As custody requirements evolve, independent RIA owners face important decisions about maintaining control, preserving client relationships, and positioning their businesses for the future.
The independent registered investment advisor (RIA) industry has long been built around the idea that advisors should have the flexibility to operate their businesses in ways that best serve their clients. But as the industry grows and evolves, the infrastructure supporting that independence is changing.
Fidelity Investments’ decision to extend its $100 million custody minimum to existing RIA relationships is one example of that shift. For some independent firms, the change introduces an unexpected decision about how to maintain their current operating structure, preserve established client relationships, and determine the right path forward.
While the immediate issue centers on custody, the broader conversation extends to the future of independence and the resources firms need to sustain it.
Understanding Fidelity’s New Custody Requirements
Fidelity has announced plans to require existing RIA custody clients to maintain at least $100 million in assets on its platform by June 30, 2027. Firms that do not meet the requirement may face the discontinuation of their custodial relationship.
Importantly, the minimum is based on assets held at Fidelity, not a firm’s total assets under management (AUM). An RIA managing more than $100 million across multiple custodians could therefore still fall below the threshold.
For affected firms, the change creates a need to evaluate both immediate operational considerations and longer-term business priorities.
A custodial relationship is often deeply integrated into an advisory firm’s day-to-day operations, from account administration and investment management to technology workflows and client servicing. Changing that relationship can require substantial planning, making it important for advisors to understand their options before taking action.
Evaluating the Options Available to Independent RIAs
There is no single approach that will be appropriate for every firm. An advisor’s existing custodial relationships, business structure, growth objectives, and client needs will all influence the decision.
Several potential paths warrant consideration.
- Evaluate Opportunities to Meet the New Minimum
For firms using multiple custodians, one option may be to evaluate whether additional client assets could appropriately be consolidated at Fidelity.
This requires considering client preferences, investment needs, operational implications, and whether consolidation supports the firm’s broader strategy.
For firms without sufficient assets to meet the threshold, however, this may not be a practical solution.
- Explore Alternative Custodial Relationships
Another option is to evaluate custodians whose service models and requirements may be better aligned with the firm’s size and needs.
While changing custodians may provide a viable long-term solution, advisors should carefully assess the potential implications for clients, account transitions, technology integrations, service capabilities, and business continuity.
The objective should extend beyond identifying an available custodian to finding a relationship that supports the firm’s ability to serve clients effectively.
- Consider an Established RIA Platform or Affiliation Structure
For some advisors, evolving custody requirements may create an opportunity to revisit their broader business structure.
Affiliating with an established RIA platform may provide access to institutional relationships, integrated technology, operational support, compliance resources, and additional professional capabilities.
Depending on the arrangement, an advisor may be able to preserve important elements of their independence, including their brand, client relationships, and day-to-day business management.
However, affiliation structures vary considerably. Advisors should evaluate the implications for regulatory oversight, ownership, economics, operational control, and client experience.
Importantly, joining a larger platform does not automatically guarantee continued access to a particular custodian. Eligibility and custody arrangements must be evaluated and confirmed based on the specific circumstances.
Independence Is About More Than an Operating Structure
For many RIA owners, independence represents years of investment in building a business around their own vision, client relationships, and approach to advice.
That makes decisions about affiliation, custody, and strategic relationships particularly significant.
As firms navigate these choices, an important question emerges: What does independence need to look like for the next stage of the business?
For some, the answer may be maintaining a fully standalone structure. Others may see value in accessing additional capabilities through a platform or strategic partnership.
Technology, artificial intelligence, cybersecurity, regulatory complexity, and increasing client expectations are creating new demands on independent firms of all sizes. The ability to address those demands while maintaining meaningful control over the business is becoming an increasingly important consideration.
Ultimately, the right structure should support an advisor’s ability to serve clients, pursue their long-term goals, and preserve what makes their business distinct.
Concurrent’s Perspective on the Future of Independence
At Concurrent Investment Advisors, we believe independence should give advisors the freedom to build businesses that reflect their own vision, without having to navigate every operational and strategic challenge alone.
As the industry evolves, maintaining that independence increasingly requires access to the right infrastructure, expertise, and resources. From technology and investment capabilities to compliance, operations, and business development support, the needs of independent firms can change significantly as they grow.
Concurrent’s platform is designed to provide advisors with access to these capabilities while supporting their ability to maintain their brands, client relationships, and long-term business objectives.
For established RIA owners, strategic partnerships can also present opportunities to access additional resources and capital while retaining meaningful ownership and control. Through its partnership model, Concurrent works with firms evaluating how to support their next stage of growth while preserving the businesses they’ve built.
We recognize that independence looks different for every advisor. Whether a firm is navigating an immediate industry change or evaluating a longer-term strategic opportunity, the priority should be finding an approach that aligns with its goals, clients, and vision for the future.
Looking Beyond the Immediate Decision
While Fidelity’s updated requirements have created an immediate need for some advisors to evaluate their options, the underlying considerations are relevant across the broader RIA industry.
Established firms are also evaluating how to balance independence with access to greater scale, specialized resources, and strategic capital.
Whether prompted by a change in custodial requirements or a firm’s next stage of growth, these decisions deserve a thoughtful assessment of both near-term needs and long-term objectives.
The goal is not simply to respond to industry change. It is to make informed decisions about the future of the business.
Join the Conversation: What’s Next for Your RIA?
To explore these considerations further, Concurrent Investment Advisors CEO Nate Lenz will join Todd Resnick, CEO of OneSeven, for an upcoming AdvisorHub webinar, When Change Forces a Decision: What’s Next for Your RIA?, moderated by Tony Sirianni, CEO and Publisher of AdvisorHub.
The discussion will examine evolving custodial requirements, different RIA operating and affiliation structures, and the role of technology, scale, and strategic partnerships in supporting independent advisory businesses.
Whether navigating immediate industry changes or evaluating your firm’s next stage of growth, the conversation will offer perspectives to help you assess your options and plan for the future.
Register for the AdvisorHub Webinar “When Change Forces a Decision: What’s Next for Your RIA?” here: https://hubs.li/Q04C85Pm0
November 3, 2026 | 2pm ET
CE credit available for eligible attendees.
