Fidelity Investments is extending its $100 million custody minimum to existing RIA clients, setting a June 30, 2027 deadline for firms to meet the threshold or wind down their custodial relationship. The move, confirmed by a company spokesperson, affects nearly 1,000 independent registered investment advisors, according to new data from private wealth intelligence firm FINTRX.
FINTRX analysis of Form ADVs filed as of October 5, 2026, identified 986 RIAs with less than $100 million in assets held at Fidelity. These firms collectively manage $151.0 billion in total client assets, with approximately $37.2 billion custodied on Fidelity's platform. The data reveals a structural challenge: 706 of the 986 firms (72%) report less than $100 million across all custodians combined, meaning they cannot consolidate their way to the threshold. Only 280 firms (28%) hold sufficient total custodied assets to qualify by moving balances from other custodians.
The affected firms are predominantly small practices. The median firm employs two people, and 387 firms (39%) report one or zero employees. Notably, 354 firms use Fidelity as their sole custodian, serving a combined 57,790 client accounts. At these Fidelity-only practices, solo advisors manage a median of 72 client accounts per employee—more than double the rate at firms with 11 or more staff. This concentration raises operational concerns, as a custodian switch requires repapering every client account.
For the 280 firms that could qualify by consolidating, the median practice holds just 21% of its total assets at Fidelity. Schwab emerges as the most common primary custodian, with 246 of those firms holding a combined $58.3 billion at Schwab. To meet Fidelity's threshold, these firms would need to shift a median of approximately $39 million onto the Fidelity platform, in most cases making Fidelity their primary custodian—a significant change in their operational setup.
However, a narrow window exists for some. Seventy-one firms are within $10 million of the threshold, requiring a median increase of about 5% in Fidelity-held assets to qualify; none would need more than an 11% increase. For the 632 firms already using a second custodian, consolidating at that existing relationship is the path of least friction. Schwab already holds a dominant position, custodying assets for 442 of those firms.
The 354 Fidelity-only firms face the most complex transition. With no existing custodian relationship to fall back on, they must identify a new platform, negotiate terms, and repaper every client account before the deadline. The broader RIA custody market has expanded in recent years, offering more alternatives than a decade ago. Fidelity has stated it remains committed to supporting firms through the transition process.
This development comes amid broader industry shifts. For context, Schwab has raised minimums on certain SMA products, and Fidelity reported record retirement balances in Q2 2026. Advisors navigating these changes may also consider new tools for 401(k) advice as they reassess custodial relationships.
