Indeed, Mr Miller, who is by his own admission not a fan of the regulator or the rule changes it pushed through, says his clients and the man on the street will not benefit from the regulatory overhaul and that advisers are slowly being wiped out.
He says the biggest hurdle to getting RDR-ready was completing the qualifications, which he describes as a “waste” of 600 hours of his life as he claims a lack of technical knowledge was not to blame for identified mis-selling and client risk failings.
“I wasted 600 hours of my life in study time just to prevent the FSA stealing my license to trade. With the time pressure on one’s working life, you cannot be going back two to three times to retake exams.
“That was the main problem to transitioning to the RDR and even legal opinion by sophisticated barristers opine that that process was probably illegal, because there’s nothing in the legislation that allows for the removal of a license just by failure to upgrade one’s knowledge level.”
“Critical client risk occurred by products that were poorly designed, in combination with market conditions.”
However, despite his lamentations Mr Miller says he the RDR has not resulted in his firm losing any clients, saying all were “very understanding” about the limitations studying for exams placed on his time.
He adds that despite many being “horrified” about the charging changes many have accepted the new remuneration model, which is based around a simple transposition to a percentage of assets invested structure.
“The issue of commission never was an issue between me and my clients. Every element of commission was discussed early in the discussion process. It wasn’t, ‘oh by the way I am going to be paid by such and such’.
“So that has always been extremely transparent and never an issue so when this method was removed from them they were pretty horrified.”
Mr Miller decided to remain independent post-RDR world as a “shopfront” for the firm as it is a “clear concept” for clients to understand, although he admits that it does involve more “complexity” for advisers under the new guidelines.
“This muddying the waters with restricted advice is just a bridge too far for me. I have kept it as an independent practice as I want to offer anyone any product that may potentially be needed to cover off their potential requirements.”