What Does Fidelity's $100 Million RIA Custody Minimum Mean for Your Firm?

The short answer: Fidelity is raising the minimum for RIAs that custody client assets with it to $100 million. Firms below that level have until June 30, 2027 to reach it or begin moving, and Fidelity has said it will support firms through the transition. The minimum applies to the RIA firm itself, the one with its own Form ADV and its own Fidelity relationship. A firm below the line generally has four paths: grow past $100 million, consolidate onto another custodian it already uses, move to a custodian without that minimum, or join a larger RIA that already custodies at Fidelity.

What Fidelity announced

In a letter reported on October 1, 2026, Fidelity's custody business told advisors it is raising its minimum to $100 million in client assets for all RIAs. Fidelity had already set that threshold for firms new to the platform, and its spokesperson described the change as extending it to existing firms for consistency. Firms below $100 million have until June 30, 2027 to meet the requirement or start moving to another custodian, according to the letter, which the company confirmed to WealthManagement.com; a spokesperson told AdvisorHub that Fidelity will otherwise discontinue the custodial relationship.

Fidelity framed the decision as part of a regular review of its business model and client relationships, and said it remains committed to servicing firms during the transition. Its spokesperson said the company has committed to giving firms time to evaluate their options. Fidelity has not said how many firms are affected.

Nine months is the working window. Firms that start the decision this quarter keep every option open; firms that wait until spring may find the choice narrowing to whichever move can be finished in time.

Who the minimum applies to

The minimum is measured on the registered firm: the RIA with its own Form ADV and its own custodial relationship with Fidelity. A solo advisor or small team that runs its own registered firm and custodies at Fidelity is the one being measured. According to AdvisorHub, the figure that counts is the client assets the firm holds at Fidelity; assets at other custodians do not count toward it. A firm managing $150 million with $60 million at Fidelity is below the line.

An advisor who works as an investment adviser representative under a larger firm's registration sits inside that firm's relationship with the custodian. That includes advisors at corporate RIAs and at platforms that hold the registration on the advisor's behalf; a hybrid advisor whose advisory business runs through an RIA of their own is measured on that RIA. Fidelity's announcement is addressed to registered firms, so for an advisor under someone else's registration the likely question is whether that firm meets the minimum on the assets it holds at Fidelity. A large firm that spreads assets across several custodians can still hold less than $100 million there, so it is worth asking.

The firms with the most work ahead are RIAs with less than $100 million at Fidelity that custody most or all of their client assets there. A firm that already uses a second custodian has a shorter path. Fidelity has not said publicly how the minimum treats firms that reach its platform through an introducing broker-dealer, so a firm in that position should ask.

How many firms this touches. Fidelity has not published a count. Winthrop & Co. counted them from each firm's latest Form ADV, for firms registered as of September 2026: SEC-registered firms from the SEC's monthly Form ADV data, and state-registered firms, which include most RIAs of this size, from their own filings on the SEC's adviser search site. About 3,000 RIAs list Fidelity as a custodian. About 1,100 of them report less than $100 million in separately managed account assets at Fidelity, and roughly 400 of those manage $100 million or more in total, so firm size alone does not clear the line. Roughly 385 of the 1,100 list Fidelity as their only custodian. Form ADV names a custodian where it holds 10% or more of a firm's separately managed account assets and reports the amount held there, which is the closest public measure of assets at Fidelity.

The four paths, side by side

Grow past $100 million

A firm close to the line may reach it in time. Organic growth alone may not close a large gap in nine months, so firms in this position often look at bringing in another advisor's practice. That is an acquisition or merger, with its own valuation, agreements and client transition, and it needs to close early enough to count.

Consolidate onto a custodian you already use

A firm that already custodies some accounts elsewhere can move its Fidelity accounts there. Because the minimum counts assets at Fidelity, consolidation can also run the other way: a firm whose total client assets are above $100 million can bring the accounts it holds elsewhere onto Fidelity. Either way, the firm keeps its registration and its clients. Each household still signs new account documents and has its assets transferred, so the work depends on how many households sit at Fidelity today.

Move to a custodian without that minimum

Some custodians serve smaller firms without that threshold. Moving means opening the new custodial relationship, then repapering every household: new account applications, asset transfers, re-established standing instructions and money movement, and reconnected technology for trading, billing, performance reporting and the CRM. Clients receive new statements from a new name. How custody actually works explains what the custodian does day to day, which is the list of things that has to be rebuilt.

Join a larger RIA that custodies at Fidelity

A larger RIA that already custodies at Fidelity and meets the minimum can take in a smaller firm's practice. Client accounts can stay at Fidelity, and the advisor keeps serving the same households. Clients become clients of the larger firm under its Form ADV, so each client consents to the change, usually by signing a new advisory agreement under the larger firm's process. Advisory contracts with an SEC-registered firm must bar assignment without the client's consent (section 205 of the Advisers Act); most firms below $100 million are registered with their state, whose rules govern their contracts. What the advisor keeps, the name, the team, the economics and any equity, is set by the agreement with the larger firm. Start or join an RIA compares joining and tucking in with running your own firm.

This is the path Winthrop helps with. We work through which larger firms fit a practice, what each would offer, and how the move would run, and the advisor never pays us.

What a custodian move involves

Whichever path involves new accounts, the work is the same list for every household:

1. New account paperwork at the receiving custodian, signed by the client.
2. Transfer of assets, in kind where possible, and a check that nothing was left behind.
3. Re-established standing instructions, recurring contributions and distributions, and any linked bank accounts.
4. Reconnected technology: portfolio management, trading, billing, performance reporting and the CRM.
5. A conversation with each client about the change, before the new statements arrive.

The count of households drives the effort more than the dollar amount. A $60 million firm with 300 households carries more work than a $90 million firm with 80.

What to do this quarter

• Confirm the number. Know the firm's client assets at Fidelity today and where they are likely to be by June 2027.
• Map the households. Count accounts by type and complexity, since that sets the size of any move.
• Talk to Fidelity. Ask your relationship contact how and on what date the firm will be measured, how long servicing continues after June 30, 2027 for a firm that is mid-move, and what transition support looks like.
• Decide the path early. Each of the four takes time, and the ones that involve another advisory firm add a search and an agreement before any client paperwork starts.

What is a small RIA covers the economics of running a firm at this size, which is often the real question behind the custody decision.

If joining a larger firm that already custodies at Fidelity is on the table, the specific answer comes from a conversation: which firms fit your clients, what each would offer, and what you would keep. Request an introduction.