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The Portfolio

Merrill adds third-party manager data fees up to $860,000 and a 0.1% revenue share

The Bank of America subsidiary's Form ADV updates say it will have a financial incentive to recommend third-party managers that pay for data analytics, with the schedule effective Jan. 1, 2027.

Under updates to its Form ADV filings, Merrill Lynch will charge third-party asset managers between $125,000 and $860,000 a year for data on their actively managed products, including ETFs, plus a revenue share of as much as 0.1% on every Merrill asset they manage. RIABiz reported the schedule on Sept. 29, and it takes effect Jan. 1, 2027.

The money buys a manager a place in the menu Merrill's brokers work from when they shop investments for client accounts, and the chance to be listed, seen, and recommended on it. Thousands of third-party managers compete for that attention, and the company's position is that broker incentives will not shift even as the fees sort third-party managers into those that pay and those that do not.

The firm put the logic in writing, with the ADV updates stating, according to RIABiz, “We will have a financial incentive to make available and recommend products from third-party firms that pay fees for data analytics over those that do not.” Merrill presents the arrangement as a way to remove existing bias against third-party managers and give them footing closer to equal with in-house and big-house products, a goal analysts quoted in the report say it stops short of reaching.

The incentive the filing describes therefore runs between third parties that pay and those that decline, rather than between third-party and in-house products, and the coverage does not say whether any portion of the platform is reserved for paying managers or what changes for a manager that keeps its wallet closed.

A flat charge against an uneven book

A firm that maxes out its data analytics purchases can spend as much as $1.4 million a year on incentives, according to the report, and the data fee is billed in absolute dollars rather than as a share of the assets a manager runs through Merrill, a design the report calls a hard nut for small firms to crack. The $125,000-to-$860,000 package range and the $1.4 million annual ceiling are not reconciled, but the distinction is what decides who can afford the ticket.

A boutique with a thin Merrill presence and a firm with billions on the platform both start at the same $125,000, so the fixed charge presses hardest on the manager with the least revenue to spread it across, while the revenue share runs the other way, capping at 0.1% of everything a manager oversees at the wirehouse and placing the largest variable bill on the largest distribution relationships. For the largest managers the 0.1% is the number that matters, and for the smallest the question is whether a data package can be justified at all.

The decision is now explicit in a way it was not before. A budget line for Merrill data has to be weighed against the revenue the platform already produces, and a firm that stays out of the data purchases is choosing the unpaid side of the menu; nothing in the schedule compels a manager to buy, but declining means competing for the same broker attention without the packages paying rivals will hold.

Analysts quoted by RIABiz give Merrill credit for its timing, noting that peer wirehouses moved earlier to formalize arrangements of this kind and that arriving last carries the advantage of observing what the market would bear, pricing near that ceiling, and avoiding a squeeze on the managers whose funds its brokers sell.

The schedule also lands while the distribution force it serves is in motion, with Merrill team liftouts logged on Sept. 25 and Sept. 26, in the same stretch as the fee disclosure.

The $125,000-to-$860,000 packages price access to the recommendation itself, with the advisors who generate the fees not parties to the trade, as PWD reported on Sept. 21, and the ADV language now tells clients where the firm's incentive points.

Little of it shows up on a fact sheet. The revenue share is a cost the manager carries, and whether it is absorbed or recovered through product pricing is something neither the ADV updates nor the report resolves, leaving the schedule in the diligence file next to the questions that attach to any menu: who pays for access, in what unit, and what the payment buys.

The platform is no longer a neutral utility, and the menu, sweep, and referral terms now compete for the client relationship instead of quietly servicing it; Merrill's filing is the wirehouse edition of that shift, access to the recommendation menu itemized in dollars and basis points and the direction of the incentive stated by the firm itself.

The schedule takes effect Jan. 1, 2027, and the first year should show where the 0.1% lands—whether in manager economics, in share-class pricing, or in neither—and whether rival wirehouses write schedules of their own.

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