Only just spotted this post – don’t know if you found an answer elsewhere but my reading is in line with the second. COBS 6.1ZA.11 refers to all costs incurred being required and the following clause refers to the same information as having to be aggregated. Maybe the reasoning is that if the fee wasn’t to be paid the client would have more to invest therefore a direct fee does impact on the returns the client could otherwise have received.
Vince