FastTrackr Research · October 2026

The $100M Line

What Fidelity’s custody minimum means for 1,087 advisors, and how the next nine months play out.

On October 1, 2026, Fidelity began telling advisory firms with less than $100M on its platform that their custody will end on June 30, 2027. We read the public filings of every retail advisory firm under $1B to see who is affected, where the money goes, and what the move takes.

Read the key findings
Below the line at Fidelity
1,087
registered investment advisers hold less than $100M at Fidelity.
$40.5B
Client assets those firms hold at Fidelity
393
Fidelity-only firms that must open a new custodian
~$33–39B
Estimated to leave Fidelity, across four scenarios · Estimated
Jun 30, 2027
when custody ends below the line
The short version

A letter, a deadline and 1,087 firms below the line

  1. 01

    Nearly half of Fidelity's small-firm users fall short.

    1,087 of the 2,286 firms in our study that use Fidelity hold less than $100M there. That count is a floor.

  2. 02

    Two kinds of firm face two different jobs.

    708 small firms keep almost everything at Fidelity. 379 larger firms keep only a small slice there.

  3. 03

    393 firms have no second custodian.

    They must open a new one from scratch. The other 694 can fold their Fidelity accounts into a custodian they already use.

  4. 04

    Most of the money goes to Schwab.

    An estimated $33–39B leaves Fidelity in every scenario we tested, and ~$24–27B of it lands at Schwab.

  5. 05

    Paperwork is the real limit, and it lands in tax season.

    We estimate ~376,000 documents (range 244,000–564,000). For a typical small firm, client signatures fall between March and May 2027.

  6. The story starts with the letter itself, and with how much of it is still unclear.

    Start reading

Form ADV lists only custodians that hold 10% or more of a firm’s separately managed assets, so some affected firms are not visible. Firm and asset counts are observed; flows and paperwork are Estimated. Source: SEC Form ADV; FastTrackr analysis.

01The letter

Fidelity set a firm date but left the edges open

The rule is simple. Several of the details that matter most are not.

Letters began reaching advisory firms around October 1, 2026. Firms that custody with Fidelity must hold at least $100M in client assets on the Fidelity platform, or the custody relationship ends after June 30, 2027. Trade press quoting the letter reports that “only assets held at Fidelity will be counted.”[1] A firm’s total assets under management do not help.

Fidelity called it a matter of consistency. It already asked new firms for $100M. A spokesperson said it is “now extending that criteria to existing custody clients.”[2] We found no Fidelity press release, FAQ or list of exceptions as of October 5.

That is unusual. Custodians have usually priced small firms out with fees rather than ended the relationship. Fidelity itself widened a small-firm platform fee in 2013. Raymond James raised its minimum for new firms in 2009 but kept existing ones.[6][7]

Nine months from the letter to the deadline

Oct 1
Letters arrive
Jun 30
Custody ends
Tax season
OctNovDecJanFebMarAprMayJun
Mar 31 Form ADV update due
Dates as reported; 268 days from Oct 5, 2026 to June 30, 2027. Tax season shown as Feb–mid-Apr 2027. Source: Fidelity letter as reported in trade press; FastTrackr analysis
View data
DateEvent
Oct 1, 2026Letters begin reaching advisory firms
Feb 1 – Apr 15, 2027Tax season
Mar 31, 2027Annual Form ADV update due for most firms
Jun 30, 2027Custody ends for firms below $100M at Fidelity

The calendar is tight. From October 5 there are 268 days left, and the annual Form ADV update is due March 31 for most firms, in the middle of tax season.

02Who is affected

Nearly half of Fidelity’s small-firm users are below the line

1,087 firms and $40.5B, spread across almost every state.

We started with every registered adviser, about 33,000 firms, and kept those that serve individual clients, report a custodian and manage under $1B. That left 16,332 firms. Of those, 2,286 use Fidelity, and 1,087 hold less than $100M there. Together they keep $40.5B at Fidelity.

Most firms are far from the line, but most of the money is close to it. 483 firms hold under $25M at Fidelity, yet together they hold less than a tenth of the dollars. At the other end, 192 firms sit within $25M of the line and hold 42% of the money. For some of them, moving other assets in could clear the bar.

Nearly half of Fidelity's small-firm users fall below the line

Retail RIAs under $1B that report a custodian16,332
List Fidelity as a custodian2,286
Hold under $100M at Fidelity1,087
Retail RIAs under $1B that report a custodian. 1,087 of 2,286 Fidelity users (48%). Source: SEC Form ADV; FastTrackr analysis
View data
StepFirms
Retail RIAs under $1B that report a custodian16,332
List Fidelity as a custodian2,286
Hold under $100M at Fidelity1,087

Many firms sit far below; most dollars sit close

FirmsShare of dollarsUnder $10M
332
3%
$10–25M
151
6%
$25–50M
226
20%
$50–75M
186
29%
$75–100M
192
42%
Affected firms by dollars held at Fidelity (n=1,087; $40.5B). 192 firms within $25M of the line hold 42% of the dollars. Source: SEC Form ADV; FastTrackr analysis
View data
Held at FidelityFirmsShare of $
Under $10M3323%
$10–25M1516%
$25–50M22620%
$50–75M18629%
$75–100M19242%

The problem is spread out. California has 132 affected firms, Texas 108, Florida 91, New York 68 and Massachusetts 53. No single city has more than 18. Few local markets will feel a wave; nearly every state will feel something.

Affected firms in 48 states and DC; five hold 42%

California132
Texas108
Florida91
New York68
Massachusetts53
Michigan41
Ohio40
Pennsylvania32
Colorado32
Virginia31
Affected firms by main office state, top ten (n=1,087). No single city has more than 18. Source: SEC Form ADV; FastTrackr analysis
View data
StateAffected firms
California132
Texas108
Florida91
New York68
Massachusetts53
Michigan41
Ohio40
Pennsylvania32
Colorado32
Virginia31
03Who is affected

The same rule creates two very different problems

For small firms it means a full move. For larger ones it means tidying up a side account.

The affected firms split almost evenly by dollars, but not by shape. 708 small firms (under $100M in total) hold $20.8B at Fidelity; the typical one keeps 99% of its custodied assets there. 379 larger firms clear $100M in total but not at Fidelity; they hold $19.7B there, yet the typical one keeps only 25% at Fidelity.

Small firms
Under $100M in total
Firms
708
$ held at Fidelity
$20.8B
Median clients per firm
~45
Median share of assets at Fidelity
99%
Larger firms
$100M+ in total, under $100M at Fidelity
Firms
379
$ held at Fidelity
$19.7B
Median clients per firm
~157
Median share of assets at Fidelity
25%

Medians. Source: SEC Form ADV; FastTrackr analysis.

Two composite firms show what that gap means in practice.

Composite firm

Jordan

The $50M solo planner

Firm AUM
~$50M
At Fidelity
~$48M
Second custodian
None
Clients
59 (~51 households)
Accounts
~128
Documents
~386 est.

Jordan runs a one-person, state-registered practice and keeps nearly everything at Fidelity, the firm's only custodian. There is nothing to consolidate. Every account must be opened somewhere new and moved: ~386 documents (Estimated; range 228–620).

Built from the 75 Fidelity-only affected firms with $40–60M under management. 67 are state-registered; 56 have two or fewer employees. Built from Form ADV medians; not a real firm.

Composite firm

Riley

The larger firm with a small Fidelity slice

Firm AUM
~$212M
At Fidelity
~$49M (21%)
At Schwab
~$135M
Team
5 people
Clients with Fidelity assets
~33 of ~168
Documents
~145 est.

Riley can fold its Fidelity accounts into Schwab, where it already works. That is ~29 households, ~72 accounts and ~145 documents (Estimated; range 102–200).

Built from the 254 larger affected firms whose main other custodian is Schwab. Built from Form ADV medians; not a real firm.

Jordan (one person, ~$48M at Fidelity) faces more than twice the paperwork of Riley (five people, ~$49M at Fidelity).

04Who is affected

Most firms have an easy move; 393 face the hard one

A second custodian turns a forced move into a transfer between accounts.

A firm’s starting point sets the size of the job. Firms that already use a second custodian can move their Fidelity accounts there. Fidelity-only firms need a new custody agreement, new technology links and new paperwork for every client before any money moves.

694 firms already use a second custodian. 393 are Fidelity-only, and most of those are small: 349 small firms holding $15.7B. Only 44 larger firms are Fidelity-only.

For firms that have a backup, it is mostly Schwab, which holds the most money for 480 of the 694. These are real relationships with real money in them: the typical larger firm in this group already holds $135M at Schwab, more than twice its Fidelity balance.

Nearly two in three firms already have a second custodian

Small firms (under $100M AUM)Larger firms
Already has a second custodian · Consolidate694
359
335
Fidelity-only · Open a new custodian393
349
44
Affected firms by whether another custodian holds 10%+ of client assets (n=1,087). Source: SEC Form ADV; FastTrackr analysis
View data
Starting pointSmall firmsLarger firmsTotal
Already has a second custodian359335694
Fidelity-only34944393

For firms with a backup, it is mostly Schwab

Schwab480
Altruist (Vanguard)40
Interactive Brokers25
AssetMark12
SEI11
All others126
Largest other custodian by dollars, among the 694 firms that already use a second custodian. Source: SEC Form ADV; FastTrackr analysis
View data
Largest other custodianFirms
Schwab480
Altruist (Vanguard)40
Interactive Brokers25
AssetMark12
SEI11
All others126
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05Where the money goes

Most of the money ends up at Schwab

Schwab wins mainly by default, because so many firms already use it.

We modeled where each firm’s Fidelity assets are likely to go. Firms with a second custodian move into it. Fidelity-only firms are split across five custodians, in line with where new small firms have gone since 2024. A small share joins a larger firm instead. All of these figures are estimates.

In the base case, ~$38.5B of the $40.5B leaves Fidelity. Schwab receives ~$25.9B directly, about two-thirds, and ~$15.5B of that comes from firms that already custody there. Altruist (Vanguard) is a clear second at ~$4.3B.

We tested three other scenarios: more firms joining larger firms, an early Savvy route, and larger firms moving assets into Fidelity. In every case ~$33–39B leaves Fidelity, 81–95% of the total, and Schwab receives ~$24–27B.

About two-thirds of the money lands at Schwab

Estimated
Schwab~$25.9B
Other existing custodiansRaymond James, Axos, Pershing, LPL and others~$4.6B
Altruist (Vanguard)~$4.3B
Interactive Brokers~$2.0B
Stays at Fidelity via a host firm~$2.0B
Schwab, via a host firm~$1.1B
SEI~$0.6B
Goldman Sachs Advisor Solutions<$0.1B
Base case. Where the $40.5B now at Fidelity goes, by destination. Altruist and Vanguard shown combined (deal pending). ~$15.5B of Schwab's total comes from firms that already custody there. Source: SEC Form ADV; FastTrackr estimates
View data
Destination$B (base case)
Schwab~$25.9B
Other existing custodians~$4.6B
Altruist (Vanguard)~$4.3B
Interactive Brokers~$2.0B
Stays at Fidelity via a host firm~$2.0B
Schwab, via a host firm~$1.1B
SEI~$0.6B
Goldman Sachs Advisor Solutions<$0.1B

$33–39B leaves Fidelity in every scenario

Estimated
Leaves FidelityStays at Fidelity
Base case~$2.0B stays
~$38.5B
More firms join larger firms~$3.5B stays
~$37.0B
Early Savvy route~$2.9B stays
~$37.6B
Larger firms consolidate into Fidelity~$6.4B stays
~$34.1B
Dollars leaving vs staying at Fidelity across four scenarios (n=1,087 firms; $40.5B). Source: SEC Form ADV; FastTrackr estimates
View data
ScenarioLeaves ($B)Stays ($B)
Base case~38.5~2.0
More firms join larger firms~37.0~3.5
Early Savvy route~37.6~2.9
Larger firms consolidate into Fidelity~34.1~6.4
06Where the money goes

The firms leaving Fidelity have places to go

Schwab is the largest. Altruist is growing fastest with new small firms.

The custodians that serve small firms best charge no custody fee and publish no minimum. Schwab, Altruist and Interactive Brokers fit both, which makes them the natural landing spots for small firms.

Schwab is used by two in three retail firms in our study, and its share of new small firms has held steady at about 65%. Altruist is smaller, but its share of new small firms more than doubled, from 9.5% to 22.1%. Interactive Brokers still reaches about one new small firm in eleven, but its share is falling. Fidelity was already losing ground with new small firms before the letter.

CustodianRetail firms using itNew small firms, ≤2021 → 2024–26Published minimumCourting small firms
Schwab67%66% → 65%NoneYes, explicit
Fidelity14%8.5% → 6.2%$100M at Fidelityn/a
Altruist (Vanguard)8%9.5% → 22.1%NoneYes, explicit
Interactive Brokers8%13.9% → 9.3%NoneFactual only
SEI2%2.3% → 1.5%None foundNone found
Goldman Sachs Advisor Solutionsunder 1%~1.1% → 0.3%Not disclosedNone found
Betterment (not modeled)1%1.9% → 1.9%NoneFactual only

Altruist alone in the cohort column; Vanguard’s purchase of Altruist is pending. Betterment is shown but not modeled: it reprices on January 1, 2027 and has made no recruiting statement. Retail firms using it: share of 16,332 firms in the study. New small firms: under $100M, by registration year (n = 6,472 and 1,445). Source: SEC Form ADV; FastTrackr analysis; custodian pricing pages.[11]

Altruist more than doubled its share of new small firms

2021 and earlier2024–26
Schwab66% → 65%
Fidelity8.5% → 6.2%
Altruist9.5% → 22.1%
Interactive Brokers13.9% → 9.3%
SEI2.3% → 1.5%
Goldman Sachs Advisor Solutions~1.1% → 0.3%
0%20%40%60%
Share of new small firms (under $100M) listing each custodian, by registration cohort: 2021 and earlier (n=6,472) vs 2024–26 (n=1,445). Altruist alone; Vanguard deal pending. Source: SEC Form ADV; FastTrackr analysis
View data
Custodian≤20212024–26
Schwab66.3%64.7%
Fidelity8.5%6.2%
Altruist (Vanguard)9.5%22.1%
Interactive Brokers13.9%9.3%
SEI2.3%1.5%
Goldman Sachs Advisor Solutions1.1%0.3%

On October 1, Schwab’s head of advisor services called small firms “the backbone of the independent advisory profession.”[2] Altruist’s chief executive said the firm could serve advisors leaving Fidelity.[4] No custodian had published a Fidelity-specific offer, such as fee waivers, by October 5.

Picking a custodian is the easy part. Moving the clients is where the time goes.

07The paperwork wall

The real bottleneck is paperwork, and it lands in tax season

Assets move in days. The forms before the transfer take months.

Every move needs two sets of papers: the custodian’s account paperwork and the advisory firm’s own client documents. What changes from move to move is how much custodian paperwork is needed. Opening a new custodian is the heaviest: about three forms per account, plus a firm agreement.

Documents per account, by type of move

Estimated
Custodian formsFirm documents
Consolidate~2.0
Open a new custodian~3.0
Join a firm, keep Fidelity~2.6
Join a firm at Schwab~4.6
Base case. Typical documents per account by type of move; joiners also sign firm documents. Source: SEC Form ADV; FastTrackr estimates
View data
MoveCustodian forms / accountFirm documents / account
Consolidate2.00.0
Open a new custodian3.00.0
Join a firm, keep Fidelity1.01.6
Join a firm at Schwab3.01.6
~58,000
households
~146,000
accounts
~376,000
documents
~151,000
client conversations

Estimated, base case, all 1,087 firms. Document range 244,000–564,000. Source: SEC Form ADV; FastTrackr estimates.

The load is lopsided. Small Fidelity-only firms are about a third of affected firms but carry ~48% of the documents. They are also the firms least likely to have operations staff.

Jordan's signatures land in tax season

Estimated
Tax season
Decide the path
Sign up with the new custodian
Collect data, prepare forms
Client meetings and signatures
Transfers in waves
FastTrackr span
OctNovDecJanFebMarAprMayJun
Jordan: composite $50M solo planner, ~$48M at Fidelity, no second custodian, ~51 households. Base case: ~128 accounts, ~386 documents. Illustrative dates. Source: SEC Form ADV; FastTrackr estimates
View data
StepFromTo
Decide the path2026-10-012026-11-30
Sign up with the new custodian2026-12-012027-02-01
Collect data, prepare forms2027-01-152027-03-01
Client meetings and signatures2027-03-012027-05-15
Transfers in waves2027-05-012027-06-15
08The four paths

Four paths, side by side

Each path trades paperwork against independence and certainty.

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).

Every path open to Jordan means 330 or more documents

Estimated
Join a larger firm that keeps Fidelity~333 (272–413)
Open a new custodian~386 (228–620)
Wait for Savvy (if confirmed)~386 (228–620)
Join a larger firm at Schwab~590 (408–856)
0200400600800
Jordan: composite $50M solo planner, ~$48M at Fidelity, no second custodian, 59 clients (~51 households). Dot = base case; bar = low–high range. Consolidating is not an option for Jordan. Source: SEC Form ADV; FastTrackr estimates
View data
PathLowBaseHigh
Join a larger firm that keeps Fidelity272333413
Open a new custodian228386620
Wait for Savvy (if confirmed)228386620
Join a larger firm at Schwab408590856
09What to do

What to do between now and June

A firm that decides by late November can finish signatures by mid-May.

These steps are vendor-neutral. The dates are working targets for a small firm, not rules. Only June 30, 2027 comes from Fidelity.

  1. 1Decide
    Oct–Nov 2026
    • By Oct 31, 2026Confirm the number held at Fidelity, not total assets under management.
    • By Oct 31, 2026List every household, account and account type, with beneficiaries, bank links and standing instructions.
    • By Nov 15, 2026Ask Fidelity, in writing, how offboarding works and whether any network or broker route changes the picture.
    • By Nov 30, 2026Choose a path. Compare fees, minimums, technology links and written transition support.
  2. 2Prepare
    Dec 2026–Feb 2027
    • By Dec 15, 2026Sign the custody agreement and connect CRM, billing, trading and reporting.
    • By Jan 15, 2027Update Form ADV Part 2A, the advisory agreement and Form CRS where needed.
    • By Feb 1, 2027Tell clients early, in a short letter. Order households from simplest to most complex.
  3. 3Sign and move
    Mar–Jun 2027
    • By Mar 1, 2027Prepare every form before the first meeting, to cut rejected paperwork.
    • By May 15, 2027Finish signatures. Use e-signature where the custodian accepts it.
    • By Jun 15, 2027Transfer in waves, fix rejects, and confirm cost basis and standing instructions.

Frequently Asked Questions

No. The letter, as reported, counts only assets held at Fidelity.
Yes, if it has assets elsewhere. 307 affected firms would clear $100M if they moved their other custodied assets to Fidelity.
Not yet known. Fidelity has not said whether its test applies to firms that reach it through an introducing broker.
Fidelity says the custody relationship ends. It has not published offboarding details, so firms should ask in writing.
Our analysis of SEC Form ADV filings finds 1,087 retail advisory firms under $1B that hold less than $100M at Fidelity, together holding $40.5B there. Because Form ADV lists only custodians holding 10% or more of a firm’s separately managed assets, that count is a floor.

Planning a move? Tell us.

A firm like Jordan’s (a $50M solo practice, ~$48M at Fidelity, no second custodian) faces ~386 documents (Estimated) and a deadline that runs through tax season. Advisors planning a move can share four things with us:

  • Current custodian
  • Likely destination or path
  • Rough number of accounts
  • Target completion date

How FastTrackr helps, whichever way a firm moves

An advisor may stay at Fidelity by joining another firm, join a firm that custodies elsewhere, or move existing accounts to a new custodian. In every case FastTrackr does the repapering: all the custodian paperwork and all the firm paperwork, across custodians and firms, for every account in bulk.

  1. 1
    Share the four details.
    FastTrackr maps which custodian and firm forms each account needs for that move.
  2. 2
    Collect the data once.
    Household and account data comes in from CRM exports, spreadsheets or statements, with a view of only what is still missing.
  3. 3
    Get signature-ready paperwork.
    Validated packages go to DocuSign in one step, or as filled PDFs for wet signatures.

Disclosure: FastTrackr provides transition and re-papering software to advisers and may benefit from the transitions described in this report.

How we did this

Counts come from our own analysis of public SEC Form ADV data: the SEC roster of September 1, 2026 and the state feed of October 1, 2026. The study covers 16,332 retail firms under $1B that report a custodian. “Affected” means a firm lists Fidelity in Schedule D, Item 5.K(3), with less than $100M there. Small firms manage under $100M in total; larger firms manage $100M or more. Fidelity-only means no other custodian at 10% or more.

Observed counts are exact. Flows and workload are modeled and marked Estimated; they rest on stated assumptions about joining rates, households and forms per account. Third-party estimates appear only as cross-checks. Jordan and Riley are composites built from Form ADV medians, not real firms. No affected firm is named.

Sources

  1. [1]AdvisorHub, “Fidelity to Drop RIAs Below $100M Custody Minimum,” 2026-10-01
  2. [2]Financial Planning, “Fidelity says it will end custody relationships with RIAs under $100M,” 2026-10-01
  3. [3]Financial Advisor Magazine, “Fidelity To Small RIAs: Find Another Custodian,” 2026-10-01
  4. [4]WealthManagement.com, “Fidelity to Raise Custody Asset Minimum to $100M,” 2026-10-01
  5. [5]Winthrop & Co., “Fidelity’s $100M Custody Minimum for RIAs: Your Four Options,” 2026-10-02
  6. [6]InvestmentNews, “Fidelity zaps more RIAs with fee,” 2013-10-09
  7. [7]PlanAdviser, “Raymond James Ups AUM Requirement for New RIAs,” 2009-10-29
  8. [8]WealthManagement.com, “Tech-Based Custodian Altruist Sells to Vanguard,” 2026-08-26
  9. [9]Business Wire, “Savvy Wealth Announces the Launch of Savvy Custodial Platform,” 2026-09-23
  10. [10]AdvisorHub, “Savvy Wealth to Offer Fidelity-Based ‘Custody’ Platform to Outside RIAs,” 2026-09-23
  11. [11]Financial Planning, “Why SEI’s 0.10% custody fee stands out from giant custody rivals,” 2026-07-21
  12. [12]Financial Planning, “IBKR’s custody pitch to RIAs focuses on low fees, growth potential,” 2026-09-09
  13. [13]Financial Planning, “For RIA custody, Betterment’s platform fees will begin at 0.20%,” 2026-09-28

Primary data: SEC Form ADV (SEC monthly roster, 2026-09-01; IAPD state feed, 2026-10-01). The appendix lists all 158 sources consulted.