What changed in this filing

/stocks — the workspaceLOADING

Item 1. Business

2025-02-18 compared with 2024-02-27 · 264 added, 185 removed, 304 unchanged (60% of the section changed)

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We started with a revolutionary, bold brand and design in the Robinhood app which makes investing approachable for millions.

We pioneered commission-free stock trading with no account minimums, which has since been adopted by the rest of the industry, and we continue to build relationships with our customers by introducing new products that further expand access to the financial system.

Over the last decade, we have disrupted and changed the industry, becoming the first U.S.

retail broker to offer commission-free stock trading with no account minimums, which was subsequently adopted by the rest of the industry.

In recent years, we have continued to build relationships with our customers by introducing new products and diversifying our services that further expand access to the financial system, including focusing on products and tools for more seasoned investors.

Through these efforts, we believe we have made investing culturally relevant and understandable, and that our platform is enabling our customers to become long-term investors and take greater control of their finances.

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Robinhood is a safety first company.

We create with care, make changes thoughtfully, and we obsess over details.

We create with care, make changes thoughtfully, and obsess over details.

We don’t compromise regulatory requirements to move fast, and when we see something amiss, we move quickly to correct it.

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and when something is broken, we fix it.

We are driven by impact and constantly go after big opportunities.

We are driven by impact and constantly go

after big opportunities.

We are making Robinhood a place people want to be by investing in our employees, leveraging diverse perspectives, and rewarding top performance.

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We are passionate about operating Robinhood in a way that aligns with customer interests, applicable regulations, and with our own mission to democratize finance for all.

We plan to create an ecosystem of financial products and services that will enable people across the world to become investors.

We believe the products on our roadmap will go a long way toward making that a reality.

We believe our products can transform the relationship people have with the financial system.

We began by offering our customers the ability to buy and sell equities on a mobile-first platform and have since continued to expand our offerings to add products and features for our customers.

We continue to create an ecosystem of financial products and services that will enable people across the world to become investors.

We believe our products can transform the relationship people have with the financial system and that the products on our roadmap will go a long way toward making that a reality.

We began by offering our customers the ability to buy and sell equities on a mobile-first platform and have since continued to expand our offerings to add new asset classes, products and features, while also growing internationally to better serve our customers.

We designed our mobile platform to be an elegant, intuitive investing interface that provides our customers with trading functionality and market information such as historical prices, valuation multiples, recent news, analyst ratings, advanced charts, and more, at no additional cost.

During the fourth quarter of 2024, we introduced Robinhood Legend.

Built specifically for active traders, Robinhood Legend is a new powerful, sleek browser-based desktop trading platform that is fully customizable and available at no additional cost to anyone with a Robinhood account.

We are in the process of scaling Robinhood Legend to all supported asset classes and capabilities, with the goal of making it the most state-of-the-art desktop platform for trading.

Each capability we have added has been the result of a continuous focus on our customers’ needs and feedback, which has guided our product development decisions throughout our history.

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We remain focused on building the best products and ultimately aim to serve all of our customers’ financial needs.

United States

• Investing .

Our platform allows our customers to invest commission-free in U.S.-listed stocks and exchange traded funds (“ETFs”), as well as related options and American Depository Receipts (“ADR”).

We believe we have designed an elegant, intuitive investing interface that provides our customers with trading functionality and market information such as historical prices, valuation multiples, recent news, analyst ratings, and more.

We also launched advanced charts, which gives customers customizable, quick, simple and in-depth analysis right in the app.

Our platforms allow our customers to invest commission-free in U.S.-listed stocks and exchange traded funds (“ETFs”), as well as related options and American Depository Receipts (“ADR”).

• Options Trading.

We review eligibility for our customers who wish to trade options, including disclosure of investment experience and knowledge, investment objectives and financial information.

Subject to approval from Robinhood, customers can access basic options strategies (Level 2), which permits buying calls and puts and selling covered calls and puts, or more advanced options strategies (Level 3), which permits fixed-risk spreads (such as credit spreads and iron condors) and other advanced trading strategies, depending on their individually disclosed preparedness.

and iron condors) and other advanced trading strategies, depending on their individually disclosed preparedness.

We conduct regular reviews of our customers’ eligibility and take action to revoke access to trading options as appropriate, to ensure our customers are accessing the level of options strategies that are appropriate for them based on information such as their trading experience, investment objectives and financial situation.

During the fourth quarter of 2024, we announced index option trading and made it available to all customers in January 2025.

Index option trading allows our customers to trade options on diversified indices like the S&P 500 and VIX, while gaining access to potential tax benefits and one of the lowest contract fees among leading brokerages.

• Fractional Trading .

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Subject to approval upon meeting eligibility criteria set by Robinhood, customers can invest on margin.

This allows eligible customers to borrow a limited amount of funds from Robinhood at a floating interest rate to use as additional investing capital.

This allows eligible customers to borrow a limited amount of funds from Robinhood to use as additional investing capital.

Robinhood decides whether to extend margin to each customer who applies for access based on information regarding customer activity, portfolio equity or net worth criteria, investment objectives, and investing experience reported by the customer.

In 2024, we began to offer an industry-leading tiered margin structure where customers now receive a single low interest rate based on their total margin balance, replacing the floating interest rate that was offered previously.

• Fully-Paid Securities Lending.

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Our instant withdrawals feature enables eligible customers to withdraw money from their Robinhood accounts and instantly deposit it to their bank accounts or debit cards with a fee.

Instant withdrawals are also available to customers of the Robinhood Cash Card and Spending Account (each described below).

• Robinhood Retirement.

We are making it easy and accessible to start saving for retirement through a traditional Individual Retirement Account (“IRA”) or Roth IRA and are expanding options for the growing population of freelance and gig workers without access to employer-based matching programs.

Customers’ eligible contributions to their retirement account can earn a percentage match by Robinhood (“Robinhood Retirement Match”), subject to a five-year holding period.

Customers’ eligible contributions to their retirement account can earn a percentage match by Robinhood, subject to a five-year holding period.

We offer customer IRA instant deposits up to $1,000, which allows customers to immediately start investing.

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• 24 Hour Market .

We are the first U.S.

We were the first U.S.

broker to offer around-the-clock trading of individual stocks, 24 hours a day, 5 days a week.

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It allows our customers to better manage their risk and take advantage of opportunities, no matter what time of day they arise.

• IPO Access and Directed Share Program .

Our IPO Access feature enables our customers, with no account minimums, to buy shares in participating initial public offerings (“IPOs”) at the IPO price, before trading begins on public exchanges.

We also offer our Directed Share Program service that gives an issuing company the chance to set aside a certain amount of shares, at the IPO price, for a specific group of people, such as employees, valued customers, vendors, or others who have a relationship with the issuer.

• Joint Investing Accounts.

Our joint investing accounts allow customers to seamlessly manage investments with their partner while keeping their shared assets in one place.

The joint account provides shared access for account holders that allows them to combine funds and increase their investment power as they work towards their financial goals.

Gold Subscribers can also extend certain Robinhood Gold benefits to a joint account at no additional cost.

• Event Contracts.

An event contract is a type of financial derivative that allows traders to speculate on the outcome of a specific event.

These contracts are generally structured around “Yes” or “No” outcomes, and fluctuate in price based on the projected outcome of the event.

Event contracts then pay out if the position held matches the correct outcome of the event;

otherwise, they expire with no value.

Event contracts are offered through our Futures Commission Merchant (“FCM”) license regulated by the Commodity Futures Trading Commission (“CFTC”).

During the fourth quarter of 2024, we were one of the only companies offering presidential election event contracts for the U.S.

presidential election, which allowed customers to trade based on their prediction for which candidate would win the election.

We believe event contracts give people a tool to engage in real-time decision-making, unlocking a new asset class.

Following the success of our presidential election market, we plan to launch a more comprehensive event contract product in response to customer demand.

A futures contract is a legal agreement between two parties to buy or sell a set amount of an asset at an agreed-upon future date with the price set today.

We started to make futures trading available to customers beginning January 2025 and expect full availability to all customers in the first quarter of 2025.

Our futures trading allows customers to trade stock indexes, energy, currency, metals, and crypto at the speed of a tap with our sleek new trading ladder, while gaining access to potential tax benefits and one of the lowest commissions rates among leading competitors.

In addition, our futures trading has no pattern day trading rules.

United Kingdom

• In 2024, we began to offer most of our brokerage services to customers in the U.K.

through Robinhood U.K.

Ltd (“RHUK”), using a separate mobile application that is only available to eligible users in the U.K.

Brokerage services available to our U.K.

customers include commission-free trading on U.S.-listed stocks and ADR, option trading, fractional share trading, recurring investments, investing on margin, Fully-Paid Securities Lending, Cash Sweep, and 24 Hour Market.

We plan to continue expanding our U.K.

brokerage product offering in 2025.

Robinhood Crypto

United States

We offer commission-free cryptocurrency trading in the United States through Robinhood Crypto, LLC (“RHC”).

We have expanded our coverage to include every U.S.

state and the District of Columbia, except for Hawaii.

We offer cryptocurrency trading in the United States through Robinhood Crypto, LLC (“RHC”).

We have expanded our coverage to Hawaii, Puerto Rico, and the U.S.

Virgin Islands, achieving full coverage across all U.S.

states and the largest territories.

Customers trading in the Robinhood app can choose to have orders routed to non-exchange liquidity providers (“market makers”) commission-free or through exchange liquidity providers (“partner exchanges”) via smart exchange routing for a fee.

Orders placed on Robinhood Legend are all routed to the partner exchanges via smart exchange routing.

We currently support trading in the following 22 cryptocurrencies, where available (1) :

Aave (AAVE) Avalanche (AVAX)* Bitcoin (BTC)

Bitcoin Cash (BCH) Chainlink (LINK) Compound (COMP)*

Dogecoin (DOGE) Ethereum (ETH) Ethereum Classic (ETC)

Litecoin (LTC) Shiba Inu (SHIB)* Stellar Lumens (XLM)*

Tezos (XTZ)* Uniswap (UNI)* USD Stablecoin (USDC)**

Aave (AAVE) Avalanche (AVAX)

Bitcoin (BTC)

Bitcoin Cash (BCH) BONK (BONK)

Cardano (ADA)

Chainlink (LINK) Compound (COMP)

Dogecoin (DOGE)

Dogwifhat (WIF) Ethereum (ETH) Ethereum Classic (ETC)

Litecoin (LTC) Pepecoin (PEPE) OFFICIAL TRUMP (TRUMP)*

Shiba Inu (SHIB)

Solana (SOL) Stellar Lumens (XLM)

Uniswap (UNI)

USD Stablecoin (USDC)**

_______________

(1) Not all cryptocurrencies are available in every state.

A single asterisk indicates a cryptocurrency is not currently available for trading in New York.

An asterisk indicates a cryptocurrency is not currently available for trading in New York;

a double asterisk indicates a cryptocurrency is not currently available for trading in New York or Texas.

We also offer crypto recurring investments, allowing customers to automatically buy crypto, commission-free, on a schedule of their choice.

We also offer commission-free crypto recurring investments, allowing customers to automatically buy crypto on a schedule of their choice.

This feature allows customers to build positions in their favorite cryptocurrencies over time.

As an agent, we route all cryptocurrency transactions initiated by customers to third-party market makers.

As an agent, we route all cryptocurrency transactions initiated by customers to third-party market makers or exchange liquidity providers .

We never act as a counterparty to our users’ buy or sell transactions.

We also offer cryptocurrency transfers (“Crypto Transfers”), allowing customers to transfer cryptocurrency into and out of their RHC accounts without commission, where eligible.

Additionally, we provide real-time market data for certain cryptocurrencies, including those that are not supported on RHC’s platforms, for informational purposes only.

In 2023, we launched Robinhood Connect, a new avenue that allows customers to fund Web3 wallets without the need to leave decentralized applications, or dApps.

We offer cryptocurrency transfers (“Crypto Transfers”), allowing customers to transfer cryptocurrency into and out of their RHC accounts without commission, where eligible.

Additionally, we provide real-time market data for certain cryptocurrencies, including those that are not supported on RHC’s platform, for informational purposes only.

With Robinhood Connect, a fiat-to-crypto on-ramp tool that developers can embed directly into their decentralized applications, customers can fund Web3 wallets without the need to leave decentralized applications, or dApps.

This avenue also benefits developers by being able to quickly embed the feature directly into their dApps, allowing their customers to use Robinhood Crypto to buy and transfer crypto, and fund their self-custody wallets.

We also launched the Robinhood Crypto Trading API to our most seasoned crypto traders, which can be used to set up advanced and automated trading strategies that allow them to stay ahead of market trends, react to significant market movements, or simply trade crypto–all without needing to open the Robinhood app.

European Union

As of December 2023, we also offer commission-free cryptocurrency trading in select jurisdictions within the European Union (the “EU”) through Robinhood Europe, UAB (“RHEC”) using a separate mobile application that is only available to eligible users in the EU.

Eligible users in select jurisdictions in the EU can currently buy, sell, and hold select cryptocurrencies through RHEC.

The list of cryptocurrencies supported by RHEC for eligible users in select jurisdictions in the EU is available on our website at https://robinhood.com/eu/en/support/articles/about-robinhood-crypto/ .

We offer cryptocurrency trading in select jurisdictions within the European Union (the “EU”) through Robinhood Europe, UAB (“RHEU”) using a separate mobile application that is only available to eligible users in the EU.

Eligible users in select jurisdictions in the EU can currently buy, sell, and hold select cryptocurrencies through RHEU.

We charge users a commission each time a user decides to buy or sell certain cryptocurrencies in the EU.

The list of cryptocurrencies supported by RHEU for eligible users in select jurisdictions in the EU is available on our website at https://robinhood.com/eu/en/support/articles/about-robinhood-crypto/ .

We offer staking exclusively for EU customers on selected cryptocurrencies.

Staking allows customers to earn rewards by locking up the cryptocurrencies, subject to the network and cryptocurrency’s requirements and bonding periods.

In 2024, we also made Crypto Transfers available in the EU, giving EU customers greater flexibility and control over their digital assets.

We hold all settled cryptocurrencies in custody on behalf of customers in two types of wallets:

(i) hot wallets, which are managed online, and (ii) cold wallets, which are managed entirely offline.

Our wallets store and transfer all the settled digital assets listed above using either private keys through hardware security modules or an architecture combining multi-party computation and hardware security to eliminate a single point of failure.

(i) hot wallets, which are managed online, and (ii) offline cold wallets, which require physical access controls.

Our wallets store and transfer all the settled digital assets listed above using an architecture combining multi-party computation and hardware security to eliminate a single point of failure.

We do not utilize third-party custodians for settled cryptocurrencies, but we do integrate proprietary technology from a third-party industry-standard vendor into the systems we use to support the custody, transfer and settlement operations to our wallets.

In general, the overwhelming majority of cryptocurrency coins on our platform are held in cold storage, in facilities located in the United States with physical security systems that we believe are state-of-the-art, though some coins are held in hot wallets to support day-to-day operations.

In general, the overwhelming majority of cryptocurrency coins on our platforms are held in cold storage, in facilities located in the United States and in the EU with physical security systems that we believe are state-of-the-art, though some coins are held in hot wallets to support day-to-day operations.

We maintain custody of our customers’ cryptocurrencies in omnibus wallets on behalf and for the benefit of our customers.

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Such controls are periodically tested by the Company’s internal financial compliance team.

With the exception of small amounts of cryptocurrency we purchase to support our business operations, we do not hold cryptocurrency for our own account and, therefore, do not commingle cryptocurrencies with those of our users.

We currently do not hold significant amounts of cryptocurrency for our own account.

The small amounts of cryptocurrency assets we currently hold are purchased to solely support our business operations, and we do not commingle cryptocurrencies with those of our users.

We do not engage in lending transactions with cryptocurrencies held on behalf of customers.

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Robinhood Wallet

Separately from RHC and RHEC, Robinhood offers a self-custody, web3 wallet (the “Robinhood Wallet”) in over 150 countries through our Cayman Islands subsidiary, Robinhood Non-Custodial Ltd.

(“RHNC”), that allows customers to deposit and withdraw cryptocurrencies to and from their wallets.

Customers can store and manage cryptocurrencies on the Ethereum, Bitcoin, Dogecoin, Polygon, Arbitrum, Optimism and Base networks.

Separately from RHC and RHEU, Robinhood offers a self-custody, web3 wallet (the “Robinhood Wallet”) in over 150 countries through our Cayman Islands subsidiary, Robinhood Non-Custodial Ltd., that allows customers to deposit and withdraw cryptocurrencies to and from their wallets.

Customers can store and manage cryptocurrencies on the Ethereum, Bitcoin, Solana, Dogecoin, Arbitrum, Polygon, Optimism and Base networks.

The Robinhood Wallet gives customers full control over their cryptocurrencies, which means they hold and maintain the private key to their assets, and does not collect any portion of network or “gas” fees imposed by the applicable network.

The Robinhood Wallet is a software application that users must access via a separate application.

Neither RHC nor RHEC custody any Robinhood Wallet assets.

Neither RHC nor RHEU custody any Robinhood Wallet assets.

Robinhood Gold

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Subscribers can immediately access $5,000 to $50,000 of their deposit, depending on their brokerage account balance and status, instantly so they can invest that portion of their deposit right away.

• Access to Investing on Margin at a More Competitive Interest Rate .

Subscribers can invest on margin at a lower rate compared to users who do not subscribe to Gold.

• Access to Investing on Margin .

No interest is charged on the first $1,000 in margin borrowed by each Robinhood Gold subscriber.

• Lower Contract Fees or Commissions.

Subscribers can trade index options at a lower contract fee or futures with lower commissions charged compared to customers who do not subscribe to Gold.

• Professional Research.

Subscribers have unlimited access to in-depth stock research reports provided by Morningstar.

• Nasdaq Level II Market Data.

Subscribers have the ability to see greater depth of orders for any given stock or option.

• Advanced Market Data.

Subscribers have the ability to see greater depth of orders for any given stock or option with Level II Market Data from Nasdaq.

The ability to see multiple buy and sell requests helps subscribers understand the availability or desire for a stock at a certain price.

Robinhood Credit Card

Our Robinhood Credit Card allows us to provide our customers access to credit.

The credit card program is funded under a program agreement (“Program Agreement”) between Robinhood Credit, Inc.

(“Robinhood Credit”) (formerly X1 Inc.) and Coastal Community Bank (“Coastal Bank”), a member of the FDIC.

There are no annual fees, no late fees, and no foreign transaction fees.

The credit card offers rewards on each purchase.

Robinhood Cash Card and Spending Account

Our Cash Card and Spending Account allows customers to spend with a prepaid spending card (“Robinhood Cash Card”) issued by Sutton Bank (“Sutton”).

We offer a variety of features, such as recurring investments, paycheck early access, and a cash back rewards program.

There are no monthly fees, no subscription fees, and no account minimum fees.

Funds held in Robinhood Cash Card and Spending Account are eligible for FDIC insurance.

Robinhood Gold Card

Robinhood Gold Card is offered under a program agreement (“Program Agreement”) between Robinhood Credit, Inc.

(“Robinhood Credit”) and Coastal Community Bank (“Coastal Bank”), a member of the FDIC.

There are no annual fees, and no foreign transaction fees.

Robinhood Gold Card is exclusively for qualified Gold Subscribers and offers rewards on each eligible purchase, which are redeemable for travel, gift cards, and shopping, or can be instantly transferred to a Robinhood Gold Card user's brokerage account to invest, earn interest, or withdraw.

Robinhood Gold Card users can manage their card activities via a separate mobile application, the Robinhood Credit Card app.

We continue to roll out Robinhood Gold Card, now in the hands of nearly [100 thousand] customers.

We believe that offering educational resources is critical to advancing our mission.

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• Robinhood Learn .

Robinhood Learn is an online collection of beginners’ guides, feature tutorials, and an extensive financial dictionary available to anyone.

Robinhood Learn is an online collection of guides, feature tutorials, and an extensive financial dictionary available to anyone.

It is designed to provide people with a breadth of financial education and is regularly updated to ensure we provide timely and relevant information for anyone to learn and grow.

• In-App Education .

Our first in-app education resources cover investing fundamentals including why people invest, a stock market overview, and tips on how to define investing goals.

Our in-app education resources cover investing fundamentals including why people invest, a stock market overview, and tips on how to define investing goals.

This allows customers to understand the basics of investing before their first trade.

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Our newsfeeds give customers access to free, premium news from sites such as Barron’s, Reuters and Dow Jones.

• Robinhood Snacks .

Robinhood Snacks is an accessible digest of business news stories written for a new generation of investors.

• Sherwood Snacks .

Sherwood Snacks is an accessible digest of business news stories written for a new generation of investors.

Its bite-sized news stories bring new investors the latest market-moving news without all of the complicated financial jargon.

Building on the success of Robinhood Snacks, we formed Sherwood Media, LLC, a subsidiary that is the home for news and information about the markets, economics, business, technology, and the culture of money.

Throughout 2023, we offered a suite of new editorial offerings, complementing Robinhood Snacks with more always-on news updates and analysis, original reporting and new newsletter offerings.

Building on the success of Robinhood Snacks, we formed Sherwood Media, LLC (“Sherwood Media”), a subsidiary that is the home for news and information about the markets, economics, business, technology, and the culture of money.

We offer a suite of new editorial offerings, complementing Robinhood Snacks with more always-on news updates and analysis, original reporting and new newsletter offerings.

• Crypto Learn and Earn .

Our exclusive in-app educational module available to all RHC and eligible RHEC customers via Robinhood Learn that educates customers on the basics about cryptocurrency.

Our exclusive in-app educational module available to all RHC and eligible RHEU and Robinhood Wallet customers via Robinhood Learn that educates customers on the basics about cryptocurrency.

Customers who complete these courses will be eligible to receive rewards, which will be paid out in cryptocurrency.

Our Technology

The Robinhood mobile app is the core front-end pathway through which our customers engage with us.

Our self-clearing platform, order routing system, data platform, and other back-end infrastructure deliver the capabilities that allow our customers to focus on investing, saving and spending, while also enabling us to rapidly develop products that our customers love to use.

The Robinhood apps and Robinhood Legend are the core front-end pathways through which our customers engage with us.

Our self-clearing system, order routing system, data platform, and other back-end infrastructure deliver the capabilities that allow our customers to focus on investing, saving and spending, while also enabling us to rapidly develop products that our customers love to use.

Some of our most critical technologies include:

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• Self-Clearing System.

Our self-clearing services allow us to clear and settle trades across stocks, ETFs, and options without relying on a third-party clearing firm, an approach that provides increased internal visibility over clearing and settlement.

• Order Routing System.

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We are committed to seeking a quality execution on every order, and our routing protocols are designed with this in mind.

• Machine Learning Platform.

Our machine learning models are highly advanced and contribute to multiple capabilities across our business.

For example, we use machine learning as part of our fraud detection systems and customer support workflows, and even to improve the customer experience in our newsfeed by expanding the number of sources we can pull from, parsing and categorizing these articles, and delivering highly relevant and varied news to our customers for companies, stocks, or cryptocurrencies.

• Machine Learning Platform and Artificial Intelligence.

We currently use machine learning and AI to improve our products and processes in certain circumstances.

Our machine learning models and AI contribute to multiple capabilities across our business.

For example, we use machine learning and AI to increase the efficiency of our in-app chat support, customer support workflows, fraud detection systems, and even to improve the customer experience in our newsfeed by expanding the number of sources we can pull from, parsing and categorizing these articles, and

delivering highly relevant and varied news to our customers for companies, stocks, or cryptocurrencies.

• Experiments Infrastructure.

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The iterative, customer-centric product development approach that is so core to our success is enabled by this robust internal technology.

Looking ahead, we believe we are strategically positioned at the center of two major platform shifts—AI and cryptocurrency and blockchain technology—which have the potential to transform the industry.

• Artificial Intelligence .

We currently expect our adoption of AI to occur in three phases:

by augmenting internal operations, by enhancing customer-facing products, and by developing sophisticated autonomous financial agents.

We have successfully created operational efficiencies and brought in top-tier AI talent, including experts from leading frontier AI labs, to accelerate our advancements in AI.

Additionally, we have begun to incorporate early applications of generative AI into our product offerings, such as within our customer service flows.

As a technology company, we believe we are able to rapidly adopt new tools on the way to building complex AI agents and expect to introduce significantly more in the coming year, including our first AI-native advisory products.

• Cryptocurrency and Blockchain Technology .

We believe cryptocurrency and blockchain technology will fundamentally transform financial infrastructure by offering significant efficiencies as the blockchain reduces the need for traditional financial intermediaries, such as clearing houses, transfer agents, and payment processors, leading to lower operational costs.

We anticipate that cryptocurrency will increasingly integrate with the traditional financial system, ultimately serving as the new infrastructure for financial services.

We expect that this will be driven by tokenization, which enables efficiency gains by moving traditional financial assets onto blockchain.

We believe our leadership in crypto trading will position us to lead in this space and expect to continue launching new products and features that drive tokenization in the future.

Our Customers

We are empowering a new generation of financial consumers.

Robinhood was built to make the financial system more friendly, approachable, and understandable to newcomers and experts alike.

We have reached customers across the United States from a wide variety of social and economic backgrounds and many of our customers funding accounts on our platform told us that Robinhood was their first brokerage account.

We take pride in the fact that we are expanding the market by welcoming new investors into the financial system and helping the next generation of investors build sound long-term investing, saving, and spending habits.

Robinhood was built to make the financial system more accessible and transparent for everyone.

We have reached customers from a wide variety of social and economic backgrounds and many of our customers have told us that Robinhood was their first brokerage account.

We are also laser focused on being the top platform for active traders who trade more actively and use more sophisticated products.

Customer feedback is at the heart of product development at Robinhood.

As such, we regularly communicate with our customers—not just to provide support, but also to learn more about their experiences and insights, and to respond to their feedback about our products.

This keeps us connected with customers and enables us to understand their expectations and the problems and opportunities they face financially.

In response to slower customer support response times during high volume periods, we also streamlined the in-app phone support request process and introduced 24/7 in-app chat support.

We regularly communicate with our customers—not just to provide support, but also to learn more about their experiences and insights, and to respond to their feedback about our products.

This keeps us connected with customers and enables us to understand their expectations, problems and opportunities they face financially.

For example, in response to this customer feedback, we launched tax lots, an important feature designed to help customers manage their tax liabilities and give them flexibility when selling stocks.

Further, in response to feedback from our active traders to have more tools to better track and manage their portfolio’s performance, both past and present, we also introduced the profit and loss chart, which enables our customers to see realized profit and loss information on all trades since January 1, 2024.

These launches reflect our ongoing commitment to providing our customers with the insights and resources they need to make informed decisions and plan for the future.

Our Growth Strategies

We aim to serve our customers with existing product offerings, grow with our customers over time as they build their wealth, and create new and innovative products that are relevant to new and existing customers.

Winning the Active Trader Market

We are laser focused on being the top platform for traders who trade more actively and use more sophisticated products, and we track our progress here by Notional Trading Volume (as defined in Part II, Item 7 of this Annual Report, “Glossary Terms”) market share.

Our focus has been on systematically resolving issues that would lead an active trader to consider using another platform, with a particular emphasis on pricing, speed, and app usability.

In 2023, we launched several new features and products focused on delivering the top feature requests and addressing pain points from our active traders.

These features and products included 24 Hour Market, upgraded advanced charts, strategy builder, stock screeners, and streamlined equity trading flow.

We plan to keep investing in mobile where we are number one in the market today and to create a pro trader web experience that positions us to be the number one overall.

We also plan to continue to innovate for our active traders to drive an even better experience.

Increasing Wallet Share

Our growth strategies are built around three key focus areas designed to meet increasing demand from our customers and further our mission of democratizing finance for all.

We believe we are still in the early stages of this journey and remain committed to expanding access to financial services through innovative products.

Establishing Ourselves as the Number One Platform for Active Traders

Our focus has been on systematically resolving issues that would lead an active trader to consider using another platform, with a particular emphasis on innovation and speed.

We track our progress here by Notional Trading Volume (as defined in Part II, Item 7 of this Annual Report, “Glossary Terms”) market share.

Our strategy for being number one in active traders is centered on three main priorities:

• new product innovations not yet available from all of our competitors such as our 24 Hour Market;

• expansion of asset classes such as index options, futures, and event contracts;

• improving our tools, latency and charting to be best-in-class, particularly on Robinhood Legend.

With the launch of Robinhood Legend, along with a range of new capabilities and features that we have built and released, and plan to continue building and releasing in the future, we believe in our path to becoming the number one retail trading platform across all asset classes.

Becoming the Number One in Wallet Share for the Next Generation

Many of our customers are just beginning their financial journeys.

As our customers grow their wealth, we believe they will continue to expand their relationship with our platform, providing an increased opportunity to meet their growing financial needs.

As our next generation customers grow their wealth, we believe they will continue to expand their relationship with our platform, providing an increased opportunity to meet their growing financial needs.

We believe that these needs may come in a number of forms, from helping new investors grow into long-term investors to providing other financial services such as saving, spending, or facilitating payments.

We are committed to deepening strong relationships with our customers and we are focused on increasing Robinhood Gold Memberships and Net Deposits (as defined in Part II, Item 7 of this Annual Report, “Key Performance Metrics”).

We plan to keep investing in our existing products and features such as Robinhood Gold, Robinhood Retirement, and deposit matches, while also launching new products like credit cards.

Expanding Internationally

We are committed to deepening strong relationships with our customers and we track our progress here by Robinhood Gold Subscribers and Net Deposits (each as defined in Part II, Item 7 of this Annual Report, “Key Performance Metrics”).

Our strategy for being number one in wallet share for the next generation is centered on three main priorities:

• build new products that cover the next generation’s remaining core financial needs, such as wealth management and advisory.

We expect multigenerational advisory to be a big focus area in our future product roadmap, including via our pending acquisition of TradePMR (refer to Note 3 - Business Combinations to our consolidated financial statements in this Annual Report for more information);

• innovate on incentives, particularly through Robinhood Gold, to provide our customers with greater value as their assets grow with us.

Robinhood Gold has accelerated our growth in wallet share with our customers and we plan to continue expanding its coverage to include more of our products;

• reduce withdrawals and increase deposits by further streamlining the process for customers to onboard, deposit funds, and transfer assets into Robinhood.

Building the Number One Global Financial Ecosystem

We believe there is a significant opportunity for Robinhood to grow internationally.

The Robinhood Wallet was our first offering to customers internationally and is empowering customers around the world to custody their own crypto.

In December 2023, we launched the brokerage services in the United Kingdom on a rolling basis, and plan to reach full availability in the first half of 2024.

The United Kingdom customers have access to commission-free trading of U.S.-listed stocks and ADRs.

Additionally, we launched the Robinhood Crypto app to all eligible customers in select jurisdictions in the EU.

Over time, we intend to pursue a disciplined approach to international expansion and we will consider factors such as population size and demographics, legal and regulatory environments, and general investing attitudes and the competitive landscape in potential new markets prior to pursuing such expansion.

We have leveraged our strengths as a technology and innovation leader in the U.S.

and expanded our reach globally in the U.K.

with brokerage services and in the EU with cryptocurrency trading.

We have also taken our first steps in the business-to-business and institutional markets through our pending acquisitions of Bitstamp and TradePMR (Refer to Note 3 - Business Combinations to our consolidated

financial statements in this Annual Report for more information).

Our strategy for building a global financial ecosystem is centered on three main priorities:

• extend and adapt products that we have already built for U.S.

consumers, such as our planned 2025 launch of options trading in the U.K.;

• prioritize functionality that creates value for our customers across our platforms globally, and not just focusing on one individual market, such as multicurrency accounts and integration with foreign exchanges like the London Stock Exchange;

• introduce market-specific functionality, such as individual saving accounts and self-invested personal pensions in the U.K.

We consider factors such as population size and demographics, legal and regulatory environments, general investing attitudes and the competitive landscape in potential new markets prior to pursuing such expansion.

This drove our decision to open an office in Singapore as our APAC headquarters.

Our plans to pursue international expansion are dependent on a variety of external factors, including, among other things, our obtaining required regulatory approvals, authorizations, licenses and consents, our obtaining and protecting intellectual property rights abroad, and the identification of, and successful entry into new business partnerships with third-party service providers that would be necessary to provide our products and services in the relevant local market.

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• vertical integration.

We seek to differentiate ourselves from competitors primarily through our vertically integrated, mobile-first platform and focus on accessibility, customer experience, and trust.

We believe that our ability to innovate quickly further differentiates our platform from our competition.

We seek to differentiate ourselves from competitors primarily through our vertically integrated mobile and desktop platforms, and focus on accessibility, customer experience, and trust.

We believe that our ability to innovate quickly further differentiates our platforms from our competition.

We believe we compete favorably across all key competitive factors and that we have developed a business model that is difficult to replicate.

Our Competitive Advantages

We believe we have a number of competitive advantages that position us well to serve an increasing portion of the population and the broader financial services ecosystem.

We believe we have a number of competitive advantages that position us well to serve an increasing portion of the population and the broader global financial ecosystem.

Creative Product Design

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In addition, we continue to work to deliver an intuitive product experience including developing and implementing designs to celebrate investing milestones of our customers in a responsible way.

Our products are designed mobile-first, allowing us to offer attractive investing, spending, and saving experiences as more people shift their daily financial services activities to the palm of their hands.

While many of our products are designed mobile-first, allowing us to offer attractive investing, spending, and saving experiences as more people shift their daily financial services activities to the palm of their hands, we have also introduced Robinhood Legend, which we are in the process of scaling to all supported asset classes and capabilities.

Category-Defining Brand

We believe Robinhood today is a symbol of retail investing and finance in America.

We believe Robinhood today is a symbol of retail investing and finance in America, and we are committed to expanding our reach globally.

By taking a fresh, people-centric approach and creating a delightful, engaging customer experience, we believe we have built a trusted, category-defining brand that has made investing socially relevant for the next generation.

The relationship we have built with our customers has led many to want to talk about Robinhood and share their experience with their friends and family.

From Robinhood’s inception, a vast majority of our growth has come directly from customers joining our platform organically or through the Robinhood Referral Program (defined below).

Since 2023, we have increased our investment in paid marketing channels to continuously promote our brand, products, and services.

We believe the excitement around Robinhood demonstrates how our innovative approach to financial products has built deep, loyal customer relationships and positioned us well to continue attracting new people to our platform, and sharing new product experiences with our customers.

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Vertically Integrated Platform

We design our own products and services and deliver them through a single, app-based platform supported by proprietary technology that has been cloud-based from the start.

We are a licensed introducing broker-dealer, a licensed clearing broker-dealer, and a licensed money-transmitter.

We design our own products and services and deliver them through app-based and desktop platforms supported by proprietary technology that has been cloud-based from the start.

We are a licensed introducing broker-dealer, a licensed clearing broker-dealer, a licensed money-transmitter, and a registered futures commission merchant.

Our digitally-native technology stack also gives us control over our product development from end-to-end, enabling faster development times, better customer experiences, stronger unit economics, greater flexibility, and a robust and dynamic risk management framework.

Our vertically integrated platform has enabled us to rapidly introduce new products and services such as 24 Hour Market, Robinhood Wallet and Robinhood Retirement while also supporting our ability to scale.

Our vertically integrated platform has enabled us to rapidly introduce new products and services such as index options, futures, and event contracts, while also supporting our ability to scale.

Operating Efficiency

We believe our operating efficiency and disciplined approach to managing fixed costs, along with our technology-first approach to product development and customer service, creates a cost advantage that allows us to competitively price our offerings while profitably serving our customers.

Our business can be subject to seasonal fluctuations due to such factors as retail interest in investing, overall number of market participants and trading volumes, varying numbers of trading days from quarter-to-quarter, declines in trading activity around holidays, and proxy and investor communications activity during proxy season.

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Our Employees and Culture

Robinhood employees are at the heart of our company mission.

As of December 31, 2023, we had approximately 2,200 full-time employees.

We seek to foster a high-performance culture that elevates and embraces all voices.

During our weekly “all-hands” meetings, every employee has the opportunity to ask a question of our senior leadership.

To ensure we provide a rich experience for our employees, we conduct ongoing employee surveys to build on the competencies that are important for our future success.

Our employee surveys are an important part of our culture and the results are an important part of how we make decisions about life at Robinhood.

These regular check-ins with employees provide critical input for company decisions on how to best improve productivity, inclusion, and retention.

Inclusivity is core to our culture and we seek to create an environment where all viewpoints, including opposing ones, are welcome.

We provide resources, opportunities, and support for career and personal growth, as well as ongoing company initiatives to maintain strong employee engagement.

Talent Acquisition and Development

A critical foundation of our mission is building an inclusive environment that attracts, develops and retains exceptional talent from diverse backgrounds and experiences.

We prioritize hiring great leaders with deep functional expertise, we set high standards for performance and we commit to their professional and technical development so we can grow together as we transform the future of finance.

We continue to invest in recruiting and fostering diverse talent and supporting all of our employees.

We work to attract the best talent from a range of sources in order to meet the current and future demands of our business.

We have relationships with universities, professional associations, and industry groups to proactively engage and attract talent from underrepresented groups.

We work with trusted third-party partners to help us mitigate potential bias in our hiring process—from the language used in our job descriptions to how technical screening interviews are conducted.

The professional growth of our people is essential to the growth of our business and we aim to empower all Robinhood employees to reach their full potential.

In order to pursue our ambitious product roadmap we need to foster a great culture.

At Robinhood, that means focusing our human capital strategy on building a high performance culture, building community, and investing in top talent.

High Performance Culture

We design our talent programs to motivate, recognize, and reward high performance.

We maintain a lean organizational structure to provide internal development opportunities, set clear goals, and assess performance based on impact.

We support job-specific capabilities and training to help develop behavioral and leadership capabilities for all employees.

All full-time employees are offered funds that can be used for education to support skill-building both in current and for future roles, as well as access to resources and training to build their capabilities and professional coaching.

We also offer a variety of formal and informal development and skills-building opportunities to our managers.

For example, we have a leadership development experience for all managers to support them in their growth and development as leaders at Robinhood.

Inclusion, Equity, and Belonging (“IEB”)

Prioritizing an inclusive and equitable culture that attracts, motivates, and retains diverse talent within our workplace is critical to delivering on our mission.

As our customer base is incredibly diverse, we are building a company that can anticipate and meet their needs.

We strive to do this in four distinct ways:

ensuring our workplace culture is accessible and respectful, broadening the diversity of our workforce at all levels, effectively serving non-traditional investors, and increasing financial literacy among underserved communities.

We value each of our employees and their unique contributions as we build our company together.

We have an IEB team dedicated to delivering on Robinhood’s commitment to create an inclusive environment.

In 2023, we integrated IEB education into the workflow for our leaders and people managers, incorporating mitigating bias and equity content into feedback loops, performance reviews, and promotions.

We attended and sponsored a number of conferences focused on recruiting talent from underrepresented groups and continued to expand our community outreach efforts around financial inclusion for underrepresented communities.

As of December 31, 2023, 60% of our employees are members of at least one of our Robinhood Employee Resource Groups (“ERGs”) which are voluntary, identity or experience-based groups led by members and allies who join together to foster a more inclusive workplace.

Each ERG is sponsored by members of our leadership team.

We utilize ERGs to create a welcoming environment for new employees by designating Robinhood Ambassadors, leaders within our ERGs who are available to candidates and new employees who want to learn more about working at Robinhood.

ERG members also have the opportunity to develop professionally, expand their networks, drive awareness around important social issues, and amplify the needs and voices of underrepresented groups.

Robinhood ERGs include:

Asianhood, Black Excellence (BEX), Divergent (for Neurodiversity), Latinhood, Parenthood, Rainbowhood, Sisterhood, Veterans at Robinhood, and Women in Tech.

In addition to providing a supportive, safe space for employees, a number of Robinhood ERGs support specific business objectives that include recruiting, employee engagement, marketing, and more.

For example, our Women in Tech ERG hosted their annual Women in Tech conference, providing opportunities for career development and networking.

We are dedicated to attracting and retaining the top talent in our industry.

We prioritize hiring great leaders and industry talent with deep functional expertise, we set high standards for performance and we are committed to our employees’ professional and technical development so we can grow together as we transform the future of finance.

We work to attract the best talent from a range of backgrounds and experiences in order to meet the current and future demands of our business.

As of December 31, 2024, we had approximately 2,300 full-time employees.

Robinhood aims to build an inclusive workplace where everyone feels valued and empowered to do their best work.

We invest in high quality tools and resources for the employee experience, especially in our office locations.

We also value the benefits of working in person and create office environments that foster collaboration and connection.

We also aim to support an inclusive community through ten Employee Resource Groups (“ERGs”) that, as of December 31, 2024, engage about 60% of our employees:

Asianhood, Black Excellence, Christianhood, Divergent, Latinhood, Parenthood, Rainbowhood, Sisterhood, Veterans at Robinhood, and Women in Tech.

Employee Incentives and Benefits

We offer competitive compensation for employees and benefits for themselves and their families.

To help foster our high performance culture, all employees are eligible for variable incentive pay (bonus and/or equity) and all of our compensation programs are directly linked to individual and company performance.

We offer highly competitive compensation for employees and benefits for themselves and their families.

To help foster our high performance culture, all employees are eligible for variable incentive pay

(bonus and/or equity) and all of our compensation programs are directly linked to individual and/or company performance.

Our comprehensive benefits are designed to attract the best talent and to ensure Robinhood employees are supported.

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our approach aims to support the diverse needs of our employees.

Some notable benefits that our employees value include lifetime fertility benefits, a flexible lifestyle wallet that can be used for wellness, education or any number of other benefits, generous paid family leave, retirement savings with employer match, and employer-paid health benefits.

Some notable benefits that our employees value include fertility benefits, a flexible lifestyle wallet that can be used for wellness, education or a number of other benefits, generous paid family leave, retirement savings with employer match, and employer-paid health benefits.

Intellectual Property

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In addition, we have a suite of defensively registered domain names.

believe that the protection of our trademark rights is an important factor in product recognition, protecting our brand, combating fraud, and maintaining goodwill.

We believe that the protection of our trademark rights is an important factor in product recognition, protecting our brand, combating fraud, and maintaining goodwill.

We believe the duration of our patents, trademarks, copyrights, and licenses is adequate relative to the expected lives of our products.

Litigation or proceedings before the U.S.

Patent and Trademark Office or other governmental authorities and administrative bodies in the United States and abroad may be necessary in the future to enforce our trademark rights and to determine the validity and scope of the trademark rights of others.

Patent and Trademark Office or other governmental authorities and

administrative bodies in the United States and abroad may be necessary in the future to enforce our trademark rights and to determine the validity and scope of the trademark rights of others.

Despite our efforts to obtain, maintain, protect, defend, and enforce our intellectual property rights, we cannot be certain that the steps we have taken will be sufficient or effective to prevent the unauthorized access, use, copying, or the reverse engineering of our technology and other proprietary information, including by third parties who might use our technology or other proprietary information to develop services that compete with ours, and our intellectual property rights might not be respected in the future or might be invalidated, circumvented, or challenged.

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laws and regulations apply to many key aspects of our current business operations and future business plans.

Failure to comply with these requirements may result in, among other things, revocation of required licenses or registrations, loss of approved status, private litigation, administrative enforcement actions, sanctions, civil and criminal liability, and constraints on our ability to continue to operate.

For additional information relating to regulation and regulatory actions, see “Risk Factors—Risks Related to Regulation and Litigation,” “Risk Factors—Risks Related to Cybersecurity and Data Privacy,” and “Risk Factors—Risks Related to Cryptocurrency Products and Services.”

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As broker-dealers, our subsidiaries Robinhood Securities, LLC (“RHS”) and Robinhood Financial LLC (“RHF”) are subject to extensive regulation by federal, state and SROs, and are subject to laws and regulations covering all aspects of the securities industry.

Federal, state and SROs, including the SEC and Financial Industry Regulatory Authority (“FINRA”), can, and in some cases have in the past, among other things, investigate, censure or fine us, issue cease-and-desist orders or otherwise restrict our operations, require changes to our business practices, products or services, limit our acquisition activities or suspend or expel a broker-dealer or any of its officers or employees.

Similarly, state attorneys general and other state regulators, including state securities and financial services regulators, can bring and have in the past brought legal actions on behalf of the citizens of their states to assure compliance with state laws.

Federal, state and SROs, including the SEC and Financial Industry Regulatory Authority (“FINRA”), can, and in some cases have in the past, among other things, investigate, censure or fine us, issue cease-and-desist orders or otherwise restrict our operations, require changes to our business practices, products or services, limit our marketing or acquisition activities or suspend or expel a broker-dealer or any of its officers or employees.

Similarly, state attorneys general and other state regulators, including state securities and financial services regulators, can bring and have in the past brought legal actions on behalf of the residents of their states to assure compliance with state laws.

In addition, criminal authorities such as state attorneys general or the U.S.

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Rule 15c3-1 (the “Net Capital Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”) specifies that at least a minimum part of a broker-dealer’s assets be maintained in a relatively liquid form.

If the Net Capital Rule is changed or expanded, or if there is an unusually large charge against our broker-dealer’s net capital, our operations could be limited.

A large charge or operating loss against our net capital could adversely impact our ability to maintain or expand current business, which could have a material adverse impact on our business and financial condition.

Changes to or expansion of the Net Capital Rule, or an unusually large charge against our broker-dealer’s net capital, could limit our operations.

See “—Risks Related to Our Business—We might need additional capital to provide liquidity and support business growth and objectives, and this capital might not be available to us on reasonable terms, if at all, might result in stockholder dilution, or might be delayed or prohibited by applicable regulations.” A large charge or operating loss against our net capital could adversely impact our ability to maintain or expand current business, which could have a material adverse impact on our business and financial condition.

If one of our regulated entities fails to maintain its required net capital, it may be subject to suspension or revocation of its registration by regulatory authorities and suspension or expulsion by these regulators could lead to the entity’s liquidation.

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We are also subject to regulation by the Consumer Financial Protection Bureau (the “CFPB”).

We have obtained or are in the process of obtaining licenses to operate as a money transmitter (or as another type of regulated financial services institution, as applicable) in the United States and in the states where this is required.

As a licensed money transmitter, we are subject to obligations and restrictions with respect to the investment of customer funds, reporting requirements, bonding requirements, and inspection by state regulatory agencies concerning those aspects of our business considered money transmission.

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Anti-Money Laundering and Counter-Terrorist Financing

We are subject to anti-money laundering (“AML”) laws and counter-terrorist financing laws and regulations in the United States, the United Kingdom and the EU.

We are subject to anti-money laundering (“AML”) laws and counter-terrorist financing laws and regulations in the United States, the U.K.

Under the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”), broker-dealers and money transmitters are required to “know your customer” and to monitor their customers’ transactions for suspicious transactions.

In the United Kingdom, the Financial Services and Markets Act 2000 is the primary regulation for all financial services in the United Kingdom.

This law enacts the Financial Conduct Authority as the main AML regulator and provides guidelines for its duties.

As required by the USA Patriot Act and other rules, we have established comprehensive AML, customer identification and transaction surveillance of customers designed to prevent our financial services from being used to facilitate money laundering, terrorist financing, and other illicit activity.

In the U.K., the Financial Services and Markets Act 2000 is the primary regulation for all financial services in the U.K.

This law designates the Financial Conduct Authority as the main AML regulator and provides guidelines for its duties.

As required by the USA Patriot Act and other rules, we have established comprehensive AML, customer identification and transaction surveillance designed to prevent our financial services from being used to facilitate money laundering, terrorist financing, and other illicit activity.

Our program is also designed to prevent our products and services from being used to facilitate business in countries, or with persons or entities, included on designated government sanctions lists, including lists promulgated by the U.S.

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Additionally, we have designed and implemented restrictions to prevent certain types of high-risk activity, including account opening fraud, and systems to identify potentially manipulative patterns of trading or higher risk patterns of money movements, and report such activities and transactions, where appropriate.

Our AML compliance program includes policies, procedures, reporting protocols, and internal controls, including the designation of AML compliance officers, and is designed to address these legal and regulatory requirements and to assist in managing risk associated with money laundering and terrorist financing.

Anti-money laundering regulations are constantly evolving.

We continuously monitor our compliance with AML rules and regulations and industry standards and implement policies, procedures and internal controls in light of current legal requirements.

Our AML compliance program includes policies, procedures, reporting protocols, and internal controls, including the designation of AML compliance officers.

This program is designed to address these legal and regulatory requirements, while managing risk associated with money laundering and terrorist financing.

Anti-money laundering regulations are constantly evolving, thus we actively monitor our compliance with AML rules and regulations and industry standards, and continuously implement policies, procedures, and internal controls in light of current legal requirements.

Cryptocurrency Regulation

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RHC also is registered with the Financial Crimes Enforcement Network.

The laws and regulations applicable to cryptocurrency are evolving and subject to interpretation and change.

The laws and regulations applicable to

cryptocurrency are evolving and subject to interpretation and change.

Therefore, our current and future cryptocurrency services may be or become subject to additional licensing and regulatory requirements by other state and federal authorities.

Data Privacy and Security

We are also subject to laws and regulations regarding data privacy and security;

We are also subject to a variety of federal, state, local, and non-U.S.

laws and regulations regarding data privacy and security.

In the U.S., federal law, such as the Gramm-Leach-Bliley Act of 1999 and its implementing regulations, restricts certain collection, processing, storage, use and disclosure of personal data, requires notice to individuals of privacy practices and provides individuals with some rights to prevent the use and disclosure of nonpublic or otherwise legally protected information.

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The New York State Department of Financial Services (“NYDFS”) also issued Cybersecurity Requirements for Financial Services Companies, which took effect in 2017, and which require banks, insurance companies, and other financial services institutions regulated by the NYDFS including RHC, to establish and maintain a cybersecurity program designed to protect consumers and ensure the safety and soundness of New York State’s financial services industry.

We are also subject to, or expect to be subject to, the General Data Protection Regulation, the Digital Operational Resilience Act, the ePrivacy Directive (including its national implementations), and other privacy, data security, and data protection laws and regulations in connection with our expansion into the U.K., the EU, and other jurisdictions.

Communications Regulation

We send texts, emails, and other communications in a variety of contexts, such as when providing digital receipts and marketing.

We send texts, emails, and other communications in a variety of contexts, such as when providing digital transaction confirmations and marketing.

Communications laws and regulations, including those promulgated by the Federal Communications Commission, apply to certain aspects of this activity in the United States and elsewhere.

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Robinhood Credit is subject to the regulatory and enforcement authority of the CFPB, as a facilitator, servicer or acquirer of consumer credit.

As a vendor to Coastal Bank, Robinhood Credit is also subject to examination by federal banking

regulators, such as the Federal Reserve Board, with respect to the marketing, customer screening and servicing activities undertaken by Robinhood Credit on Coastal Bank’s behalf.

As a vendor to Coastal Bank, Robinhood Credit is also subject to examination by federal banking regulators, such as the Federal Reserve Board, with respect to the marketing, customer screening and

servicing activities undertaken by Robinhood Credit on Coastal Bank’s behalf.

In addition, Robinhood Credit may be considered to qualify as a “debt collector” and federal, state and local statutes establish specific guidelines and procedures which debt collectors must follow when collecting consumer receivables.

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Authorized Activities in the U.K.

Robinhood U.K., Ltd.

(“RHUK”) is authorized and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom to carry on certain regulated activities related to the provision of investment services.

The FCA regulates the financial services industry in the UK.

Its role includes securing an appropriate degree of protection for consumers, protecting and enhancing the integrity of the UK financial system, and promoting effective competition in the interest of consumers.

If RHUK and/or its personnel fail to meet FCA standards, the FCA has a range of enforcement powers that it can use, including among other things, withdrawing a firm’s authorization, prohibiting and suspending firms and individuals from undertaking regulated activities, issuing fines, and bringing criminal prosecutions.

RHUK is authorized and regulated by the Financial Conduct Authority (“FCA”) in the U.K.

to carry on certain regulated activities related to the provision of investment services.

The FCA regulates the financial services industry in the U.K.

Its role includes securing an appropriate degree of protection for consumers, protecting and enhancing the integrity of the U.K.

financial system, and promoting effective competition in the interest of consumers.

If RHUK and/or its personnel fail to meet FCA standards, including, but not limited to, RHUK’s compliance with its obligations under Consumer Duty rules and guidelines, the FCA has a range of enforcement powers that it can use, including among other things, withdrawing a firm’s authorization, prohibiting and suspending firms and individuals from undertaking regulated activities, issuing fines, and bringing criminal prosecutions.

Cryptocurrency Regulation in the European Union

RHEC offers cryptocurrency services to eligible customers in select jurisdictions in the EU and is registered according to the regulatory requirements of the Republic of Lithuania as a virtual currency exchange and virtual currency depository wallet operator.

RHEC is supervised by the Lithuanian Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania.

RHEC is also registered under the applicable Polish law as a virtual assets service provider (“VASP”) in the Register of Virtual Currency Activities maintained by the Director of the Tax Administration Chamber in Poland.

RHEC is in the process of obtaining necessary authorizations and licenses to operate in other countries in the EU.

RHEC also intends to expand its offerings.

Failure to comply with applicable Lithuanian rules and regulations, and similar laws, rules and regulations in other EU countries could result in fines or other legal consequences for RHEC.

In addition, EU-level legislation imposing additional regulatory requirements in relation to crypto-related activities is also expected to take effect in the near term, with the adoption of the Markets in Crypto-Assets Regulation (“MiCA”).

Among other provisions, MiCA introduces

a comprehensive authorization and compliance regime for crypto asset service providers and a disclosure regime for the issuers of certain crypto assets, which is expected to impact our operations in the EU.

RHEU offers cryptocurrency services to eligible customers in select jurisdictions in the EU and is registered according to the regulatory requirements of the Republic of Lithuania as a virtual currency exchange and virtual currency depository wallet operator.

RHEU is supervised by the Lithuanian Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania.

RHEU is also registered under the applicable Polish, Italian, and Spanish laws as a virtual assets service provider in the Register of Virtual Currency Activities maintained by the Director of the Tax Administration Chamber in Poland, the Register of Bureaux de Change maintained by the Organismo Agenti e Mediatori in Italy, and the Registry of Providers of Virtual Currency Exchange Services for Fiat Currency and Custody of Electronic Wallets maintained by the Bank of Spain.

RHEU is in the process of obtaining necessary authorizations and licenses to operate in other countries in the EU.

RHEU also intends to expand its offerings.

Failure to comply with applicable Lithuanian rules and regulations, and similar laws, rules and regulations in other EU countries could result in fines or other legal consequences for RHEU.

In addition, EU-level legislation imposing additional regulatory requirements in relation to crypto-related activities is

also expected to take effect in the near term, due to the adoption of the Markets in Crypto-Assets Regulation (“MiCA”).

Among other provisions, MiCA introduces a comprehensive authorization and compliance regime for crypto asset service providers and a disclosure regime for the issuers of certain crypto assets, which is expected to impact our operations in the EU.

Futures and Commodity Industry Regulations

The principal operations of our subsidiary Robinhood Derivatives, LLC (“RHD”) are to facilitate trading of futures contracts, event contracts, and options on futures contracts for our customers.

RHD is registered with the CFTC as an FCM and is a member of the National Futures Association (the “NFA”).

RHD is also a registered swap firm with the CFTC for trading cleared swaps.

RHD is required to comply with a wide range of requirements imposed by the CFTC and the NFA.

The commodity futures, commodity options, and the cleared swaps industries in the U.S.

are subject to regulation under the U.S.

Commodity Exchange Act (the “CEA”).

The CFTC is the U.S.

federal agency charged with the administration of the CEA.

RHD is subject to the margin rules issued by the CFTC.

RHD is also subject to NFA regulation, including requirements pertaining to cybersecurity and supervision.

The CFTC has stringent rules and regulations with respect to the maintenance of specific levels of net capital required by regulated entities.

RHD is subject to the CFTC’s minimum financial requirements under the CEA.

Generally, a FCM’s capital is its net worth plus qualified subordinated debt less deductions for certain types of assets.

See “—Risks Related to Our Brokerage Products and Services— Our exposure to credit risk with customers, market makers, and other counterparties could result in losses.” A large charge or operating loss against RHD’s net capital could adversely impact its ability to maintain or expand current business, which could have a material adverse impact on its business and financial condition.

If RHD fails to maintain its required net capital, it may be subject to suspension or revocation of its registration by regulatory authorities and suspension or expulsion by these regulators could lead to the entity’s liquidation.

Anti-Bribery and Anti-Corruption Regulations

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Companies may also be subject to oversight by an independent consultant.

In the U.K., the Serious Fraud Office (“SFO”) has also published various policies and internal guidance documents for investigators and prosecutors considering bribery offenses.

In the U.K., the Serious Fraud Office has also published various policies and internal guidance documents for investigators and prosecutors considering bribery offenses.

The consequences for individuals and organizations found guilty of an offense under the Bribery Act can be serious.

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Environmental Protection Agency.

In addition, we are, or may become, subject to various climate disclosure regimes regulating the disclosure of green house gas (“GHG”) emissions and related information, such as the EU’s Corporate Sustainability Reporting Directive (“CSRD”) and California’s Climate Corporate Data Accountability Act and Climate Related Financial Risk Act.

The interpretation and enforcement of such climate disclosure regimes remains uncertain, and compliance may require the investment of significant resources, increase our costs, disrupt our business operations and pose reputational and other risks.

In addition, we are, or may become, subject to various climate disclosure regimes regulating the disclosure of green house gas (“GHG”) emissions and related information, such as the EU’s Corporate Sustainability Reporting Directive, California’s Climate Corporate Data Accountability Act and Climate Related Financial Risk Act, and the SEC’s final rules under SEC Release No.

34-99678 and No.

33-11275 entitled “The Enhancement and Standardization of Climate-Related Disclosures for Investors.” The interpretation and enforcement of such climate disclosure regimes remains uncertain, and compliance may require the investment of significant resources, increase our costs, disrupt our business operations and pose reputational and other risks.

AI Regulation

As we continue to expand into a global financial ecosystem, we are subject to laws, regulations, and industry standards that develop in response to the use of AI.

The EU’s AI Act, which became effective on August 1, 2024, governs the development, marketing, and use of AI in the EU and could impose significant additional costs on us to comply or we may face significant fines for failing to comply.

On a state level, in 2024 California enacted a range of laws regulating the use and development of AI, which generally relate to transparency, privacy and fairness, among other concerns, which may impact us.

The legal and regulatory landscape surrounding AI technologies is rapidly evolving and uncertain, including with respect to intellectual property ownership and licensing rights, cybersecurity, and data protection laws.

Available Information

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We use the “Overview” tab of our Investor Relations website (accessible at investors.robinhood.com/overview) and its Newsroom (accessible at newsroom.aboutrobinhood.com), as means of disclosing information to the public in a broad, non-exclusionary manner for purposes of the SEC’s Regulation Fair Disclosure.

Investors should

routinely monitor those web pages, in addition to our press releases, SEC filings, and public conference calls and webcasts, as information posted on them could be deemed to be material information.

Investors should routinely monitor those web pages, in addition to our press releases, SEC filings, and public conference calls and webcasts, as information posted on them could be deemed to be material information.

The contents of our websites are not intended to be incorporated by reference into this Annual Report or in any other report or document we file with the SEC, and any references to our websites are intended to be inactive textual references only.

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1. Business