RDR is estimated to have cost the industry £2.6bn (and tens of thousands ofjobs!) but only four years since being introduced it seems the Financial Conduct Authority is pragmatically accepting a partial failure by considering reversing its ban on commission.

Having seen thousands of independent financial advisers forced to sink or swim by adapting business models to a world where commission is no longer accepted, it will have raised many an eyebrow across the financial services industry when news broke last week of a Government appointed panel of experts – who are advising the FCA in its Financial Advice Market Review – considering calling for the return of commission as a revenue source for advisers.

The news was supported by FCA interim chief executive Tracey McDermott on Money Box where she acknowledged the regulator “would not rule out an element of commission in sales” provided there were suitable safeguards in place.

It is worth underlining the pain financial advisers have had to endure in shouldering the cost of RDR has weighed heavily on businesses.

Not only have they had to shift business models but also regulatory-linked professional standards required improvement with firms generally having to bear the brunt of a cost between £3,000 and £5,000 to get their advisers up to the level required to continue offering financial advice.

The 1,000 advisers surveyed in CoreData Research’s 2015 Adviser Fees and Business Models research cited increase paperwork (71%) and the cost of remaining independent (58%) as the biggest hindrances they faced as a result of RDR.

It is also worth noting that 43% cited a lack of support from the regulator. When we talked to these advisers in more detail it is clear they felt there was no major difficulty in adapting their business model or that a loss of clients will be a direct result – it is more they believe they are being asked to maintain a set of standards which do not deliver direct benefits to their businesses or clients.

But the pressures are clear – regulation and general administration coupled with continued professional development now account for 40% of an adviser’s time as they look/continue to rebuild their business models in a post-RDR world.

The average advice firm still derives 13% of its business revenues from trail commission; however there remains a strong portion of adviser firms generating more than 15% from this avenue.

These businesses look materially different from firms with little or no trail commission within their business as they tend to be smaller practices with less than £25m of total client assets under management.

The pressure remains for some adviser firms with only a few months remaining until the sunset clause comes into effect, meaning the end of trail commission on almost all products.

Our research indicates the industry could lose as many as 4,000 advisers by 2020 following the introduction of the sunset clause.

This is without even touching on the increasing fees being levied on advice firms from the regulator.

However, it is the advice gap – which can be traced back to the RDR – that is the greatest concern.

With advisers typically charging around £150 for advice (remember this needs to be a fee-only process) many mass market investors are being priced out of financial advice.

While the attempted move to greater transparency has benefited some consumers by offering an explicit fee it has alienated others who simply cannot afford it.

There is an argument for a move back to commission.

For example, we looked at those advice firms with more than 15% of their business coming from trail commission; only 59% of their client base was active. Given the average adviser in the UK says they have 243 clients, we can deduce that for trail-reliant advisers it means 100 of those clients are dormant, a third of which, according to our research, are clients they are still receiving trail commission from.

It means these trail-reliant advisers are set to lose up to 14% of their revenue from these clients unless they look to re-engage.

The idea of these advisers being allowed some potential commission structure – provided it is transparent and clear – would offer them an opportunity to keep their businesses operational and prevent yet more experienced advisers leaving the industry.

Some would argue it is sensible to re-introduce a fee that looks similar to commission with safely regulated (simple) products as a means to fix the advice gap.

The trouble the regulator will have is hiding from those initial numbers as a decade of work, £2.6bn in cost, thousands of job losses and millions locked out from accessing financial advice are hard to hide from.

Would Hector lose his knighthood if a process that cost billions of pounds and changed thousands of lives was reversed?

It is hard to see the FCA making the biggest admission of all – that the biggest industry wide initiative of the past 10 years has fallen short by some distance.