Advorra blog

Moving custodians? The records checklist for RIAs under $100M

By the team at The CollabHub · Co-written with Mohammad Aamish Aaftab
Published 6 Oct 2026 · Updated 17 Oct 2026

A custody move records checklist is the list of practice records that have to survive a change of custodian: your account list, which model each account follows, the signed IPS for each client, your fee rules, your trade history and where each compliance record lives. The account transfer is only half the work. Firms under $100M at Fidelity have until June 30, 2027.

If your firm has under $100 million at Fidelity, you've probably already had the conversation: grow past the minimum, join a larger firm, or move. Each of those is a business decision with its own timeline. Whichever you pick, the records that explain how you manage each account have to come with you, and those are the ones that get left until last.

What changed at Fidelity?

Fidelity has told RIAs with less than $100 million in client assets on its platform that they need to meet a new $100 million custody minimum or start moving, with a deadline of June 30, 2027. The minimum previously applied only to new relationships; this time it reaches firms already on the platform.

Estimates of how many firms are affected vary. Fidelity has said the change affects a few hundred firms. AdvizorPro counted about 1,150 RIAs that could be affected, and FINTRX counted 986. (Financial Planning, WealthManagement.com.)

Why do records get left behind in a custody move?

Because the transfer has a deadline and forms, and the records don't. The account transfer paperwork gets planned in detail. The practice records, the ones that explain how the firm manages each account, wait until after. That's when the gaps show up: a model change nobody dated, an IPS that was never re-signed, a fee exclusion that lived in someone's head.

Custodian statements will tell you what was held and what traded. They won't tell you which model an account was meant to follow, or why a trade was placed.

Which six records should you write down before you move?

Accounts, models, IPS, fees, trades and compliance records. Start with the account list, because everything else gets checked against it.

What does this look like for a small firm?

Take a hypothetical two-person RIA with about 80 households and roughly 190 accounts, planning to move in the first half of 2027.

In the first two weeks, the operations lead exports every account from the current platform into one list with registration type, discretionary status and household. That list turns up 6 accounts nobody had grouped into a household, and 2 closed accounts still marked active.

Next, she matches each account to its model and version. Most are clear. Eleven accounts switched models in the past year, and only four of those switches were dated. She dates the rest from trade records and meeting notes while the people who made the decisions still remember.

Then the IPS check: 9 clients have an IPS that was never re-signed after a model change. Those go on the list for the next review meeting, before any transfer forms go out.

By the time the firm picks a destination, the six records are written down. The move itself is now paperwork and phone calls, with no archaeology.

What four questions should you ask of every record?

1. Where does it live? One place, not three.
2. Who owns it? A named person.
3. How long is it kept? A retention period you can state.
4. How fast could you produce it? Days, not weeks.

If you can answer those four for each of the six records above, the move is mostly a matter of logistics.

What should you ask a new custodian about records?

Ask what data they'll send you, how you get history out of the old platform, and what changes for fees.

• What account, position and transaction data will you send us, in what format, and how often?
• How do we get our historical data out of the old platform, and how far back?
• What changes for fee deduction, and when does the first quarter on the new platform bill?

Write the answers down next to your six records. They decide how much rework the move creates.

Trade-offs to plan for

Moving in one batch keeps the cut-over date clean for billing and performance, but puts every client's paperwork into the same few weeks. Moving in waves spreads the work, and leaves you running two custodians for a quarter or more, which means two sets of files, two fee deductions to reconcile and a household split across platforms. Neither is wrong. Pick one deliberately and write down the cut-over date for each account.

How Advorra handles this

Advorra keeps a firm's clients and households, versioned models, the strategy each account was managed to by date, IPS documents with their signed copies, the trade blotter, quarterly billing and compliance registers in the firm's own workspace. It sits on top of the custodian rather than inside it, so the practice records stay put when the custodian changes. It works from your custodian's account files. You can see the product on the product page, or download the one-page version of this checklist by getting in touch.

This article is general information about organising records. It is not legal, tax or compliance advice. Facts about Fidelity's minimum are from the press reports linked above as of October 2026; check the current terms with Fidelity directly.