He said the regulator was failing to take account of how technology is changing the landscape of financial services.

The review was announced on Friday with the FCA saying its proposals will give millions access to 'simplified advice' on investments and pensions.

It received a mixed reaction, with most industry experts welcoming the proposals. But some warned that the boundaries between advice and guidance must remain clear to avoid consumers being mis-sold.

Mr Velani echoed that warning, saying that the regulator was "courageous" to seek to reduce uncertainty and confusion by introducing two new levels of service when consumers are already struggling to understand the difference between guidance and advice.

But, specifically, he said the review failed to take account of the “rich data’ companies now have about consumers at their disposal.

He said: “The Review states that targeted support, "would be based on limited customer data and the consumer may have individual needs that have not been identified." This makes sense if a product manufacturer has only limited customer data.

“However, increasingly, there is access to much richer data through the growth of open banking and product aggregation services.”

He asked whether financial service firms would be allowed to ignore the rich data they hold for some of their customers to put them into broad groups with similar characteristics.

He said: “Is it ok to suggest to customers who appear to be heading for poor retirement outcomes, that they increase their pension contributions when there is data available showing that some of them have high levels of credit card debt? Ignoring this information does not seem to sit well with Consumer Duty.”

Working through all the complexity is going to take a lot of time, he pointed out, “not allowing, of course, for a potential change of Government, so we shouldn’t hold our breath.”

He urged the regulator to try to get ahead of the curve and understand how technology such as AI is going to transform the effectiveness of guidance and improve the efficiency of delivering advice.

Meanwhile Bernie Hickman, chief executive of Legal & General Retail, said the proposals address many of the gaps in the regulatory framework, potentially allowing more people to benefit from practical support.

He said consumers will continue to make Ill-informed choices without reforms to the legislative and regulatory framework around advice.

Mr Hickman said: “Due to the regulatory restrictions currently in place, we as providers cannot prompt, nudge or alert customers to options that might offer them better retirement solutions and the paper sets out a positive way forward to address this.

“Furthermore, the proposals could give providers the ability to alert customers if they are at risk of receiving an inadequate income at retirement – potentially in time for them to take action to improve the situation.”

He concluded the FCA’s three proposals mark a significant effort to foster innovation in the financial services sector, and to empower more people to make informed financial decisions.