RIA management fees

A question about IRAs and management fees. We are an RIA and charge quarterly management fees which are deducted from the accounts (not invoiced).

Scenario:
A client has two IRA accounts that are the same type of IRA. Ex. Darth Vader Traditional IRA
The accounts are at two different custodians. We manage both IRAs.
Management fee for IRA at custodian A is $125.
Management fee for IRA at custodian B is $100.

Can the total fee of $225 be charged to the IRA at custodian A? Similar to RMDs where the total can be withdrawn from only one IRA.

The management fee system that is used at custodian A allows for multiple management fees to be charged to one account. So logistically it can be done. The larger question is whether this is allowable by the powers that be.

Thanks for your help,



That’s OK since they are both the same type of IRA. You couldn’t bill both to A if custodian B held a Roth IRA, or you couldn’t deduct management fees for taxable accounts from an IRA. If one of these accounts was an inherited IRA subject to current RMDs, deducting all IRA fees from the inherited account is more of a stretch, but not likely to cause a problem. 

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