Fidelity’s $100M RIA Minimum: What Small RIAs Should Know
Fidelity’s $100M Custody Minimum: What Small RIAs Should Know Before June 30, 2027
If you run a small independent RIA, there is a decent chance October started with a letter you did not expect. Fidelity is raising the minimum it asks of the advisory firms it custodies for, and plenty of advisors are now asking the same question over their morning coffee: what does this actually mean for my practice, and how much time do I have?
Here is the plain-English answer. Fidelity is moving to a $100 million minimum for all RIAs on its custody platform, and firms below that line have until June 30, 2027 to meet it or begin moving off the platform. That gives most affected firms around eight months to choose a path, and the decision is worth making calmly rather than in a rush.
Photo: Tony Webster via Wikimedia Commons, CC BY 2.0
What exactly did Fidelity change?
A custodian is the firm that actually holds your clients’ accounts and assets, while you, the advisor, manage them. Fidelity had already been asking new advisory firms to bring $100 million, and it is now extending that to everyone. As WealthManagement.com reported on Oct 1, 2026, Fidelity is “raising its minimum threshold to $100 million for all RIAs,” up from a previous $15 million threshold set back in 2008. Firms below the new minimum “have until June 30, 2027, to meet the new requirement or start the process of moving off the platform.”
Fidelity framed the change as a business review and promised a runway. In its words, “We recognize that change requires thoughtful planning,” and the company says it has committed to giving firms time to evaluate their options.
Photo: Behnam Norouzi via Unsplash, Unsplash License
Who is affected?
The honest answer is that nobody outside Fidelity knows the exact number. A Fidelity spokesperson described the group as “a few hundred firms,” according to a follow-up from WealthManagement.com on Oct 7, 2026. The same report notes that one data provider, working from Form ADV filings (the public disclosure document every registered adviser files), estimated a figure closer to 1,000 before pulling its post while it waited for clarification from Fidelity.
For context, the affected firms make up less than 1% of the roughly $5.8 trillion in assets Fidelity clears and custodies across about 3,300 RIAs, family offices and broker-dealers. That is a small slice for Fidelity, and a very big deal if your firm happens to be in it.
There is one reassuring detail, too. Fidelity told WealthManagement.com that “the majority of the firms that will be affected are also multi-custodial,” meaning many already keep some client accounts at a second custodian. If that describes you, part of the groundwork may already be done.
The three paths small RIAs are weighing
Most of the industry commentary so far lands on the same three options. Financial Planning laid them out on Oct 6, 2026, and each comes with real tradeoffs.
Stay at Fidelity by joining a larger firm
Some networks and aggregators already meet the minimum, so joining one can keep your Fidelity relationship intact. The catch is in the fine print. Will Trout of Datos Insights pointed out that “if the aggregator files separately for each acquired firm, the RIA doesn’t benefit from scale,” so it is worth confirming exactly how assets are reported. You will also want to understand how much ownership, control and revenue you would be giving up in exchange.
Move to, or add, another custodian
This is the path most firms are researching, and custodians have noticed. WealthManagement.com reported that several are actively courting affected advisors. Schwab says it has no asset minimum and already works with more than 11,000 firms under $100 million, and Betterment is waiving its platform fee through the end of 2028 for advisors who opt in by June 30, 2027. Financial Planning also notes that Interactive Brokers and Altruist have no asset minimum for custodial clients, and Altruist has agreed to be acquired by Vanguard. If you want a wider list, Financial Planning published a roundup of RIA custody options that also covers BNY Pershing, SEI and others, with what is publicly known about their pricing.
Switching does take work. Every client account has to be repapered (new account forms and agreements signed at the new custodian), and as InvestmentNews put it on Oct 26, 2026, that process takes time and can test client goodwill. Ola Abdul, founder and CEO of a London-based wealth platform, summed up the effort this way: “Changing custodians is a one-off project with real costs, mainly client communication and staff time.”
Grow past $100 million
Growing your way over the line keeps everything as it is, which is appealing. It also depends on adding clients or acquiring a firm on a fairly tight clock. Consultant Tim Welsh told Financial Planning he doubts most firms can count on getting there in time, and Trout added a sobering point: even a firm that reaches $100 million in time has no guarantee the bar will stay there. Abdul offered a gentler version of the same caution: “Racing to $100 million just to keep a custodian is the wrong reason to grow.”
Questions to ask any custodian or platform you’re considering
Whichever path you lean toward, a short list of questions will save you a lot of second-guessing later. These are worth putting to every option on your shortlist, in writing where possible.
Is there an asset minimum today, and has it changed in the last few years?
How do you make money from my firm and my clients (custody fees, platform fees, cash sweep, trading)?
What does account opening look like for a brand new client, from first form to funded account?
How long does a typical transition take, and who on your side does the repapering work?
Which tools in my current stack (CRM, planning, rebalancing, reporting) connect to you today?
If I ever want to leave, what does that process look like?
That last one comes straight from Welsh, whose advice to Financial Planning readers was simple: “Know how they get paid, get commitments in writing, and always know how you’d leave.” He also suggested keeping relationships with more than one custodian where you can. Speaking to WealthManagement.com, he added that $100 million is best treated as a first cutoff, since the threshold “could continue to be raised by Fidelity and potentially others.”
A planning checklist for the next eight months
June 2027 sounds far away until you count the client meetings between now and then. A rough plan, worked backward from the deadline, might look like this:
This month: confirm your firm’s assets on the Fidelity platform and whether your letter applies to you. If you already use a second custodian, note which clients sit where.
By the end of the year: decide which of the three paths you are seriously exploring, and build a shortlist of two or three options.
Early 2027: run your questions past each option, compare fees and service, and check how each one handles opening accounts for new clients, which is the part of the process you will repeat the most.
Spring 2027: make the call, then plan your client communication before any paperwork goes out. Clients take change much better when they hear about it from you first.
Before June 30, 2027: finish transitions or confirm your growth or affiliation plan is on track, and keep notes on every decision for your compliance file.
Whatever you decide, this is also a natural moment to look at how your firm onboards net new clients. The custodian question gets the headlines, but the day to day experience of opening accounts, setting up portfolios and keeping everyone’s paperwork tidy is what you and your clients will live with for years.
Frequently asked questions
What is Fidelity’s new minimum for RIAs?
Fidelity is raising its custody minimum to $100 million in assets for all RIAs on its platform. It had already applied that level to new firms, and the previous threshold for existing firms dated back to 2008 at $15 million.
When is the deadline?
Firms below the minimum have until June 30, 2027 to meet it or start moving off Fidelity’s custody platform, as reported by WealthManagement.com on Oct 1, 2026.
How many firms are affected?
Fidelity has described it as “a few hundred firms.” Outside estimates based on Form ADV data have been higher, so the exact number is not public.
What are my options if my firm is under $100 million?
Most commentary points to three paths: join a larger firm or network that already meets the minimum, move to or add another custodian, or grow past $100 million before the deadline. Each one has tradeoffs in cost, control and effort.
Do other custodians have asset minimums?
It varies. Schwab, Interactive Brokers and Altruist have each been reported as having no asset minimum, but terms change, so confirm minimums and fees in writing with any custodian you consider.
Tell us how you run your practice
At Surmount Wealth, we are talking with small independent RIAs about how they set up and serve new clients, and we are forming a small founding cohort to learn alongside. If you would like to share how your firm works today, join the waitlist and start a conversation with our team.
This content is educational and general. It is not investment, legal, or tax advice, is not a recommendation to buy or sell any security, and does not consider your individual circumstances. Any securities or strategies mentioned are illustrative only. Consult a qualified professional about your situation.
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