-support staff to avoid the subject. Robinhood’s SEC-required disclosures did mention the payments. (¶3)

02

The trade-off. The SEC found that Robinhood offered to accept less price improvement for its customers in exchange for higher payments for order flow. (¶23)

03

The public claim. Robinhood publicly said its execution quality matched or beat its competitors’, while its own internal analysis found otherwise. The claim was removed in June 2019. (¶¶37, 39)

04

The quantified harm. The SEC estimated that certain orders from October 2016 to June 2019 lost about $34.1 million in price improvement, after deducting the roughly $5 commissions customers would have paid elsewhere. It found the shortfall concentrated in larger orders. Civil penalty: $65 million. (¶¶40, 42)

Keep the characterisation precise. Robinhood settled without admitting or denying the findings. The $34.1m is the SEC’s estimate for certain orders in a past period. It is not a measure of harm to every customer, and it says nothing about execution quality today. [S16] [S17]

Settled regulator finding Consented without admitting or denying

FINRA AWC · 30 June 2021 · conduct 2016–early 2021

01

Options approvals (historical example). In one example, a 19-year-old applicant was rejected for Level 3 options, reapplied minutes later with changed answers, and was approved in the same minute. This describes the approval process in that period. It is not evidence of today’s application flow, which CHI has not observed.

02

A doubled balance. FINRA records that one customer, a 20-year-old, was shown a negative cash balance of −$730,165.72 when the actual figure was −$365,530.60. The order records that he took his own life in June 2020. CHI notes this once. One case does not establish a statistical pattern.

03

The outage. On 2–3 March 2020 Robinhood’s website and apps went down, and no customer could access their account during a period of historic market volatility.

04

Sanction. A $57 million fine and about $12.6 million in restitution, covering options-spread losses, erroneous margin calls and outage losses.

Source: FINRA AWC, 30 June 2021 [S18]. Robinhood announced in October 2021 that customers could request 24/7 phone callbacks in its app [S36]. This describes the launch, not current support hours.

January 2021 — not scored, and not treated as present conduct

On 28 January 2021, facing clearing-house deposit requirements, Robinhood restricted purchases of a set of volatile securities. SEC staff later described how those clearing deposit requirements shaped broker restrictions that week. [S19] Customer litigation over the restrictions has run on several tracks, and no merits adjudication of the customers’ claims is relied on here. CHI does not score this episode. It does not quote internal communications from that week that it has not verified against the primary record, and it does not suggest the episode recurs.

Principal orders, by order date

AuthorityOrder dateSubjectResolutionSanction
FINRA19 Dec 2019Review of execution quality (2016–17 conduct)Settled, no admission$1.25m
SEC17 Dec 2020PFOF communications and execution (2015–Jun 2019)Settled, no admission$65m
FINRA30 Jun 2021Displays, options approvals, March 2020 outageSettled, no admission$57m + ~$12.6m restitution
SEC13 Jan 2025Books-and-records, reporting and supervisory matters across two broker-dealers (earlier conduct periods)Settled$45m combined
FINRA7 Mar 2025AML, supervisory and disclosure violations (earlier conduct periods)Settled, no admission$26m + $3.75m restitution

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Sources: [S16] [S18] [S21] [S22] [S37] [S38]. The December 2019 FINRA $1.25m entry is corroborated by Robinhood’s own SEC filing. This list is not exhaustive. A targeted check on 25 September 2026 found no newer general brokerage enforcement finding that supersedes it. That was a spot check, not a full docket audit. Robinhood’s Q2 2026 filing discloses pending investigations [S23]. Pending matters are not findings.

Counterevidence and falsification

The strongest objections, answered directly.

CHI tests each finding against the best case for the company. Where an objection succeeds, the finding narrows.

“The cash cut simply followed interest rates.”

The non-Gold rate fell from 1.5% to 0.01% between November 2023 and May 2024. Over that period the Fed’s target range did not move. The objection does not explain this event. It may explain later changes to the Gold rate, which this page does not score.

“$700 million was taken from customers.”

No. Robinhood reports that about $700m of balances moved to free-credit balances. That is a transfer of balances, not a measure of loss. CHI publishes no loss estimate.

“Non-Gold customers now earn nothing.”

For self-directed free-credit balances outside the High-Yield Cash Program, the current Customer Agreement §27 says they do not earn interest. That does not apply to eligible managed Strategies cash or interest-earning brokerage-held cash inside the Gold program. [S15] [S5]

“Everything is gated behind Gold.”

No. Managed Robinhood Strategies accounts earn the published 3.6% on eligible swept cash without Gold. Zero-commission stock trading and the baseline 1% IRA match do not require Gold either.

“The SEC case proves ‘free’ was a lie.”

No. It is a settled finding, without admission, about certain orders in 2016–2019, and its harm figure is calculated after the commissions customers saved. It proves a historical price on those orders. It says nothing about 2026.

“Execution is worse at Robinhood today.”

The August 2026 Rule 605 summaries give a mixed result in one shared S&P 500 market-order category: Robinhood reports faster execution, while Fidelity and Schwab report more price improvement and lower effective spread. Order mix differs, so CHI does not rank overall execution or infer customer harm from this comparison. [S30] [S31] [S32] [S33]

“Gold is a trap.”

The evidence does not support that. Gold is opt-in, costs $50 a year on the annual plan [S29], and pays for itself on cash alone at modest balances (see the break-even table). Customers can use other cash products or move. What CHI records is where the condition sits, not that customers are trapped.

“Studies show today’s customers are harmed.”

No qualifying study of Robinhood customer outcomes after remediation was verified in the sources CHI inspected by 25 September 2026. Some papers published after 2020 discuss Robinhood users, but the periods their data cover were not established. [S25] [S26]

CHI signal results

Four signals, and one cash event counted once.

CHI’s Special Investigations test a fixed set of signal definitions. These results were reviewed through 1 October 2026. No score follows from them, and no new pattern is proposed.

SP001

Unmonetized access / entitlement monetization

SUPPORTED

On one cash-sweep transition: a published non-Gold yield in 2023, cut in May 2024, and the self-directed non-Gold sweep ended in November 2025, leaving Gold as the self-directed route to the published rate. Managed Strategies accounts are excepted.

Requires a real transition, for existing customers, from included to gated. New premium features do not count.

SP002

Existing-customer yield optimization

SUPPORTED, NARROW

Anchored on the reduction for existing customers effective 8 May 2024. This is the same cash event as SP001, and it is not counted as a second independent event. Other repricing needs its own dated evidence and remains secondary.

More revenue from existing customers without proportionate added value. Revenue growth alone is not proof.

SP003

Legacy product deprioritization

WEAKLY SUPPORTED

None of the other legacy-product candidates showed a large, proven customer consequence. The cash transition is not counted here again to strengthen this signal.

Retiring or downgrading a legacy product or feature with a customer consequence. Routine iteration does not count.

SP004

Pass-through of external cost pressure

WEAKLY SUPPORTED

Robinhood attributes some customer-facing charges to external costs, but nothing shows material cost recovery. No external cost has been linked to the cash change.

The company must explicitly link an external cost to a customer-economic action. CHI never infers the link.

Not adopted. Earlier CHI work on Robinhood floated “Yield Gating” as a possible lexicon entry. It is not adopted, and it does not appear in the Lexicon. One specimen is not a pattern.

Method and limitations

What this investigation did not establish.

Each item below is left out of the findings rather than guessed. If new evidence settles one, the page changes.

Individual cash outcomesCustomer Agreement §27 specifies no interest outside the High-Yield Cash Program; CHI has not measured each customer’s balance, alternatives or lost interest.
Cash-sweep settlement termsReported by plaintiffs’ counsel as a settlement in principle. Agreement, remedy, amount, class period and approval are not verified.
Current execution qualityAugust 2026 Rule 605 summaries permit a narrow category comparison. They do not control for order and stock mix, establish an overall ranking or measure customer harm.
Live-app behaviourNo authenticated US account was used. Screens, prompts, application flows and cancellation sequences were not observed and are not described.
Crypto spread outcomesNo independent measurement of current crypto execution, and no rebate history before June 2026.
Event-contract pricingCompany sources conflict on a per-contract cap. Pricing is omitted until they are reconciled.

Source handling. Company statements, regulatory orders and agreements are paraphrased with source links and paragraph or section references. No passage is quoted verbatim from those documents.

Reserved

Robinhood ↔ Revolut

A head-to-head with Revolut has not been written. The Revolut investigation is published separately. The rules below are recorded now so that the comparison, when written, is built correctly rather than conveniently.

Binding non-comparability rules, carried forward

  • Foreign exchange is not a clean comparison. It is Revolut’s founding product and essentially absent from Robinhood’s US offering. It must be marked not applicable for Robinhood, never given a clean sheet.
  • Order-flow payment differs by jurisdiction, not by virtue. Revolut’s explicit commissions are partly a regulatory consequence. Robinhood’s model is partly a US permission.
  • Restriction volumes cannot be compared raw. A payments bank and a brokerage carry different obligations. Compare notice, explanation and recourse, not counts.
  • Cash yield must be compared by customer segment and date. That means subscriber against non-subscriber and self-directed against managed, each on a stated date. A headline rate alone flatters whichever firm is being described.

Sources

Primary sources, with the date each was checked.

“Fetched” and “checked” record the date CHI examined each source. The August Rule 605 summaries and the current Customer Agreement were reviewed on 1 October; other sources retain their earlier check dates. Rates and terms can change after these dates.

  1. Robinhood newsroom — Gold 5.0% APY announcement (states non-Gold 1.5%), 15 Nov 2023. Fetched 25 Sep; rechecked 1 Oct 2026.
  2. Robinhood newsroom — new margin rates (non-Gold APY effective 8 May 2024), 21 May 2024. Fetched 25 Sep; rechecked 1 Oct 2026.
  3. Robinhood newsroom — joint investing accounts (repeats 0.01% disclosure), 25 Jul 2024. Checked 25 Sep 2026.
  4. Robinhood Markets — November 2025 operating data release, 10 Dec 2025. Fetched 25 Sep; rechecked 1 Oct 2026.
  5. Robinhood support — High-Yield Cash Program (eligibility; Cash Sweep, Brokerage-Held Cash and options collateral; Strategies), rate as of 17 Sep 2026. Fetched 25 Sep; checked 1 Oct 2026.
  6. Robinhood Financial fee schedule (PDF), margin rate dated 16 Sep 2026. Current schedule visually checked 1 Oct 2026.
  7. Fidelity — margin rates, effective 18 Sep 2026. Checked 1 Oct 2026.
  8. Robinhood support — IRA match FAQ. Checked 1 Oct 2026.
  9. Robinhood Gold IRA contribution match terms (PDF), p.3. Checked 1 Oct 2026.
  10. Robinhood support — crypto order routing, rebate as of 15 Jun 2026. Checked 1 Oct 2026.
  11. Robinhood support — crypto fee tiers (exchange routing). Checked 1 Oct 2026.
  12. Robinhood support — event contracts overview. Checked 25 Sep 2026.
  13. Robinhood Derivatives fee schedule (PDF), p.1. Checked 25 Sep 2026.
  14. Robinhood newsroom — World Cup event contracts, 4 Jun 2026. Checked 25 Sep 2026.
  15. Robinhood Financial / Robinhood Securities Customer Agreement (PDF), §27 (interest on free credits outside program), §39.C (pending class case). Current PDF checked 1 Oct 2026; the hosted file can change.
  16. SEC — In the Matter of Robinhood Financial LLC, Order 33-10906 (PDF), 17 Dec 2020, ¶¶3, 23, 37, 39, 40, 42. Cited paragraphs rechecked 1 Oct 2026.
  17. SEC press release 2020-321, 17 Dec 2020. Checked 25 Sep 2026.
  18. FINRA — Robinhood Financial LLC, Letter of Acceptance, Waiver and Consent (PDF), 30 Jun 2021. Cited pages rechecked 1 Oct 2026.
  19. SEC staff — Report on Equity and Options Market Structure Conditions in Early 2021 (PDF), Oct 2021. Located 25 Sep 2026.
  20. SEC — Rule 605 amendments, compliance-date release 34-104147 (PDF). Checked 25 Sep 2026.
  21. SEC press release 2025-5 — two Robinhood broker-dealers to pay $45 million, 13 Jan 2025. Located 25 Sep 2026.
  22. FINRA news release — $3.75 million restitution; fines for AML, supervisory and disclosure violations, 7 Mar 2025. Located 25 Sep 2026.
  23. Robinhood Markets — Q2 2026 Form 10-Q, commitments and contingencies note. Checked 25 Sep 2026.
  24. Kessler Topaz Meltzer & Check — Robinhood cash-sweep case page (plaintiffs’ counsel). Checked 1 Oct 2026.
  25. Val, Hsiung & Hofmann — SSRN 4900783. Listing checked 25 Sep 2026; data period not established.
  26. De Giorgi, Hirt & Schuettler — SSRN 6182060. Listing checked 25 Sep 2026; data period not established.
  27. Federal Reserve — open market operations: federal funds target range history. Fetched 25 Sep 2026.
  28. Robinhood support — High-Yield Cash Program interest rate (APY): the $10,000 brokerage-held / swept split, rate as of 17 Sep 2026. Fetched 25 Sep; location rule checked 1 Oct 2026.
  29. Robinhood support — How do I pay for Robinhood Gold? ($5 monthly or $50 annual). The page carries no date. Checked 1 Oct 2026.
  30. Rule 605 August 2026 Order Execution Summary Data Report — Robinhood Financial (CRFN), PDF. Published 30 Sep; visually checked 1 Oct 2026.
  31. Rule 605 August 2026 Order Execution Summary Data Report — Robinhood Securities (HOOD), PDF. Published 30 Sep; checked 1 Oct 2026 against its CSV and rendered summary.
  32. Rule 605 August 2026 Order Execution Summary Data Report — Fidelity (FIBS), PDF. Published 30 Sep; visually checked 1 Oct 2026.
  33. Rule 605 August 2026 Order Execution Summary Data Report — Schwab (CHAS), PDF. Published 30 Sep; checked 1 Oct 2026 against rendered summary.
  34. SEC staff — Rule 605 FAQ (categorization, share weighting and metrics). Checked 1 Oct 2026.
  35. Charles Schwab — October 2019 zero-commission announcement. Checked 1 Oct 2026.
  36. Robinhood newsroom — Introducing 24/7 Phone Support, 5 Oct 2021. Checked 1 Oct 2026; historical launch, not current availability.
  37. FINRA — Robinhood Financial 2019 best-execution AWC (PDF), 19 Dec 2019. Located 1 Oct 2026.
  38. Robinhood SEC filing — December 2019 FINRA proceeding and $1.25m fine, filed 2021. Checked 1 Oct 2026.
  39. In re Robinhood Cash Sweep Program Litigation — joint status report, docket 131, filed 8 Sep 2026. Checked 1 Oct 2026; no agreement terms in this filing.

Robinhood lowered the visible price of investing, and many customers benefited.

What “free” cost in 2016–2019 is documented: an SEC finding, settled without admission, of lost price improvement on certain orders. That finding belongs to its period and is not a description of today.

What CHI can document now is narrower and different in kind. A non-Gold cash yield was published, cut, and then ended for self-directed customers, while Robinhood’s published high-yield cash rate is reserved for Gold, with managed Strategies accounts the stated exception. Around it sit disclosed conditions on the IRA match, outgoing transfers and crypto routing.

That supports a narrow thesis.
It does not support calling today’s Robinhood deceptive, or calling Gold a trap.

NARROW THESIS SUPPORTED CHI Special Investigation · no numerical score · evidence reviewed through 1 October 2026

Reading this beside the rest of the index

A Special Investigation of where the conditions moved, not of whether the product is good.

Read it alongside the other Special Investigations, the Revolut investigation that will become its comparator, the pattern behind the exit fee, and the methodology that explains why no number appears here.