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SEC Company Response from WEALTHFRONT (WLTH) — Dec 9, 2025

WEALTHFRONT CORP
Date: Dec. 9, 2025 · CIK: 0001524566 · Accession: 0001628280-25-055960

Offering / Registration Process Regulatory Compliance Business Model Clarity

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File numbers found in text: 333-290583

Date
December 9, 2025
Author
Danielle Freeman
Form
CORRESP
Company
WEALTHFRONT CORP

Letter

Document Goldman Sachs & Co. LLC 200 West Street New York, New York 10282 J.P. Morgan Securities LLC 383 Madison Avenue New York, New York 10179 December 9, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Robert Arzonetti Susan Block Victor Cecco Marc Thomas Re: Wealthfront Corporation Registration Statement on Form S-1 File No. 333-290583 Acceleration Request Requested Date: December 11, 2025 Requested Time: 4:00 P.M. Eastern Time To the addressees set forth above: In accordance with Rule 461 under the Securities Act of 1933, as amended (the “ Securities Act ”), we, as representatives of the several underwriters (the “ Representatives ”), hereby join in the request of Wealthfront Corporation (the “ Registrant ”) for acceleration of the effective date of the above-referenced Registration Statement, requesting effectiveness as of 4:00 P.M., Eastern Time, on December 11, 2025, or at such later time as the Registrant or its outside counsel, Fenwick & West LLP, may request via telephone call to the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission. Pursuant to Rule 460 under the Securities Act, we, as the Representatives, wish to advise you that we will take reasonable steps to secure adequate distribution of the preliminary prospectus to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement. We, the undersigned, as the Representatives, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. [ Signature Page Follows ] Sincerely, As Representatives of the several underwriters GOLDMAN SACHS & CO. LLC By: /s/ Danielle Freeman Name: Danielle Freeman Title: Managing Director J.P. MORGAN SECURITIES LLC By: /s/ David Vaimberg Name: David Vaimberg Title: Executive Director, Commercial & Investment Banking [ Signature Page to Underwriters’ Acceleration Request ]

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CORRESP
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 Document Goldman Sachs & Co. LLC 200 West Street New York, New York 10282 J.P. Morgan Securities LLC 383 Madison Avenue New York, New York 10179 December 9, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Robert Arzonetti Susan Block Victor Cecco Marc Thomas Re: Wealthfront Corporation Registration Statement on Form S-1 File No. 333-290583 Acceleration Request Requested Date: December 11, 2025 Requested Time: 4:00 P.M. Eastern Time To the addressees set forth above: In accordance with Rule 461 under the Securities Act of 1933, as amended (the “ Securities Act ”), we, as representatives of the several underwriters (the “ Representatives ”), hereby join in the request of Wealthfront Corporation (the “ Registrant ”) for acceleration of the effective date of the above-referenced Registration Statement, requesting effectiveness as of 4:00 P.M., Eastern Time, on December 11, 2025, or at such later time as the Registrant or its outside counsel, Fenwick & West LLP, may request via telephone call to the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission. Pursuant to Rule 460 under the Securities Act, we, as the Representatives, wish to advise you that we will take reasonable steps to secure adequate distribution of the preliminary prospectus to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement. We, the undersigned, as the Representatives, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. [ Signature Page Follows ] Sincerely, As Representatives of the several underwriters GOLDMAN SACHS & CO. LLC By: /s/ Danielle Freeman Name: Danielle Freeman Title: Managing Director J.P. MORGAN SECURITIES LLC By: /s/ David Vaimberg Name: David Vaimberg Title: Executive Director, Commercial & Investment Banking [ Signature Page to Underwriters’ Acceleration Request ]