One of the concerns of the RDR was that advisers were not recommending a reasonable proportion of investment trusts and passive products, such as exchange-traded funds (ETFs).
By and large, it was thought the role of commission was to blame for this situation.
The implication was that consumers might be better off with some of these products. There is certainly a strong case to be made for them to be part of the investment mix.
In the case of trusts, they might offer access to assets that are difficult to access, gearing for those sure of their convictions, an efficient way to take income, and often better performance.
With ETFs, the big appeal is cost effectiveness, in most cases, assuming limited client demand for the more sophisticated, complex part of the market.
But is that what is happening in practice? Well it looks as if sales of trusts are up and that could well be a direct result of the RDR.
Yet if you are a passive fund or trust manager, not everything is falling into place.
It looks as if many of the big fund supermarkets are moving slowly, if at all, to embrace the full range of products. The decision by Cofunds to drop its pilot with Barclays shows that a huge section of the market remains lukewarm, at best.
Cofunds cited demand of course, though it is difficult to know if this can be extrapolated to the wider IFA market. Were advisers simply taking their time? Were they accessing these products for their clients elsewhere?
It is very likely all these big fund businesses have taken astute business decisions, but you have to hope they have taken a long-term view, because such change was always going to be an evolution.
It is also significant that Standard Life may be moving in another direction, making it easier to move clients from supermarket to wrap.
Another and even more important decision to come is from Sesame Bankhall, where if you want to be in the network, you will have to be restricted.
It will be interesting to see if this excludes or demotes product types such as trusts or ETFs.
One view of the market might be that the strongest investment solutions will be those that, at least potentially, offer a way to access the full range of investment vehicles. If that can be combined with strong, intelligent compliance that doesn’t leave clients in something that could lose them all their money, then that is surely close to the best sort of investment offering.
That clearly applies whether advisers are restricted or independent. But it isn’t clear that the market is developing this way.
We may see a big section of the market that relies much more on the mutual funds. But is this sustainable in comparison with the new model section of the market and indeed the growing self-selected part of the market?