It also does not expect the program to be costly.

"We haven't set aside a large number," John Clendening, co-head of Schwab's retail brokerage, said when asked about the budget for the program.

Bing Waldert, a research director at Cerulli Associates, said he cannot imagine that many investors will bother filling out forms to get back a small fee, though he described the offer as unusual. "I can't decide if they're opening a can of worms or it's pure hype," he said. "It's probably a non-event."

The "accountability guarantee," according to Clendening, should open conversations with dissatisfied clients so that Schwab can provide more education or better service.

"It's a very expensive thing to have an unhappy customer," Charles Schwab said.

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