Fidelity extends its $100 million custody minimum to 986 existing RIA relationships

Fidelity Investments has extended its $100 million custody minimum to the advisory relationships already on its platform, giving the 986 firms below it until June 30, 2027 to reach the number or wind down. The threshold previously applied only to RIAs new to the custodian, and the company confirmed the deadline to InvestmentNews.

An analysis by private wealth intelligence firm FINTRX of Form ADVs filed as of October 5, 2026 puts those firms at $151.0 billion in total client assets, with about $37.2 billion of that at Fidelity—under a quarter of the group's book and the whole of what the minimum measures.

The ADVs show why the deadline cuts deeper than a routine growth target: 706 of the 986, or 72 percent, report less than $100 million across every custodian they use combined, so consolidating the accounts they already hold cannot produce the threshold because the assets to consolidate do not exist. The other 280 have enough total custodied assets to reach $100 million at Fidelity, but getting there requires pulling balances off other platforms and, in most cases, making Fidelity the primary custodian.

The median practice employs two people, and 387 firms—about 39 percent—report one employee or none, a thin staffing base that makes the problem sharper. Among the 354 that custody only at Fidelity sit 57,790 client accounts, more than half at practices with two or fewer employees.

Custody is a contract, and moving it means new account documentation for every client at every account, filed with the new custodian—a workload the Fidelity-only cohort is particularly ill-staffed to absorb. At single-custodian practices, solo advisors carry a median of 72 client accounts per employee, more than double the load at firms with 11 or more staff. The fewest hands hold the most paper, which suggests a good share of those 57,790 accounts will move only as part of an ownership change.

For the 280 firms with room to qualify, the question is where the assets come from. The median practice in that group keeps just 21 percent of its total assets at Fidelity, and Schwab holds a combined $58.3 billion as the most common primary relationship for 246 of them; clearing the minimum would require the median firm to shift roughly $39 million onto Fidelity, which in most cases means promoting Fidelity to primary and demoting the incumbent.

Only a narrow slice can grow into compliance: 71 firms sit within $10 million of the threshold, and a median increase of about 5 percent in Fidelity-held assets would do it, with none needing more than 11 percent. That is roughly seven percent of the affected group with a realistic organic route, and their progress is the figure to watch when the next round of ADVs is filed.

For most of the list, escape looks easier than growth: 632 of the 986 already run a second custodian, so the hard part of a move is re-papering rather than choosing a platform, and Schwab holds assets for 442 of those firms. Adding the 354 Fidelity-only practices splits the group in two—one half already on a competitor's rails with the switch half-made, the other holding accounts that exist nowhere else and staffing ratios that turn a move into a capital event.

PWD reported on October 3 that the June 2027 deadline had already made sub-scale firms sale candidates, with Concurrent announcing its first platform purchase and HB Wealth closing a Texas deal in the same week. The ADV data supplies the seller-side logic: the $151.0 billion spread across 986 firms works out to an average of about $153 million apiece against a median payroll two people deep, a combination that makes these books plausible acquisition targets and leaves the deadline's most durable effect on ownership rather than on where accounts sit.

Fidelity's rationale is missing from the ADV data, which explain only who is affected; the concentration at stake is the $37.2 billion that either grows on the platform or leaves with the firms that cannot reach the number, and either outcome leaves Fidelity's roster of relationships shorter than it was.

In one respect the data cut against Fidelity: of the 280 relationships with enough assets to qualify, 246 already bank primarily with Schwab, and of the 632 that run a second custodian, 442 hold assets there. A firm told to consolidate onto one platform gets to choose which one, and the relationship it already knows is on the table.

Between now and June 30, 2027, two numbers matter: whether the 71 firms within $10 million of the threshold grow into it without leaving Fidelity, and how many of the 442 Schwab relationships finish a move that is already mostly documented. For the 706 that cannot reach $100 million by consolidating anywhere, the menu runs to growing, moving the book to a custodian with a lower bar, or selling—and the staffing arithmetic at these practices argues against the first.