Fidelity's $100M RIA custody minimum impacts almost 1,000 firms

Nearly 1,000 independent registered investment advisors face a hard deadline to either grow, consolidate, or find a new custodian and new data shows most cannot do either of the first two.

Fidelity Investments announced it is extending its $100 million custody minimum, which previously applied only to new RIA relationships, to existing clients on the platform. Firms that do not meet the threshold by June 30, 2027, have been asked to wind down their custodial relationship with Fidelity. A company spokesperson confirmed the deadline to InvestmentNews.

Who gets caught by the minimum

Analysis from private wealth intelligence firm FINTRX, drawing on Form ADVs filed as of October 5, 2026, identified 986 independent RIAs that currently hold less than $100 million in assets at Fidelity. Together, those firms manage a combined $151.0 billion in total assets, of which approximately $37.2 billion sits on the Fidelity platform.

The data reveals a structural problem for the majority: 72 percent of affected firms (706 of the 986) report less than $100 million across all their custodians combined, meaning consolidation alone cannot bring them to the threshold regardless of where they hold assets. Only 280 firms, or 28 percent, hold sufficient total custodied assets to qualify by moving balances from other custodians onto Fidelity.

The affected group skews small. The median firm employs two people, and 387 firms (about 39 percent) report one employee or none. Some 354 firms use Fidelity as their only custodian and serve a combined 57,790 client accounts, more than half of which sit at practices with two or fewer employees.

That concentration matters operationally. A custodian change requires new account documentation for every client, and at 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.

The consolidation math

Among the 280 firms that could qualify by consolidating, the median practice custodies just 21 percent of its total assets at Fidelity, with Schwab the most common primary relationship: 246 of those 280 firms hold a combined $58.3 billion at Schwab.

For firms in that group to qualify, they would need to shift a median of approximately $39 million onto the Fidelity platform, in most cases making Fidelity their primary custodian.

A narrow window before 2027

For the 71 firms within $10 million of the threshold, an organic growth path remains realistic. Those practices would need a median increase of approximately five percent in Fidelity-held assets to qualify, and none would require more than an 11 percent increase.

For the 632 of the 986 that already use a second custodian, consolidating at that existing relationship is the path of least friction and Schwab already holds the 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 market for RIA custody alternatives has expanded in recent years, giving advisors in transition more options than they would have had a decade ago. Fidelity has said it remains committed to supporting firms through the transition process.

FINTRX said it will continue tracking quarter-by-quarter changes in custodied assets across all 986 affected firms as the June 2027 deadline approaches.