I completely agree that COBS 6.1ZA.11 requires all costs incurred to be disclosed, regardless of the payment method. The query related more to the interpretation of 6.1ZA.14 50(10) which refers to illustrating the effect of overall costs and charges on the return of the investment. i.e. If part of the charge has been paid direct by the client, it won’t have an effect on the return. So, the table of total charges would include the direct fee, but the section of the disclosure that illustrates the impact of those charges on the return (the RIY) would disregard the direct fee.
This is the specific aspect that I have certainly seen interpreted 2 different ways