Read: SEC sets release date for its own fiduciary rule

In fact, said Capitol, FINRA “has recently made efforts to require disclosure of said incentives to customers as part of the transfer process, but to date, those efforts have not made their way through the rule-making authority board.” But that doesn’t mean that the DOL rule won’t affect them—and the results could change the way recruiting is done.

For one thing, according to Capitol, it could level the playing field for smaller firms, which don’t have the deep pockets for massive recruitment bonuses that the wirehouses do.

In addition, those bonuses often come with strings attached; production levels and quotas for proprietary products.

Capitol, a Virginia-based regional broker-dealer with a presence in 14 states and Washington, D.C., $4 billion in assets under management and about 18,000 accounts, said that under the new rule, both traditional and independent advisors might have to justify any recruitment bonuses as they apply to retirement accounts—showing, for instance, how the advisor’s move to a new firm would benefit the advisor’s clients.

This could be one of the unforeseen effects of the fiduciary rule, and it could result in as yet unquantified but perhaps substantial compliance costs for broker-dealers.

Larger BDs and wirehouses have been thought to have the advantage, since they have the financial wherewithal to foot the bill for any increased compliance costs.

Smaller independent BDs were expected to be the ones to struggle under the new requirements.

However, according to Capitol’s president Mark Hamby, that may not necessarily be the case.

In a statement, Hamby said, “When it comes to recruiting advisors, the new fiduciary ruling has the potential to be a game-changer between large and small firms. As a privately owned advisory firm and broker dealer, we don’t compete with the big checks large wirehouses issue as recruitment incentives.”

Instead, other attractions bring new talent, and the firm’s payout grid is “dollar-neutral,” not favoring any one product over another. Firms that rely on “the big check” as a recruiting tool, said Hamby, “will be left scrambling.”

It remains to be seen which firms emerge the winners and which the losers.