The Fidelity $100M Threshold by the Numbers: Which Independent RIAs Are Affected

FINTRX analysis of the latest Form ADVs identifies 986 independent RIAs that currently hold less than $100 million at Fidelity. These firms manage a combined $151.0 billion, including $37.2 billion custodied at Fidelity, and their custodian mix, team size, and distance from the threshold shape the options available to them ahead of the deadline.

The data also suggests that the path forward may be narrower than the minimum implies. Seventy-two percent of affected firms, or 706 independent RIAs, could not reach $100 million at Fidelity even if they consolidated every custodied dollar onto the platform, which means that for most of them, the deadline is less a question of whether to stay than of where to go.

Key Figures

Source: FINTRX analysis of Form ADVs

Most Firms Cannot Consolidate Their Way In

For independent RIAs that want to stay with Fidelity, the most direct path to the minimum is to move assets from other custodians onto the platform. FINTRX data shows that option is available to 280 of the 986 affected firms, or 28%. The remaining 706 report less than $100 million across all of their custodians combined, so consolidation alone cannot bring them to the threshold.

The 280 firms that can consolidate are, for the most part, established multi-custodian practices. All but one manage more than $100 million in total AUM, with a median of $230.4 million, and the median firm employs five people. Fidelity is typically a secondary relationship for this group: the median firm keeps 21% of its custodied assets at Fidelity, and only 51 hold a majority of their assets there. Schwab is the most common primary relationship, with 246 of the 280 firms holding a combined $58.3 billion at Schwab.

Qualifying would require meaningful asset movement. The median firm in this group holds $61.0 million at Fidelity and would need to move roughly $39.0 million from other custodians to reach $100 million. Ninety-seven firms are within $25 million of the threshold, while 58 would need to move more than $75 million. Across all 280 firms, reaching the minimum would mean shifting a combined $12.6 billion onto Fidelity, which in most cases means making Fidelity the firm's primary custodian.

The 706 firms that cannot qualify through consolidation present a different profile. The median firm reports one employee and holds $36.4 million across all custodians, $21.0 million of it at Fidelity. For most of these firms, Fidelity is already the primary relationship: 477 hold the majority of their custodied assets at Fidelity, and 354 use no other custodian. Together, these firms hold $21.8 billion at Fidelity.

An AUM Growth Path Exists for a Small Group

With roughly nine months until the deadline, growth is a realistic option for a small group of firms. The 71 advisers that already hold $90 million or more at Fidelity would need a median increase of about 5% in Fidelity-held assets to reach the threshold, and none would need more than 11%. Together, these firms hold $6.8 billion at Fidelity, and the 33 among them that use Fidelity as their sole custodian serve 10,481 client accounts.

These near-threshold firms divide evenly between two routes. Thirty-seven already hold enough across their custodians to qualify by consolidating, while the other 34, nearly all of them Fidelity-only practices, will need to close the gap through market appreciation, new client assets, or an acquisition. That second group includes Tudor Financial with $99.7 million at Fidelity, Crescent Wealth Advisory with $99.0 million, and Synergy Capital with $98.8 million.

Below that band, the growth path narrows quickly. Nearly two-thirds of affected firms (632 of 986) hold less than $50 million at Fidelity and would need to more than double those assets before the deadline, a level of growth that few advisory practices achieve in nine months.

Exposure is Concentrated Among the Smallest Practices

The firms affected by the new minimum are predominantly small. The median firm reports two employees, and 387 firms, or 39%, report one employee or none. Firms with two or fewer employees make up 59% of the affected population, hold $17.0 billion at Fidelity, or 46% of the assets at stake, and account for 73% of the firms that cannot qualify by consolidating.

The distance to the threshold widens sharply as team size falls. Solo advisers hold a median of $11.8 million at Fidelity and $27.1 million across all custodians, meaning the typical one-person firm would need to nearly quadruple its total custodied assets to qualify. Fidelity is also the primary relationship for most of these firms: 62% of solo advisers hold the majority of their custodied assets at Fidelity, compared with 15% of firms with 11 or more employees.

The operational burden of a transition is also heaviest at the smallest firms. At Fidelity-only practices, solo advisers manage a median of 72 client accounts per employee, more than double the 30 accounts per employee at firms with 11 or more staff. Because a custodian change requires new account documentation for every client, that work falls disproportionately on advisers with no operations support. The 354 Fidelity-only firms serve 57,790 client accounts in total, and more than half of those accounts (29,805) sit at firms with two or fewer employees.

Larger teams are positioned very differently. The 171 affected firms with six or more employees hold $8.9 billion at Fidelity, about a quarter of the total, and most already maintain a relationship elsewhere: 74% of firms with six to ten employees and 80% of those with 11 or more also custody at Schwab. With median total AUM of $229.8 million and $466.1 million, respectively, these firms are more likely to treat the minimum as a question of where to concentrate assets than whether they can meet it.

Firms with three to five employees sit between those groups and represent the largest pool of Fidelity assets by team size, at $11.3 billion. This segment also includes 28 firms already within $10 million of the threshold, more than any other band, making it the group where growth or partial consolidation is most likely to keep assets on the platform.

Larger Firms are Caught by the Asset Minimum as Well

Because the minimum counts only Fidelity-held assets, firm size alone does not determine exposure. FINTRX identified 337 affected firms, or 34%, that manage more than $100 million in total AUM but keep less than that amount at Fidelity. Together they hold $18.4 billion on the platform, roughly half of the $37.2 billion at stake.

For most of these firms, Fidelity is a secondary relationship. The median large firm keeps 25% of its custodied assets at Fidelity and the balance with another custodian.

Of the 337 firms, 279 hold enough across their custodians to qualify by consolidating onto Fidelity. For these firms, the decision is largely operational, weighing the cost of moving assets onto Fidelity against the simpler step of transferring a relatively small Fidelity balance to their primary custodian.

The Options for Affected Firms

Affected firms have five broad paths available before the deadline, and FINTRX data indicates how many are realistically positioned to take each one.

The data points to two outcomes that will likely account for most of the population. For the 632 firms that already use a second custodian, consolidating there is the path of least friction. The 354 Fidelity-only firms, by contrast, face either a full custodial transition or an exit from the business, and 70% of them report two or fewer employees to manage that process.

Their Existing Custodian Relationships

Schwab enters the transition with the largest existing footprint among affected firms. Of the 632 firms that already use a second custodian, 442, or 70%, hold the majority of their non-Fidelity assets at Schwab, and across all 986 firms, Schwab already custodies $63.3 billion, about 1.7 times what the same firms hold at Fidelity.

The 354 Fidelity-only firms are the least committed segment, with no existing relationship to fall back on, and 70% of them report two or fewer employees. Smaller custodians begin from more modest positions within this population, with Altruist custodying assets for 41 affected firms and Interactive Brokers for 35.

Geography

Affected firms are spread across 46 states, with the largest concentrations in California, Texas, and Florida. The figures below cover the 695 firms with a main office on file. FINTRX spot checks indicate that many of the remaining 291 operate from home offices with no listed headquarters, which is consistent with the solo-practice profile described above.

Reliance on Fidelity also varies by region. In the Northeast, 40% of affected firms use no other custodian, compared with 30% in the West. 

What to Watch Before June 30, 2027

• Firms near the threshold. Whether the 71 firms within $10 million of the minimum reach it through growth will indicate how much of the affected population is able to remain on the platform.
• Fee alternatives. If Fidelity offers a paid option to remain, as it has with past minimums, the calculation would change for firms close to $100 million.
• Introducing-broker access. Clarity on whether firms that reach Fidelity through third-party platforms are covered by the rule could open a route that keeps client accounts at Fidelity.
• Shifts in custodian share. Schwab already holds the largest non-Fidelity position at 442 affected firms, so the main open question is where the 354 Fidelity-only firms move.
• Small-firm consolidation. With 387 affected firms reporting one employee or none, sales and affiliations among small practices may increase ahead of the deadline.
  

FINTRX will continue to track quarter-by-quarter changes in custodied assets across all 986 firms as the deadline approaches.

Methodology

FINTRX identified independent RIAs reporting less than $100 million in custodied assets at Fidelity, combining balances reported under National Financial Services LLC and Fidelity Distributors Company LLC. Custodian balances, employee counts, and client accounts are drawn from the latest Form ADVs filed as of October 5, 2026, as captured in the FINTRX platform, and Schwab figures include assets that some firms still report under TD Ameritrade. Because custodied assets can be lower than total AUM, a firm is considered unable to qualify by consolidating if it reports less than $100 million across all custodians combined. Client account counts are reported at the firm level rather than by custodian, so this analysis cites account figures only for firms whose sole reported custodian is Fidelity.

FINTRX is a private wealth intelligence platform covering RIAs, family offices, broker-dealers, and private wealth teams, with firm- and contact-level data on custodians, holdings, AUM, and advisor movement.