More than 400 SEC-registered investment advisers report holding less than $100 million at Fidelity, the line Fidelity has drawn for keeping RIAs on its custody platform, according to a Financial ADVSR review of Form ADV filings published by the Securities and Exchange Commission. Together those firms reported more than $20 billion in client assets at Fidelity and around $300 billion in regulatory assets under management overall.
Fidelity told RIAs on Oct. 1 that they must hold at least $100 million in client assets with it by June 30, 2027, or move custody elsewhere. The threshold counts only assets held at Fidelity, not a firm's total assets under management. Fidelity has not disclosed how many firms the change affects.
The review used the custodian disclosures advisers make in Schedule D of Form ADV, where a firm lists each custodian holding at least 10% of its separately managed account assets and the dollar amount held there. More than 2,000 currently registered SEC advisers named a Fidelity entity in their most recent annual filing. Roughly four in five of them reported $100 million or more at Fidelity; about one in five fell below it.
Most of the SEC-registered firms under the line are not small overall. The large majority manage at least $100 million in total, and the typical firm in that group keeps only a small share of its assets at Fidelity. On paper, those firms could meet the minimum by consolidating accounts at Fidelity; the typical firm would need to move tens of millions of dollars. Roughly two-thirds of the firms below the line also list Charles Schwab as a custodian, with tens of billions of dollars there combined.
A smaller set has less room to maneuver. Several dozen of the firms list Fidelity as their only significant custodian, and a similar number manage less than $100 million in total, which means consolidating every account at Fidelity would still leave them short. Several dozen more sit within $10 million of the threshold. The typical firm below the line is a small practice with a handful of employees.
The SEC count is a floor, not a total. Most advisory firms that manage less than $100 million register with state securities regulators rather than the SEC, and the SEC says it does not have access to state-registered advisers' data. Those firms are likely to make up much of the group Fidelity is asking to leave, and they do not appear in these figures. RIABiz has estimated that the deadline could reach hundreds or thousands of advisors.
Competing custodians moved quickly after the announcement. Schwab, the largest RIA custodian, says it serves more than 11,000 firms under $100 million and has no published asset minimum; Schwab's Jon Beatty told RIABiz that more than 65% of new state-registered firms chose Schwab in 2025. Betterment is waiving platform fees through the end of 2028 for advisors who move, according to WealthManagement.com. Axos, which holds about $48 billion in RIA custody assets, said its sales team is calling Fidelity advisors. TradePMR's R. Scott Victoria said the firm has no strict asset minimums and offers a bulk account transfer tool, and Altruist CEO Jason Wenk said his firm can serve advisors of nearly any size.
Some industry figures have read the policy as a push to consolidate. Axos Securities executive Mike Watson told InvestmentNews that Fidelity is using the change as an opportunity to get firms to consolidate assets, and Betterment Advisor Solutions' Devon Klumb described it to AdvisorHub as a bid for assets those firms hold elsewhere. Fidelity has said it set the same minimum for new RIAs recently and is extending it to existing clients for consistency.
There is also a route that keeps small firms' assets on Fidelity's platform. Savvy Wealth launched a custody offering in late September with Fidelity as the backing custodian and said it would take smaller advisors, RIABiz reported, and Advisor Services Network offers infrastructure that lets sub-$100 million firms custody at Fidelity through its umbrella.
How we counted: Financial ADVSR used the SEC's monthly Form ADV filing data for October 2025 through September 2026, took each adviser's most recent filing, and kept firms listed as approved SEC registrants in the SEC's October 2026 adviser list. Fidelity entities included Fidelity Brokerage Services and National Financial Services; Fidelity's own affiliated advisers were excluded. Custodian amounts are as of each firm's fiscal year-end, usually Dec. 31, 2025, and custodians holding less than 10% of a firm's managed-account assets are not reported, so some firms with small Fidelity balances are not counted. Some firms that list National Financial Services may reach it through a broker-dealer rather than Fidelity's RIA custody business.