Moving custodians: a 12-week operations timeline for small RIAs
Moving custodians at a small RIA usually runs through six stages: decide and plan, prepare your records, tell clients and collect paperwork, transfer the accounts, rebuild billing, models and data feeds, and close out. Twelve weeks is a reasonable planning window for the operations side, though transfers depend on the custodians involved. The assets move with the custodians; your firm's own records (account list, strategy history, IPS documents, billing method and compliance records) are yours to carry, so prepare them first.
A custody move is mostly paperwork and patience on the asset side. The operations side is where small firms get caught out: a billing method that only made sense with the old custodian's file, a strategy history nobody wrote down, IPS documents that reference the old account numbers. Planned in order, it's manageable.
Why are so many small firms planning a move?
Some are moving for service or technology. Many are reacting to Fidelity's change: it has told RIAs under $100 million in client assets to meet its new custody minimum or start moving, with public reporting pointing to a deadline of 30 June 2027 (Financial Planning). Check Fidelity's current terms directly before acting.
What does a 12-week timeline look like?
| Weeks | Stage | Main work |
|---|---|---|
| 1 to 2 | Decide and plan | Choose the receiving custodian, ask the operational questions, set dates, name an owner for each workstream |
| 2 to 4 | Prepare your records | Account list, strategy history, IPS documents, billing method, compliance records, all current and in one place |
| 3 to 5 | Tell clients, collect paperwork | Plain letter explaining the move and what clients need to do; track signatures account by account |
| 5 to 9 | Transfer accounts | Submit transfers in batches; track each account until it lands; watch for cash and positions that don't transfer cleanly |
| 7 to 10 | Rebuild billing, models and data | Connect the new custodian's data, map accounts to households and strategies, re-test billing in parallel |
| 10 to 12 | Close out | Confirm every account moved, final bills reconciled, old access closed, records updated, lessons noted |
What should you prepare before the first transfer?
- Account list: every account, its registration type, discretionary status and owners.
- Strategy history: which model each account follows, which version, since when.
- IPS documents: the current signed version for each client, with review dates.
- Billing method: rates, exclusions, proration and timing, written down, not just in a spreadsheet.
- Compliance records: procedures, logs and registers, each with an owner.
The full list is in the records checklist for moving custodians.
A worked example
Take a hypothetical two-person RIA with about 120 households and 300 accounts. It sets a 12-week plan and moves accounts in three batches of about 100, starting with households that have the simplest account types. Before batch one, it writes down its billing method and checks every account's strategy on file. During transfers, the operations assistant tracks each account daily. After the last batch, the firm runs one billing quarter in parallel with its old calculation before relying on the new setup.
What should you record?
- The decision and the reasons, with the date.
- Each client notice and when it went out.
- Each account's transfer: submitted, completed, any problems.
- Any change to billing, models or agreements, with effective dates.
- Any Form ADV or agreement updates your compliance consultant advised.
Common gaps
- Billing logic tied to the old custodian's file layout, discovered at the first quarter end.
- Accounts that arrive at the new custodian but never get assigned to a household or strategy.
- Old custodian access left open after the move.
When is this overkill?
A firm with a handful of accounts might compress the timeline to a few weeks. The order still matters: records first, transfers second, billing tested before you rely on it.
How Advorra fits
Advorra keeps the firm's own records in one place, separate from any custodian: clients and households, accounts with discretionary status, versioned models and a dated strategy of record, IPS documents, billing and compliance records. It works from your custodian's account files and helps you assign accounts that arrive without a client. It isn't a custodian and doesn't execute trades. See the product page, or read questions to ask a custodian and reconciling custodian data.
One thing to do this week: write down your billing method in plain words, as if someone else had to run next quarter's bills without you.
An operations timeline, not legal or compliance advice, and not a recommendation of any custodian. Confirm transfer timing with the custodians involved.
Questions advisors ask
How long does a custodian move take?
It varies with the number of accounts, account types and the custodians involved. Plan the operations work over a few months and confirm transfer timing with both custodians.
Do clients need to sign new paperwork?
Usually yes: new account applications and transfer forms at the receiving custodian. Your advisory agreement may also need review. Ask your compliance consultant and attorney what applies.
Does a custodian move affect my Form ADV?
It can, because Form ADV includes information about custodians. Ask your compliance consultant whether an amendment is needed and when.
What about the Fidelity minimum?
Fidelity has told RIAs under $100 million to meet its new custody minimum or start moving, with public reporting pointing to 30 June 2027. Check Fidelity's current terms directly.
Is this a recommendation of a custodian?
No. This is an operations timeline for any custodian move.
See it on a demo firm
Advorra is practice software for independent RIAs: clients, models, IPS, billing and compliance records in one place, on top of the custodian you already use. Built by The CollabHub.
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