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BrettH - seems to me you have made your $2,000 costs savings simply by moving the client from Active Managed Funds to Passive - and that's it. The rest of your argument seems to assume the client has not been assisted for 10 years and they are owed an SOA for free. Even if the client has been around for ten years, many many hours of work assisting the client is typical - if you want to get the client to pay directly then the argument for commissions is simply the same as a fee - the client pays in the end just the fee compliance is much more expensive. Moving from Active to Passive and related fee reduction has nothing to do with Commission arrangements.