NAICS 523991 Quarterly Industry Report
Trust, Fiduciary, and Custody Activities
Comprehensive industry research for valuation professionals, business owners, buyers, and lenders
NAICS Code: 523991Sector: Finance and Insurance (52)Updated: Q1 2026
About This Report
This Fair Market Value report for NAICS 523991 provides industry data on trust, fiduciary, and custody activities including market size, employment statistics, and regulatory information. Additional data is drawn from SBA[6].. The report draws from Census Bureau[7] and Bureau of Labor Statistics sources.
Industry Snapshot
Key metrics for the trust, fiduciary, and custody activities industry.
Industry Definition & Overview
Trust, Fiduciary, and Custody Activities (NAICS 523991) encompasses establishments primarily engaged in providing trust, fiduciary, and custody services to clients on a fee or contract basis. This includes bank trust offices, escrow agencies (excluding real estate), and trust companies that act as trustees, fiduciaries, or custodians for individuals, businesses, and institutions. Per Census Bureau[5] definitions, this classification covers fiduciary management and asset safekeeping rather than investment advisory services.
The industry operates within a highly concentrated market where the 50 largest companies control more than 85% of industry revenue. With roughly 2,385 active establishments and an estimated 33,605 employees, the sector generated $28.8 billion in U.S. revenue during 2024. Key service segments include trust administration for estate planning and asset protection, fiduciary management ensuring legal compliance and investment oversight, and custody services involving safekeeping of financial assets and securities administration.
Growth drivers include wealth accumulation, demographic shifts with an aging population requiring estate planning services, and regulatory requirements increasing fiduciary service demand. Technological improvements in digital asset management platforms and globalization of investment portfolios also support market expansion. Average weekly wages of $2,141.76 and typical work schedules of 38.5 hours per week reflect the skilled professional workforce required in this sector.
What's Included in This Industry
- Trust administration and estate management services
- Fiduciary management and legal compliance oversight
- Custody and safekeeping of financial assets and securities
- Escrow agency operations (excluding real estate)
- Bank trust office operations and trust company services
- Investment account administration and recordkeeping
- Securities settlement and transaction processing
- Client reporting and regulatory compliance services
- Intergenerational wealth transfer planning support
- Corporate trust and institutional custody services
NAICS Classification Hierarchy
| Level | Description | Code |
|---|---|---|
| Sector | Finance and Insurance | 52 |
| Subsector | Securities, Commodity Contracts, and Other Financial Investments and Related Activities | 523 |
| Industry Group | Other Financial Investment Activities | 5239 |
| NAICS Industry | All Other Financial Investment Activities | 52399 |
| National Industry | Trust, Fiduciary, and Custody Activities | 523991 |
Related NAICS Codes
| Code | Description | Relationship |
|---|---|---|
| 523940 | Portfolio Management and Investment Advice | Portfolio Management and Investment Advice covers managing portfolio assets and providing investment advice, distinct from NAICS 523991 emphasis on fiduciary management and asset custody services. |
| 525920 | Trusts, Estates, and Agency Accounts | Trusts, Estates, and Agency Accounts comprises legal entities administered as trusts or estates, representing actual trust entities rather than the service providers classified in NAICS 523991. |
| 522110 | Commercial Banking | Commercial Banking includes bank trust offices providing fiduciary services, though only when trust services are the primary business activity are they classified under NAICS 523991. |
| 531390 | Other Activities Related to Real Estate | Other Activities Related to Real Estate covers real estate escrow and fiduciary activities, which are specifically excluded from NAICS 523991 classification and scope. |
| 523999 | Miscellaneous Financial Investment Activities | Miscellaneous Financial Investment Activities includes financial agents and brokers not elsewhere classified, excluding trust, fiduciary, and custody services belonging in NAICS 523991. |
| 813211 | Grantmaking Foundations | Grantmaking Foundations covers establishments awarding grants from trust funds, excluding grant distribution activities from NAICS 523991 classification and service scope. |
Geographic Concentration
Top states by share of national establishments.
| # | State | % Est. | Total Est. |
|---|---|---|---|
| 1 | California | 18.4% | 515 |
| 2 | Texas | 9.1% | 255 |
| 3 | Florida | 7.2% | 203 |
| 4 | New York | 6.1% | 171 |
| 5 | Georgia | 3.4% | 95 |
| 6 | Pennsylvania | 3.0% | 85 |
| 7 | Arizona | 2.9% | 82 |
| 8 | Illinois | 2.8% | 79 |
| 9 | Washington | 2.8% | 77 |
| 10 | Nevada | 2.5% | 69 |
% Of Establishments
0%
18%
Source: County Business Patterns, U.S. Census Bureau[3]
SBA Lending Summary
32
Total SBA Loans
$10.3M
Total Loan Volume
$321K
Average Loan Size
18 yrs
Average Loan Term
8.41%
Average Interest Rate
88
Jobs Supported
Source: SBA 7(a) Program Data, U.S. Small Business Administration — FY 2025[4]
Key Insight: Per SBA size standards[8], the threshold for NAICS 523991 is $47.0 million in average annual receipts over the preceding five fiscal years. Establishments meeting this definition may qualify for SBA programs and government contracting advantages. Eligible businesses can access SBA 7(a) loans[9] for working capital, equipment, and acquisition financing, while 504 loans[10] support major fixed-asset purchases including real estate and heavy machinery.
Top SBA Lenders
| # | Lender | Loans | Volume | Avg Loan |
|---|---|---|---|---|
| 1 | Bank of America, National Association | 8 | $4.4M | $553K |
| 2 | JPMorgan Chase Bank, National Association | 8 | $3.8M | $475K |
| 3 | Farmers and Merchants State Bank | 8 | $1.2M | $150K |
| 4 | OakStar Bank | 8 | $854K | $107K |
Frequently Asked Questions
Common questions about this industry.
What services fall under NAICS 523991?
Per Census Bureau[5] definitions, NAICS 523991 covers trust administration, fiduciary management, and custody services including managing trusts and estates, administering investment accounts, acting as escrow agents, and safekeeping financial assets.
What is the difference between NAICS 523991 and NAICS 523940?
NAICS 523991 covers trust, fiduciary, and custody services where entities act as trustees or custodians managing client assets per instructions. Per SEC[11] distinctions, NAICS 523940 includes portfolio management and investment advice, emphasizing investment management rather than fiduciary management.
How many companies operate in the trust and custody industry?
Roughly 2,385 active establishments are classified under NAICS 523991, employing an estimated 33,605 people with average weekly wages of $2,141.76 per Bureau of Labor Statistics[12] data.
What is the SBA size standard for NAICS 523991?
Per SBA standards[8], the threshold is $47.0 million in average annual receipts over five fiscal years for small business qualification.
What regulatory bodies oversee trust and custody activities?
Per OCC[13] guidelines, trust and custody services are regulated by the Office of the Comptroller of Currency for bank trust offices and federal banking regulations. State financial regulators also oversee trust companies and escrow agencies.
What types of legal entities are excluded from NAICS 523991?
Legal entities administered as trusts, estates, or agency accounts are classified in NAICS 525920 rather than 523991. Real estate escrow activities fall under NAICS 531390, and establishments awarding grants from trust funds belong in NAICS 813211.
What employment opportunities exist in this industry?
Per Bureau of Labor Statistics[12] data, positions include trust administrators, fiduciary officers, custody specialists, compliance officers, and securities settlement professionals across 2,385 establishments.
What is driving growth in the trust and custody services market?
Major growth factors include increasing wealth accumulation, an aging population requiring estate planning services, regulatory changes, and technological advances in digital asset management platforms that improve service delivery and operational efficiency.
Sources & References
Government datasets and editorial sources used in this report.
- [1]U.S. Bureau of Labor Statistics, Quarterly Census of Employment and Wages bls.gov
- [2]U.S. Census Bureau, Economic Census census.gov
- [3]U.S. Census Bureau, County Business Patterns census.gov
- [4]U.S. Small Business Administration, SBA 7(a) Loan Program Data data.sba.gov
- [5]Census Bureau census.gov
- [6]SBA sba.gov
- [7]Census Bureau data.census.gov
- [8]SBA size standards sba.gov
- [9]SBA 7(a) loans sba.gov
- [10]504 loans sba.gov
- [11]SEC sec.gov
- [12]Bureau of Labor Statistics bls.gov
- [13]OCC occ.gov
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