Advorra blog

Held-away and non-discretionary accounts: how a small RIA records the accounts it doesn't fully manage

By the team at The CollabHub · Co-written with Mohammad Aamish Aaftab
Published 18 Oct 2026

Held-away and non-discretionary accounts: how a small RIA records the accounts it doesn't fully manage

Not every account a small RIA knows about is one it manages with discretion. Give each account a clear status, such as discretionary, non-discretionary, limited purpose, held away or reporting only, and record what the firm may do with it, whether it's billed, and the document that sets that out. Then make sure the status drives what happens: held-away and reporting-only accounts stay out of model trades, and anything not billable is excluded before the fee is calculated.

A household has six accounts. Three are managed with discretion at the firm's custodian. One is the husband's 401(k) at his employer, which the advisor looks at once a year. One is a small brokerage account the wife trades herself and asked the firm to keep an eye on. One is a trust account where every trade needs the trustee's sign-off. On a household summary they look identical. In practice, the firm can do something different with each of them.

What statuses are worth using?

StatusWhat the firm can doUsually traded to model?
DiscretionaryTrade within the agreed strategy without asking each timeYes
Non-discretionaryRecommend trades; the client approves each oneOnly after approval
Limited purposeAct only for a stated purpose, such as holding cash for a planned withdrawalNo
Held awayAdvise or track; trading happens elsewhereNo
Reporting onlyInclude in reports and conversations; no managementNo

What should each account record show?

Where do the mistakes happen?

  1. Trading: a non-discretionary or held-away account swept into a model rebalance.
  2. Billing: a reporting-only account included in the fee calculation, or a billable account left out.
  3. Records: the discretionary list shows an account as discretionary long after it moved.
  4. Performance: held-away accounts mixed into a model's results.

A worked example

Take the household above at a hypothetical two-person RIA. The assistant sets each account's status from the documents on file. The 401(k) is marked held away, not billed, no strategy. The self-directed brokerage account is reporting only. The trust account is non-discretionary, with the trustee named as approver. The quarterly rebalance then picks up only the three discretionary accounts, billing excludes the two the firm doesn't manage, and the discretionary list matches the accounts the firm actually trades.

Common gaps

When is this overkill?

If every account you know about is discretionary and billed the same way, one status is enough. As soon as a household has an account you only track, record it as such.

How Advorra fits

In Advorra, each account carries its discretionary status alongside its strategy, and billing exclusions sit on the record rather than in someone's memory. Accounts from your custodian's files that aren't matched yet show up as unassigned until someone links them to a household. See the product page, or read about keeping the discretionary list accurate and households, members and accounts.

One thing to do this week: pick your three largest households and check every account has a status you could defend.

An operations guide, not legal or compliance advice. Your advisory agreement sets what you may do with each account.

Questions advisors ask

What is a held-away account?

An account held somewhere other than your firm's custodian, such as a 401(k) at an employer's plan provider. You may advise on it or simply track it, but you usually can't trade it directly.

What does non-discretionary mean?

The firm needs the client's approval before each trade, rather than trading on its own judgment within the agreed strategy.

Should held-away accounts be billed?

It depends on your advisory agreement. Some firms bill on advice given about held-away assets, many don't. Whatever you agreed, record it on the account.

Do these accounts belong on the discretionary list?

Only accounts managed with discretion. Keep the list accurate by updating it whenever an account's status changes.

Is this compliance advice?

No. It is an operations guide. Your advisory agreement and compliance consultant decide the rules for your firm.

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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