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RIA

Merrill sets data and shelf fees for third-party managers, up to $1.4 million

The Bank of America unit's updated Form ADV disclosures state a financial incentive to recommend products from firms that pay for data analytics, according to RIABiz.

Third-party asset managers who want Merrill Lynch's brokers to see their products, and with luck to recommend them, will soon be able to buy that visibility at a published price, because the Bank of America subsidiary has created two fees for outside managers—data and shelf charges, as RIABiz characterizes them in reporting published Sept. 29. The data analytics fee runs between $125,000 and $860,000 per firm, per year for information on actively managed products, including ETFs, mutual funds, annuities and model portfolios, and a manager can buy as much as $860,000 a year in incentives through one of the fees, or reach $1.4 million by taking both. The schedule takes effect Jan. 1, 2027.

Merrill's annual fee menu for third-party managers
Fixed dollars, billed per firm regardless of assets
Both fee tiers, maxed out$1.4M
Data analytics fee, high end$860K
Data analytics fee, low end$125K
RIABIZ, SEPT. 29, 2026 · MERRILL FORM ADV FEE SCHEDULE

The last mover's price list

The fee schedule is a menu presented to brokers shopping investments for their clients, with the new fees deciding which outside managers appear alongside in-house and big-house products; the pricing reads differently for an asset manager because the charges are levied in absolute dollars rather than as a share of assets—which RIABiz notes makes for a huge nut for small firms to crack. A percentage fee scales with the prize; a flat one does not. The invoice is identical whether the manager's book is large or small, so the structure rations shelf space toward firms that can spread the toll across the widest asset base, and away from the smaller managers whose capacity-constrained strategies are often what independent advisors go looking for.

The shelf fee prices the recommendation

The second fee buys a manager a leg up over third-party rivals that decline to pay, though Merrill's stated position is that broker incentives will not shift and the brokers' own compensation is not being rearranged. The firm's updated Form ADV filings say something more pointed about Merrill's own: that it will have a financial incentive to make available and recommend products from third-party firms that pay fees for data analytics over those that do not, according to RIABiz, and the same updates promise the arrangement will eliminate the current bias against third parties and produce a playing field that is more level, if not level.

A line item for shelf space

Analysts quoted by RIABiz read the leveling claim skeptically, describing the result as short of a genuine fix, though they give Merrill credit for the sequencing: the wirehouse moved later than its peers, which lets it gauge how much asset managers will pay before the business starts to suffer. A last mover can watch where the first movers found the ceiling and price just beneath it, though the peers who went first are not named in the reporting and the price points they set are not disclosed.

What the ADV language does is turn a negotiation into a schedule: managers who used to angle for attention through wholesaler relationships, conference sponsorships and the slow accumulation of performance now have a line item with a number attached, and a firm writes a fee into its disclosure when it expects that fee to be paid. What the incentive tier actually delivers—the specific placement, ranking or attention behind it—RIABiz's account does not spell out.

Merrill is charging for the recommendation—the moment a broker weighs one product against another for a client—rather than for the assets, which is the layer this publication has argued is the contested ground in platform economics; the scarce asset in wealth management is the advisor relationship, not the disclosed book, and the shelf fee is a price for renting a piece of one. Whether custodians and turnkey platforms in the independent channel will publish a comparable schedule is not something this reporting establishes, but the logic travels: whoever stands between a manager and a recommendation can price the introduction.

For RIA principals the effect is indirect and still worth tracking, since they do not buy through Merrill's platform and no invoice arrives. But a manager's distribution budget is finite, and dollars committed to a wirehouse shelf are dollars not spent on the wholesaler coverage of the independent channel that most advisory firms experience as service. The bet a manager makes in paying is that visibility converts into enough sales through the channel to cover a fixed toll, and that payback arithmetic is harsher for a narrow or capacity-limited strategy than for a broad lineup. Nothing in the disclosure promises a place on the list, and where the cost finally lands—in a fund's expense structure or in the manager's own margin—is not visible from here. The price of being seen in one channel went up, in fixed dollars that a small manager must earn back.

There is a timing question in selling access to the thundering herd, because PWD's tracking logged a run of Merrill team liftouts and advisor moves in the second half of September, and our reporting on the firm's $1.2 billion Santa Fe hire documented a four-person service bench arriving with it, and a $550 million business-owner specialist who left in the same dispatch. Managers are being asked to pay for proximity to a sales force that is plainly in motion, while the fee schedule is not: it takes effect on a fixed date and will bill the same amount whether the herd grows, shrinks or holds.

The number to watch is the top of the schedule—how many managers take both tiers at $1.4 million, because that will establish the going rate for a broker's attention and whether the last mover priced it right.

A percentage fee scales with the prize; a flat one does not.
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