More than nine months since its implementation and the RDR is still being attacked from all quarters as questions about commission continuing and an advice gap emerging are still running rife.

The latest onslaught has come courtesy of Treasury Select Committee chair Andrew Tyrie, who has slammed twin regulatory authority the Financial Conduct Authority and the Prudential Regulatory Authority for its “mindless data collection” from regulated firms.

Speaking at the Conservative Party Conference in Manchester, Tyrie said the regulators should be focusing on where the risks lie rather than becoming overly engrossed in unnecessary detail.

While acknowledging that trail commission could not continue being disguised from customers, Tyrie said the industry was being consolidated into a smaller number of large players, with concerns that an oligopoly of these players could be damaging.

Tyrie said the Treasury attempted to put a pause on the RDR to get this right only to be rejected by the FSA, He said while it was too early to assess the damage that had been done, the regulator can still minimise future concerns by spending more time focusing on the big risks rather than the pointless details.

He said: “Anybody who works in a bank or regulated firm will tell you that these guys come in and demand heaps of material. God knows what they do with it, it costs a packet and the client cost is huge but what is the point in it all? They need to be looking at where the risks really lie each time they come to examine that firm.”

Tyrie’s argument makes sense given that it was recently reported that the total industry cost of meeting regulatory requirements was estimated at £10m a year.

All this comes at a time when margins are getting squeezed at the small end of the adviser market while we are seeing big banks like Santander, Aviva and AXA scrap their advice offering in the wake of RDR as well as others pulling out of financial advice or restricting their offerings to high net worth clients.

This is the big picture – the advice gap is a huge concern for the industry as it means that those with £50,000 to £100,000 of assets are not getting the same level of service they were previously getting. Working out a cost effective advisory model for this area of the market needs addressing and those advisers that can offer this are likely to be the success stories of the RDR, hence the launch of execution-only platforms from advisers in recent years to attract this type of client.

Perhaps the most important part of the RDR will be the review to assess whether it has achieved its intended outcomes, while minimising (hopefully eliminating) its intended consequences.

The FCA has committed to a post-implementation review at the end of 2014. It’s a promise the new regulator cannot fail to deliver on.