The system is asking the wrong question—again
There’s a growing consensus emerging in response to the FCA’s renewed focus on trail commission:
“Trail commission isn’t the real problem.”
Ed Dymott is right to highlight this.
He points to something many inside the system already know:
- Billions trapped in legacy products
- Structural barriers to switching
- Tax rules that lock consumers in
- Products that persist not because they are good… but because they are difficult to leave
This is not controversial.
It’s accurate.
But it’s also incomplete.
Trail commission isn’t the problem. It’s the evidence.
Trail commission is not the root cause.
But it is visible proof of a deeper structural issue:
👉 A system where value and payment are no longer directly connected
👉 A system where inertia protects outdated structures
👉 A system where the individual has limited practical agency
So when we say “trail isn’t the problem”…
We should be careful not to say:
“There’s no problem here.”
Because there clearly is.
The real issue is structural dependency
Dymott calls it structural inertia.
At the Academy of Life Planning, we would take that one step further:
It’s structural dependency.
Consumers are not just stuck in products.
They are often:
- Dependent on legacy wrappers
- Dependent on intermediated access
- Dependent on opaque pricing structures
And crucially:
👉 Dependent on someone else to interpret and navigate the system for them
The uncomfortable truth: everyone is constrained
This is where the conversation needs to mature.
Because it’s not just consumers who are constrained.
Advisers are too.
- They can see better solutions
- But cannot always implement them
- Without triggering tax consequences
- Or operational friction
So we end up with a system where:
- Consumers remain in suboptimal products
- Advisers remain in constrained positions
- Providers retain economic advantage
And the structure sustains itself.
If trail disappears… what actually changes?
This is the critical question—and Dymott raises it well.
If trail commission is removed in isolation:
- Product charges may remain unchanged
- Providers may retain the margin
- Advisers may need to introduce explicit fees
The result?
👉 The consumer may end up paying the same—or more—
👉 With no meaningful structural improvement
That is not reform.
That is redistribution.
So what would real reform look like?
Dymott points to one powerful lever:
👉 Unlocking legacy capital through tax-preserving transfers
This would:
- Enable movement between products
- Introduce real competition
- Force providers to justify value
This is an important step.
But even this does not go far enough.
The deeper opportunity: restore agency
Because even if we unlock products…
If the individual still:
- Doesn’t understand the system
- Can’t evaluate options
- Relies entirely on intermediaries
Then we haven’t solved the problem.
We’ve just made the system slightly more flexible.
This is where the model must evolve
At AoLP, the shift is not:
👉 Trail → No Trail
It is:
👉 Dependency → Agency
Where individuals can:
- Understand their position
- Model their options (increasingly with AI)
- Make informed decisions
- Engage advisers by choice—not necessity
This is the rise of Decision Capital.
Trail commission is the symptom. Dependency is the disease.
So yes—Dymott is right.
Focusing on trail commission alone risks missing the bigger issue.
But here’s the nuance:
- Removing trail without reform = ineffective
- Reform without restoring agency = incomplete
Regulatory housekeeping… or a turning point?
The FCA now faces a choice:
- Tidy up legacy structures
- Or rethink the system itself
Because the world has changed.
AI has changed it.
Access to information has changed it.
Consumer expectations have changed it.
The question is whether regulation will catch up.
A final thought
Trail commission is being questioned 14 years after it should have been resolved.
That tells us something important.
Systems don’t change because they should.
They change when they have to.
The pressure is building.
The opportunity now is not just to remove what no longer works…
…but to build something fundamentally better.
Curious how others see this. Is this regulatory housekeeping—or the beginning of something more meaningful?
Academy of Life Planning 