Are you one of the advice businesses still pulling in a slug of trail commission?

Listening to the leading lights of the industry, both adviser and provider side, you’d be forgiven for thinking the naughty commission tap was firmly turned off five years ago.

They stand at lecterns and on conference panels and talk as if their advisers were all highly qualified and born after the RDR took effect.

It would be nice to think that was the case.

As has been repeatedly highlighted by reports and newspaper articles, there is a problem with fee transparency. Surveys suggests only a third of advisers publish their fees online.

The focus on fee disclosure in last year’s suitability thematic suggests the Financial Conduct Authority is already tired of claims it is “too hard” or even “misleading” to tell people how much they can expect to pay for your services.

But trail commission is worse. FCA figures from last year show about a quarter of adviser income from retail investments came from trail paid on pre-2013 policies.

That’s £845m a year.

The public saw the headlines in late 2012 and early 2013 and assumed bias-inducing commission was gone for good. They’re not looking for it on annual statements – and in any case they won’t see it, buried as it is within bloated management fees.

Savers’ lack of awareness and the natural decline in the level of trail mean its continued existence isn’t about to spark a scandal. But that shouldn’t matter – if you haven’t seen a client for years and are still charging them, no matter how little, that’s wrong.

At this point the belligerent few cling to legalities. Yes, a client did sign a form saying they agreed to the terms of a policy, but times change. It’s why we – rightly – scold providers who battled the cap on pension exit fees and those (like Old Mutual Wealth) that retain unlimited penalties for under-55s.

If trail represents a tiny proportion of your business’s income you won’t miss it, switch it off. If you’re reliant on trail, you have bigger problems.

And providers are not helping.

In some cases when advisers or clients switch off commission, the firms just pocket the difference.

Friends Life (now Aviva), Scottish Widows and Aegon are some of the firms where this practice persists.

Aviva told me that “in theory” trail can be switched but “because it is not a free agreed between the adviser and customer”, the customer would “not see any change to the amount they pay”.

There was no suggestion the extra 0.5pc or so simply be handed to the client via another means. I imagine Aviva don’t think it worth the administrative hassle.

It may be advisers’ hands are forced in any case. The FCA has reopened the trail debate following its sweeping asset management market study. A follow-up consultation asks whether the watchdog should ban trail from asset managers (and others) and when exactly the tap should be turned off once and for all.

“Self-employed” advisers relying on trail to fund their own retirement could be affected, the FCA notes, as will advisers counting on trail to boost the value of their business when they come to sell.

Don’t bet on those concerns being enough to stop the FCA enforcing a total ban.

How big a cut to the value of your business would a ban take? If the answer’s uncomfortably high, now’s the time to do something about it.

Zero opinion: Review how much trail commission you currently collect and whether it comes from clients who will pay an increased adviser charge or if you will lose the revenue. How much trail is from products you would find it difficult to justify moving to an alternative product which would pay an adviser charge?