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title: "Schedule RC-T for asset managers: find the investment decision-maker | Altss Blog"
description: "Use managed, non-managed and custody assets to identify bank and trust prospects, map manager-selection authority and prepare a focused distribution brief."
canonical: "https://altss.com/blog/schedule-rc-t-asset-managers-bank-trust-decision-makers"
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[Altss Research](https://www.linkedin.com/company/altss)

7 min read

Updated Nov 13, 2026

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# Schedule RC-T for asset managers: find the investment decision-maker

Use managed, non-managed and custody assets to identify bank and trust prospects, map manager-selection authority and prepare a focused distribution brief.

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A bank can administer a substantial pool of client assets while having little authority to appoint the investment manager. For a distribution team, that difference determines whether the next conversation belongs with a trust investment committee, an outside adviser, or a custody-services team.

Schedule RC-T, the fiduciary-services section of a bank's Call Report, helps make that distinction. Its most useful contribution to prospecting is the separation of investment discretion from administration. Read that separation first; use the asset totals to size the relevant business afterward.

## Start with the authority behind the assets

The [FFIEC's September 2026 instructions](https://www.ffiec.gov/sites/default/files/data/reporting-forms/FFIEC031_FFIEC041_202609_i_0.pdf) classify a fiduciary account as managed when the reporting institution has sole or shared authority to decide which securities or other assets to buy and sell. The institution need not exercise that authority for the account to be classified as managed.

Non-managed fiduciary accounts sit in a different column. Here the institution lacks investment discretion. Providing a menu of investment options does not, by itself, change the classification when the account holder or an external manager makes the selection.

Custody and safekeeping assets occupy a separate line, item 11. That business can involve holding assets, processing income and maintaining records without responsibility for selecting the investments. Total fiduciary accounts, item 10, instead sums the fiduciary categories in items 4 through 9.

Those distinctions suggest three different research questions:

- Managed fiduciary assets establish investment discretion under the reporting definition. Find out who selects outside managers, which mandates use them, and how a strategy gets reviewed.
- Non-managed fiduciary assets indicate that investment decisions rest elsewhere. Establish who holds that authority and whether the bank influences the available choices.
- Custody and safekeeping assets identify specified custody or agency functions. Investigate whether a separate investment-selection relationship is relevant to the proposed product.

A large custody business may be an excellent prospect for an operational service. It is a different starting point for a manager seeking investment allocations. Ranking both opportunities on one undifferentiated asset figure sends the two sales teams toward the wrong conversations.

## Managed assets can reverse the prospect ranking

Consider two hypothetical institutions, each reporting $1 billion of fiduciary assets. These figures illustrate the decision; they are not observations about real banks.

- Bank A reports $200 million of managed fiduciary assets in item 10 column A and $800 million of non-managed assets in column B. Its managed share is 20%. Separately, it reports $8 billion of custody and safekeeping assets.
- Bank B reports $600 million of managed fiduciary assets and $400 million of non-managed assets. Its managed share is 60%. Separately, it reports $100 million of custody and safekeeping assets.

A ranking dominated by custody scale would put Bank A far ahead. A manager researching discretionary investment relationships would begin with a different observation: Bank B reports three times as much managed fiduciary business.

That makes Bank B a stronger candidate for further qualification on this particular criterion. It does not establish a $600 million sales opportunity. The strategy still has to fit the underlying accounts, and the institution may already have an incumbent manager, manage the assets internally, or have no current review under way.

The practical change is to keep custody scale, managed fiduciary assets and confirmed manager-selection opportunities in separate fields. Promote a prospect when its relevant mandate and decision process become clearer, rather than treating a larger number as a stronger buying signal.

## Delegation changes the route to the mandate

The most consequential detail in the managed column is easy to miss. Under the FFIEC instructions, both an institution that delegates investment authority and an institution that receives delegated authority can have investment discretion. An account can therefore remain managed at the bank after an outside registered investment adviser takes on investment management, where the delegation arose from the bank's exercise of discretion.

For prospecting, a managed balance leaves an important relationship to map: internal portfolio management, an external manager selected by the bank, or another allocation of responsibilities under the account's governing terms.

The distinction also matters at group level. RC-T includes qualifying fiduciary activity within the reporting institution's consolidation scope, including trust-company subsidiaries. Investment-management assets administered by a registered investment adviser subsidiary are generally excluded, subject to the specific fiduciary and delegation arrangements described in the instructions. A group brand, an RIA registration and a bank reporting entity are not interchangeable units of analysis.

Before allocating coverage, record the legal entity behind the filing and the entity behind the investment team. If the bank has delegated selection or management, follow that relationship rather than assuming the parent company's chief investment officer controls every account. The same separation of advisory influence and delegated authority matters when [researching OCIOs and investment consultants](https://altss.com/blog/ocio-investment-consultants-as-lps-gp-fundraising-guide-2026).

## Match the account mix to the proposed strategy

RC-T also separates personal trusts, employee-benefit and retirement accounts, corporate-trust relationships, investment-management and advisory agency accounts, foundations and endowments, and other fiduciary business. These categories help a distributor decide what to investigate within an institution.

For example, a manager approaching a bank about foundation portfolios should examine the foundation-and-endowment category alongside the managed/non-managed split. A retirement specialist would investigate the employee-benefit categories. Neither should assume that a large corporate-trust business represents a comparable pool of discretionary portfolio mandates.

Account counts add context, but their units matter. For employee-benefit accounts, the instructions call for the number of plans administered rather than the number of plan participants. Dividing assets by that count produces an average per reported plan, not an average household balance or an expected investment ticket.

Use the account mix to prepare questions about investment objectives, liquidity, vehicle eligibility and how the proposed strategy would be used. Those answers belong to the mandate and its decision-makers. An aggregate reporting category alone cannot supply them.

## Build the meeting around manager selection

The [OCC's Investment Management Services handbook](https://www.occ.gov/publications-and-resources/publications/comptrollers-handbook/files/investment-management-services/pub-ch-investment-mgmt-services.pdf) describes external-manager selection as a documented process connected to the investment policy statement. Its selection guidance covers the firm's investment approach, resources, financial strength, performance, regulatory history, personnel turnover and fees.

That points toward a more useful first conversation than an assumption about how much capital the bank might allocate. Establish:

- Authority: Which entity and committee approve outside managers for the relevant accounts?
- Mandate: Which client group, portfolio role and eligible vehicle could fit the strategy?
- Process: Does the institution maintain an approved list, appoint managers for individual accounts, or delegate selection?
- Evidence: What performance, personnel, operational and fee information must a manager provide?
- Timing: Is a review scheduled, an incumbent being reconsidered, or no current selection process open?

The resulting account brief should distinguish a documented discretionary relationship from a confirmed opportunity. The former makes the institution worth researching; the latter requires evidence of fit, authority and an actual process.

## Keep the comparison on a consistent date

Reporting frequency can affect the apparent freshness of a prospect. Under the current FFIEC 031/041 instructions, institutions exceeding the specified fiduciary-asset or fiduciary-income tests report the main RC-T asset categories quarterly; institutions below those tests report specified items annually. Record the period of the actual field rather than assuming every figure in a quarterly Call Report was refreshed that quarter.

Fiduciary assets are generally reported at market value. A rise between comparable periods can reflect valuation changes as well as changes in business. It should prompt a question about the source of growth, not an automatic claim of new client inflows or additional manager capacity.

For a bank-and-trust territory plan, the useful ranking is therefore specific: relevant managed business, identifiable selection authority, suitable account types and a known route into review. The institution with the largest asset-servicing footprint need not be the first one a portfolio manager should call.

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