One accusation often levelled at the FCA is that it is not sufficiently clear in setting out what it expects from firms.
In its defence (which does not happen very often in these pages) it has tried to overcome this through its use of good and bad practice examples.
But among advisers sometimes it feels like pure guesswork as to whether their business will withstand regulatory scrutiny further down the line.
The regulator is known for being vague both in word and deed, as was shown by the confusion wrought by its independent and restricted definitions post-RDR.
We now have a multitude of labels to describe the different models and services clients can choose from – guidance, robo-advice, low-cost, online, etc. The FCA has also thrown its own terminology into the mix, so we now have advice that can be limited, focused, generic, simplified or regulated. Still with me?
It should not be this complicated to ensure consumers get the advice they need. But it has been made complicated by two indisputable facts: advice is valuable and should be paid for; and not all those who seek or need advice can afford it.
What was already a complex picture is rendered incomprehensible by the backdrop against which advice has to be given, with firms expected to meet escalating costs and serve more people for less money.
Regulated advice has become burdensome to provide, so much so that some big brand companies with the necessary firepower to cater to the mass market are afraid of doing so. The spectre of misselling looms large.
All this has culminated in firms pulling simplified offerings for fear of straying into regulated advice.
There are clients that would be well served by seeing an adviser, and at the moment it is likely they are not being served at all.
There are potential glimmers of hope in amongst all the gloom in the shape of the Financial Advice Market Review, which has the unenviable task of trying to solve all the above. At least this is a tacit acknowledgement from the Government and the regulator that access to advice is an issue they need to resolve.
As any addict knows, the first step on the road to rehabilitation is admitting you have a problem. Policymakers have now made those tentative first steps. But unfortunately the diagnosis is much easier to come by than the cure.
Natalie Holt is editor of Money Marketing. Follow her on Twitter: @Natalie_Holt_MM