Fidelity's $100M RIA Custody Minimum: Your Options
Short answer: The Fidelity RIA custody minimum is $100 million in client assets held at Fidelity. Fidelity has extended the rule, which used to apply only to new RIAs, to existing firms, and RIAs below it must meet the minimum or end their custody relationship by June 30, 2027, according to a Fidelity spokesperson quoted by InvestmentNews. Firms below the line can grow or consolidate assets, add or switch custodians, or affiliate with a larger RIA that already custodies at Fidelity.
Key takeaways
- Deadline: June 30, 2027.
- Only assets held at Fidelity count, not your total AUM.
- FINTRX counts about 986 independent RIAs below the line, and only about 28% could close the gap by consolidating assets.
- Options: consolidate, switch or add custodians, or affiliate with a larger RIA or platform.
What changed with the Fidelity RIA custody minimum?
Fidelity already required new RIAs to bring at least $100 million in custody assets. In October 2026 it told existing RIA clients the same minimum now applies to them, with a June 30, 2027 deadline to meet it or discontinue the relationship.
Fidelity says the change affects a few hundred firms, representing less than 1% of its roughly $5.8 trillion in clearing and custody assets across about 3,300 RIAs, family offices and broker-dealers.
Does the $100M minimum mean total AUM?
No. The test is assets custodied at Fidelity. A firm managing $150 million that keeps only $75 million at Fidelity is still below the line, which is why larger multi-custodian firms are affected too.
Who is affected by the Fidelity custody minimum?
| Measure (FINTRX, Oct 2026) | Figure |
|---|---|
| Independent RIAs below $100M at Fidelity | About 986 firms |
| Could reach the minimum by moving assets from other custodians | About 280 firms (28%) |
| Manage more than $100M in total assets | About 337 firms (34%) |
| Within $10M of the minimum | About 71 firms (7%) |
Sources: InvestmentNews (Fidelity spokesperson, October 2026); WealthManagement.com; FINTRX analysis of Form ADV data (October 2026); American Banker; Financial Planning. Custodian terms change often, so confirm current terms directly with each custodian.
What are your options before June 2027?
1. Consolidate or grow into it. If you use several custodians, moving assets to Fidelity may clear the bar. Organic growth or buying a small practice can close a narrow gap, but the deadline is tight.
2. Add or switch custodians. Several custodians report no firm-level asset minimum, including Schwab and Interactive Brokers, and some are offering incentives; Betterment, for example, is waiving its platform fee through 2028 for Fidelity RIAs that add it. Compare fees, technology, service and trading costs, not just the minimum. Repapering clients is real work.
3. Affiliate with a larger RIA or platform. Joining a platform RIA or a larger firm that already custodies at Fidelity can let you pool assets and keep Fidelity. Terms vary widely: some arrangements let you keep your brand and ownership, while others involve selling equity.
4. Rethink the model. Some small RIAs use the moment to join an independent broker-dealer or hybrid platform that supplies custody, compliance and technology. See our guide to going independent for how the models compare, or download the free Financial Advisor Transition Report 2026.
How to compare a custodian switch with an RIA affiliation
| Question | Switch custodian | Affiliate with a platform |
|---|---|---|
| Keep Fidelity? | No (or only partly) | Often yes, through the larger firm |
| Keep ownership and brand? | Yes | Depends on the deal terms |
| Cost | Custody fees and trading costs vary | Platform fee or revenue share |
| Client disruption | Full repapering | Usually less, if assets stay at Fidelity |
| Extra support | Little | Compliance, technology, sometimes investment and marketing help |
Fidelity RIA custody minimum: what to do now
- Measure your Fidelity-held assets and how far you are from $100 million.
- Decide what you will not give up: Fidelity, ownership, brand or cost.
- Get quotes from at least two custodians and two platforms so you can compare real terms.
- Plan client communication early. Clients handle a custody change better with time and a clear reason.
- Leave room before June 30, 2027. Repapering and platform onboarding take months.
Below $100M at Fidelity? Compare your options confidentially
We will lay out custodian, platform and affiliation paths side by side, at no cost to advisors.
FAQ: Fidelity RIA custody minimum
What is the Fidelity RIA custody minimum?
It is $100 million in client assets custodied at Fidelity. Existing RIAs below that level must meet it or discontinue their Fidelity custody relationship by June 30, 2027.
Does the Fidelity minimum count total AUM?
No. Only assets held in custody at Fidelity count toward the $100 million minimum.
Can I keep Fidelity if my RIA is under $100 million?
Possibly, by consolidating assets onto Fidelity or by affiliating with a larger RIA or platform that already meets the minimum and custodies at Fidelity.
Do other custodians have asset minimums?
Some do and some do not. Schwab and Interactive Brokers are reported to have no firm-level asset minimum, but fees and terms differ, so compare current terms directly.
Can UpTick help an RIA affected by the Fidelity minimum?
Yes. We help advisors compare custodian moves, RIA platforms and affiliation offers side by side, at no cost to advisors.
About the author: Marc Elia is the founder of UpTick Consulting Partners, a financial advisor recruiting firm and transition consultancy in Red Bank, New Jersey. He works with experienced advisors and teams weighing a move between wirehouses, regional firms, independent broker-dealers, hybrid RIAs and independent RIAs.
About UpTick Consulting Partners: UpTick is paid by receiving firms, so its consulting is at no cost to advisors. UpTick is not an investment advisor and does not provide investment, tax or legal advice. 646.734.0334 · marc@uptickrecruiting.com · uptickrecruiting.com