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Key takeaways
- Held away describes where an asset sits relative to an advisor, not what kind of asset it is. The same 401(k) is held away from your advisor and held at your recordkeeper.
- The SEC uses the phrase plainly, for client accounts held at outside financial institutions on which an adviser advises the client.
- Seeing an account and being able to act on it are separate things, and the difference is a regulated one: an adviser holding the client's login credentials for a held-away account has custody of it.
- Account aggregation is how most planning software pulls held-away assets into view. Cerulli finds 72% of affluent investors consider it important.
- The household is the only party with the complete list, which is why held-away assets go missing from a plan exactly when the plan needs them.
How Olomon thinks about this
Held away is a description of one professional's view, not a property of the asset, so a household record that only holds the managed accounts reproduces the problem it was supposed to solve. Olomon holds every account, entity, and asset the household owns regardless of who manages it, and lets the household grant an advisor scoped, read-only visibility into the parts that are theirs to see. Nobody has to share a password to give an advisor the full picture.
In-depth definition
The term describes a relationship rather than an asset class. Nothing about a 401(k), a brokerage account at another firm, or a rental property makes it held away; what makes it held away is that the person advising on the household does not manage or custody it. Any household with more than one financial relationship has held-away assets, and the phrase only exists because someone is giving advice without seeing everything.
That matters because most of the decisions worth paying an advisor for are decisions about the whole balance sheet. A withdrawal sequence, a Roth conversion, an asset-location plan, a concentration assessment, a beneficiary review: each of them depends on positions the advisor may not hold. Advice built on the managed slice can be internally consistent and still wrong against the household's actual position, and the household usually cannot tell the difference, because the plan looks complete either way.
Visibility and authority are separate asks, and confusing them has consequences. The SEC's order against Arcadia Wealth Management turns on exactly this line: the firm kept client usernames and passwords for held-away 401(k) and other advised accounts, which gave it the ability to move money out of them, so it was deemed to have custody of those assets under the custody rule, with the surprise-examination and policy obligations that follow. Read-only visibility into an account is a different arrangement from the keys to it, and the second one is the regulated one.
In practice, visibility today usually comes from aggregation: planning software connects to outside institutions and copies balances and positions back. Cerulli finds account aggregation ranked among the tools affluent investors consider most important, at 72%, precisely because it is what brings held-away assets into the picture. Aggregation is still a copy of someone else's record, which is why it goes stale, drops connections, and cannot describe the private fund or the rental property nobody can log into. The consumer's own right to authorize sharing of account data is being written into federal rule under Section 1033 of Dodd-Frank, though the compliance dates of that rule are currently stayed by a court.
Frequently asked questions
They are the complement of each other. Assets under management are what a given advisor manages and typically bills on; held-away assets are everything else the household owns. A household with $4 million at one firm and $3 million spread across an old 401(k), a rental property, and a spouse's accounts has a $4 million AUM relationship and $3 million held away from it.
Some do, using order-management tools that connect to outside accounts. That turns a visibility question into an authority question, and it is regulated as such: the SEC has found that keeping a client's login credentials for a held-away account gives an adviser the ability to move the assets and therefore custody of them, which brings independent verification and written-policy obligations with it. An adviser who only needs to see the account should ask only to see it.
Because nobody owns the list. Each institution knows its own accounts, each professional knows the slice they were hired for, and the only party who can see all of it is the household, usually from memory and under time pressure at the exact moment a decision is being made. Assets do not hide; they simply are not written down anywhere complete.
In the sense that matters for planning, yes. Real estate, a business interest, a private fund position, and a collection are all outside the advisory relationship, and they are harder to bring in than a brokerage account because there is no institution to connect to. They tend to be the largest and least current numbers in a household's picture for that reason.
Sources
Primary, authoritative references.
- 1
U.S. Securities and Exchange Commission
In the Matter of Arcadia Wealth Management, Inc., Advisers Act Release No. 6137Cited for: The Commission's own definition of held away advised accounts, and its finding that holding client login credentials for them constitutes custody under Rule 206(4)-2
- 2
Cerulli Associates
Human Advice Still Reigns as Investors Rely More on Online ToolsCited for: Account aggregation's standing among the tools affluent investors consider most important, at 72%, as the way planning software brings in held-away assets
- 3
Consumer Financial Protection Bureau
Personal Financial Data RightsCited for: Consumer authorization of third-party access to account data under Section 1033, and the stay of the rule's compliance dates
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Cite this page
APAOlomon Editorial Team. (2026). Held-away assets. Olomon Financial Glossary. https://olomon.com/financial-glossary/held-away-assets