15 pages. "[D]epending on their business models and operations, robo-advisers should keep in mind certain unique considerations as they seek to meet their legal obligations under the Advisers Act. This Staff guidance offers suggestions for how robo-advisers may address some of these issues.... [T]here may be a variety of means for a robo-adviser to meet its obligations to its clients under the Advisers Act ... This Staff guidance focuses on robo-advisers that provide services directly to clients over the internet. This guidance, however, may be helpful for other types of robo- advisers as well as other registered investment advisers."