Intermediated Search and the Limits of Financial Advisor Regulation

Jun 29, 2026

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We study a financial advisory market in which low product relevance makes investor search unprofitable without intermediation. The advisor activates the market by recommending high-relevance products, financed by commissions from firms. Raising the regulatory penalty tightens the advisor's recommendation standard. But the resulting higher value of recommendation tempts firms to raise commissions to preserve access. This ``club effect'' partially offsets the penalty's intended effect and shifts part of the regulatory burden onto investors through higher prices. When the club effect is strong, a higher penalty may hurt investors. Disclosure and financial literacy education each attenuate the club effect by reducing firms' incentive to raise commissions: the former by contracting inframarginal demand, the latter by reducing the markup premium sustained by naive investors. When the advisor's information is costly to acquire, disclosure further strengthens his incentive to learn about product relevance.


Fenghua Song

Fenghua Song

Penn State University