Every affected firm has the same four options. Which one fits depends on whether the firm already has a second custodian and how much it values its independence.
01
Consolidate
into a custodian already in use
- Best fit
- Firms with a second custodian
- Firms it fits
- 694
- Paperwork
- ~2 forms per account
- Keeps Fidelity?
- No. But 307 could move other assets into Fidelity and stay.
Main risk: Clients asked to move for a reason that is not theirs
02
Open a new custodian
start a fresh custody relationship
- Best fit
- Fidelity-only firms
- Firms it fits
- 393
- Paperwork
- ~3 forms per account, plus a firm agreement
- Keeps Fidelity?
- No
Main risk: Longest setup; signatures in tax season
03
Join a larger firm
give up your own registration
- Best fit
- Owners ready to give up their own registration
- Firms it fits
- Any. ~12% of Fidelity-only firms in our base case (Estimated)
- Paperwork
- ~1 form per account, plus 4 firm documents per household
- Keeps Fidelity?
- Yes, if the host uses Fidelity
Main risk: Loss of independence. Few hosts take books under $100M.
04
Wait for an alternative
e.g. Savvy, on Fidelity clearing
- Best fit
- Firms willing to bet on an unconfirmed route
- Firms it fits
- Unknown
- Paperwork
- Treated like a new custodian
- Keeps Fidelity?
- Possibly, on Fidelity clearing
Main risk: Fidelity has not confirmed it. Onboarding opens early-to-mid 2027.
Joining a larger firm is the only sure way to keep Fidelity custody, but it does not avoid paperwork: it swaps custodian forms for a full set of new client agreements. Few hosts publish an entry point for small firms; Savvy’s advisor recruiting cites a $25M book.
Waiting is the riskiest choice. Savvy launched its platform on September 23, cleared and custodied at Fidelity, but outside firms can only join a waitlist and pricing is not final.[9][10]
For Jordan (the $50M solo planner with ~$48M at Fidelity and no second custodian), consolidating is not an option. The lightest remaining path, joining a host that keeps Fidelity, still means ~333 documents (Estimated).