What did Fidelity announce?
Fidelity told RIAs on Oct. 1, 2026 that firms with less than $100 million in client assets custodied at Fidelity must reach that level by June 30, 2027 or discontinue their custodial relationship with the firm, according to AdvisorHub and Financial Planning.
Fidelity had recently set the same $100 million minimum for new RIAs joining its platform. AdvisorHub reported that the company is now applying it to existing custody clients for consistency. Financial Planning described it as the first time the requirement has been applied to firms already on the platform.
In its notice, Fidelity said it recognizes that change requires thoughtful planning and that firms need time to determine next steps. It also said it remains committed to servicing firms that choose to move assets to another custodian during the transition, Financial Planning reported. A source familiar with the move told AdvisorHub that Fidelity has no immediate plans to raise the minimum further.
What counts toward the $100 million?
The test is based on client assets held at Fidelity, not total assets under management. A firm that manages $500 million but keeps $60 million at Fidelity falls below the line.
Winthrop & Co. notes in its brief on the rule that the minimum applies to the registered RIA that holds its own Form ADV and custodial relationship. Advisors who work under a larger firm's registration are measured against that firm's Fidelity holdings, not their own book.
How many firms are affected?
Fidelity has not disclosed how many firms received the notice. A Financial ADVSR review of SEC Form ADV filings found more than 400 SEC-registered RIAs that report less than $100 million at Fidelity, holding more than $20 billion there in total. That is roughly one in five of the SEC-registered advisers that name Fidelity as a custodian.
Most of those firms manage $100 million or more overall and keep only part of their assets at Fidelity. About two-thirds also use Charles Schwab, and several dozen list Fidelity as their only significant custodian.
The count does not include state-registered advisers, which file with state regulators rather than the SEC. Many of the smallest firms are state-registered, so the SEC data doesn't show the full count.
Has Fidelity set small-firm thresholds before?
Yes. WealthManagement.com reported that Fidelity previously charged a $2,500 quarterly fee to firms with under $15 million, and more recently stopped accepting new firms below $100 million. The October notice extends that newer standard to all existing RIAs on the platform.
Schwab has its own history on the issue. RIABiz reported that Schwab once charged small RIAs a $10,000 annual custody fee and eliminated it in 2020.
How has the industry reacted?
Reaction from consultants and advisors has been largely critical. Michael Kitces of XY Planning Network called the decision short-sighted, Financial Planning reported. Tim Welsh of Nexus Strategy called it a dramatic move and noted that some affected advisors have been with Fidelity since the start and never grew; he told WealthManagement.com the $100 million level may not be the last change.
Devon Klumb of Betterment Advisor Solutions described the minimum to AdvisorHub as a play to get more from firms that keep client assets elsewhere. Bill Capuzzi of Apex told RIABiz that some small RIAs will be big RIAs one day. Fidelity told WealthManagement.com that its position in combined clearing and custody remains strong.
What are other custodians saying?
Schwab says it has no asset minimum and serves more than 11,000 firms with under $100 million in assets, according to Financial Planning and WealthManagement.com. Jon Beatty, head of Schwab Advisor Services, called small RIAs the backbone of the independent advisory profession.
Betterment said it will waive platform fees through the end of 2028 for Fidelity advisors who switch, with an opt-in deadline of June 30, 2027, WealthManagement.com reported. Betterment Advisor Solutions has no minimum, according to AdvisorHub.
Altruist has no asset minimum, Financial Planning reported, and is being acquired by Vanguard. TradePMR told RIABiz it has no strict asset minimums and offers an account transfer tool. Axos Advisor Services said it welcomes advisors of all sizes, and its sales team is reaching out to Fidelity-custodied advisors, WealthManagement.com reported.
What options do firms below the minimum have?
Some intermediaries offer access to Fidelity custody through their own arrangements. WealthManagement.com reported that Advisor Services Network, with about $11 billion in assets, lets sub-$100 million firms custody with Fidelity through membership in its RIA network.
Savvy Wealth launched a custodial platform for outside RIAs on Sept. 23, 2026, shortly before Fidelity's notice. Savvy acts as the introducing broker-dealer, while Fidelity's National Financial Services handles clearing, execution and custody, according to WealthManagement.com. Public reports did not state a minimum for the platform.
Winthrop & Co. lists four paths for firms below the line: grow past $100 million organically or through an acquisition, consolidate onto another custodian the firm already uses, move to a custodian without the minimum, or join a larger RIA that already custodies at Fidelity.
According to Winthrop & Co., a custodian change requires clients to sign new account paperwork, assets to be transferred, standing instructions and money movement to be re-established, and trading, billing and reporting technology to be reconnected. Clients also typically need to hear from the firm before statements from a new custodian arrive.