“Investors and business analysts looking only at the more studied implementation costs of the rule are vastly underestimating the rule's potential impact on the financial sector,” according to Ellis.

He says the high-end estimates put the rule’s cost to industry at $1.1 billion.

The actual cost of the rule will be in the neighborhood of $2.4 billion, twice what other analysis is projecting, says Ellis.

The report says investment managers—it names BlackRock—and wealth management firms—it names Morgan Stanley—could see their business models “drastically” altered.

To this point, the consensus of analysis says the proposal’s Best Interest Contract Exemptions will make commission-based sales of investment products unprofitable for providers.

If finalized as proposed, the rule will enforce a fiduciary standard of care on all investment advisors to the retail market, and on thousands of advisors to defined contribution plans.

Though the rule does not outlaw commission-based sales, the preponderance of experts say that complying with its prohibited transaction rules will be so costly that advisors of IRAs and 401(k)s will be incentivized to charge a fee for advisory services.

That will address what the DOL and the Obama White House say are the systemic conflicts of interest that cost investors billions of dollars each year.

In its report, Morningstar says that wealth managers “may” convert commission-based IRAs to a fee-based compensation structure in order to comply with the rule.

That will create some new revenue for retirement product providers and advisors.

Fee-based accounts can yield up to 60 percent more in revenue that commission-based accounts, and that could mean another $13 billion in revenue for the industry, Morningstar says.

Robo-advisors stand to benefit from the rule, says Morningstar and other industry analysis.

Morningstar expects between $250 billion and $600 billion of low-account balance IRAs will flow out of commission-based accounts.

Stand-alone robo-advisors, like Betterment and Wealthfront, are expected to capture some of those assets.

The rule will also move more than $1 trillion of retirement assets into passively managed investment funds, says Morningstar.