What is in the checklist?

Two pages for an RIA owner below Fidelity's $100 million custody minimum: the test and who is measured, four questions to ask Fidelity this quarter, a household map, a calendar to the June 30, 2027 deadline, and the four paths, each with the work it carries.

Who does Fidelity's $100 million minimum apply to?

Fidelity's $100 million custody minimum is measured on the RIA firm that holds the custodial relationship, on the client assets that firm holds at Fidelity. An advisor who works under a larger firm's registration sits inside that firm's relationship, so the question is that firm's assets at Fidelity.

When is the deadline?

June 30, 2027. RIAs with less than $100 million in client assets at Fidelity must meet Fidelity's custody minimum by then or start moving to another custodian, and Fidelity has said it will keep servicing firms during the transition.

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Your Options Under Fidelity's $100 Million Custody Minimum

A two-page checklist for RIA owners below Fidelity's new $100 million custody minimum: the test, who is measured, the questions to ask Fidelity this quarter, and the four paths, each with the work it carries.

What's inside

Fidelity is applying a $100 million custody minimum to every RIA on its platform, and firms below it have until June 30, 2027 to meet it or begin moving. This checklist turns that into a plan: work out where your firm stands on the figure that counts, settle four questions with Fidelity, map your households, and choose among the four paths early enough to finish in time.

The test, measured on the assets your firm holds at Fidelity
Four questions to ask Fidelity this quarter
The four paths, each with its own checklist
What a custodian move involves, household by household

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The figure that counts

Fidelity's minimum is measured on the registered firm that holds the custodial relationship, and AdvisorHub reported that the figure that counts is the client assets the firm holds at Fidelity, so assets at other custodians do not count toward it. By Winthrop & Co.'s count from each firm's latest Form ADV, for firms registered as of September 2026, about 1,100 RIAs report less than $100 million at Fidelity, roughly 400 of them manage $100 million or more in total, and roughly 385 list Fidelity as their only custodian.

Four paths, and the work in each

A firm below the line can grow past $100 million, consolidate onto a custodian it already uses, move to a custodian without that minimum, or join a larger RIA that already custodies at Fidelity so client accounts can stay where they are. Every path except growth means paperwork for each household, which is why the count of households matters more than the dollar amount. The checklist is general information only.

Common questions

What is in the checklist?+
Two pages for an RIA owner below Fidelity's $100 million custody minimum: the test and who is measured, four questions to ask Fidelity this quarter, a household map, a calendar to the June 30, 2027 deadline, and the four paths, each with the work it carries.
Who does Fidelity's $100 million minimum apply to?+
Fidelity's $100 million custody minimum is measured on the RIA firm that holds the custodial relationship, on the client assets that firm holds at Fidelity. An advisor who works under a larger firm's registration sits inside that firm's relationship, so the question is that firm's assets at Fidelity.
When is the deadline?+
June 30, 2027. RIAs with less than $100 million in client assets at Fidelity must meet Fidelity's custody minimum by then or start moving to another custodian, and Fidelity has said it will keep servicing firms during the transition.