Non-ACAT Assets

Last Updated: July 2026

One of the biggest misconceptions about advisor transitions is that every investment simply transfers from one firm to another through the ACAT system.

If only it were that easy.

While the Automated Customer Account Transfer Service (ACATS) handles millions of account transfers every year, it doesn't handle everything. Many investments fall outside the system entirely, while others require separate paperwork, manual processing, or additional decisions before they can move.

These are commonly referred to as non-ACAT assets.

Understanding which assets don't transfer automatically—and planning for them before the transition begins—can eliminate a significant amount of confusion for both advisors and clients.

What Are Non-ACAT Assets?

A non-ACAT asset is any investment or account that cannot be transferred through the standard ACAT process.

Instead of moving electronically between firms, these assets often require manual paperwork, additional approvals, liquidation before transfer, or in some cases, they may not be transferable at all.

Every custodian has its own rules regarding which assets it can custody, which products it supports, and which securities require special handling.

That's why identifying these accounts early is such an important part of transition planning.

Common Types of Non-ACAT Assets

Alternative Investments

Private placements, hedge funds, private equity investments, non-traded REITs, oil and gas partnerships, and other alternative investments often require their own transfer procedures.

Some can transfer.

Some cannot.

Others require approval from the sponsor before ownership can change.

Annuities

Many annuity contracts don't move through ACATS.

Depending on the carrier and contract type, the advisor may need to complete carrier-specific transfer paperwork or determine whether the contract should remain where it is.

Proprietary Mutual Funds

Some firms offer investment products that are only available on their own platform.

If the receiving custodian doesn't support those funds, clients may need to liquidate positions or choose alternative investments before completing the transition.

See Proprietary Fund Problems for more information.

529 Plans

Education savings plans frequently require separate transfer paperwork and may involve different processing timelines than brokerage accounts.

Directly Held Assets

Certain securities are held directly with transfer agents rather than at a brokerage firm.

These assets often require entirely separate transfer procedures.

Limited Partnerships

Limited partnerships commonly have transfer restrictions, sponsor approval requirements, or documentation that extends processing well beyond a typical ACAT timeline.

Why Non-ACAT Assets Create Delays

The ACAT system is highly automated.

Non-ACAT transfers usually aren't.

Manual processing introduces additional paperwork, more communication between firms, longer review periods, and sometimes third-party approvals.

That doesn't necessarily mean something is wrong.

It simply means these assets operate outside the standard transfer process.

Clients Often Don't Know the Difference

From a client's perspective, an investment is an investment.

They rarely know—or need to know—which assets transfer through ACATS and which require additional work.

What they notice is that some accounts arrive quickly while others seem to take much longer.

Without proper communication, that delay can create unnecessary concern.

Setting expectations before the transition begins helps clients understand that different assets naturally follow different timelines.

Some Assets May Need a Decision

Not every non-ACAT asset should automatically transfer.

In some cases, the receiving firm may not support the investment. In others, keeping the asset at the existing custodian may be the better option until a future decision is made.

The important point is that these decisions should happen during planning—not after transfer paperwork has already been submitted.

Inventory Matters

One of the most valuable exercises before any advisor transition is creating a complete inventory of client holdings.

That inventory helps identify:

The earlier these situations are identified, the fewer surprises everyone encounters later.

Non-ACAT Doesn't Mean Non-Transferable

These terms are often confused.

A non-ACAT asset isn't necessarily an asset that can't move.

It simply means the movement happens outside the automated ACAT system.

Many non-ACAT assets transfer successfully every day. They just require additional coordination, paperwork, and patience.

Preparation Reduces Friction

Experienced transition teams review client holdings before transfer paperwork is generated.

Doing so allows advisors to identify special situations, gather required documentation, coordinate with custodians, and prepare clients for different processing timelines.

It's much easier to explain upfront that a particular investment may take several additional weeks than it is to explain an unexpected delay halfway through the transition.

Every Transition Is Different

A practice built primarily around traditional brokerage accounts may have very few non-ACAT assets.

Another practice with extensive alternative investments, annuities, or directly held securities may require significant planning before the first transfer request is submitted.

That's why no two advisor transitions follow exactly the same timeline.

The underlying client portfolios help determine the operational complexity.

Related Topics

Key Takeaway

Non-ACAT assets aren't unusual—they're simply part of the operational reality of advisor transitions.

The advisors who experience the smoothest transitions aren't the ones who avoid these assets. They're the ones who identify them early, understand their requirements, and build realistic timelines around them.

Good transition execution means knowing which accounts will move automatically, which require extra attention, and making sure neither advisors nor clients are caught off guard along the way.