On August 3, 2009, Certified Financial Planner Board of Standards, Inc. (“CFP Board”) issued a request for comments on the proposed addition of a Financial Plan Development Course requirement to CFP Board’s education standards. The proposed addition is intended to enhance the knowledge, skills and abilities of individuals seeking to attain CFP® certification and implement an assessment of their ability to deliver professional and competent financial planning services to the public.

Comments received during the 60-day comment period, which ends October 2, 2009, will be reviewed and considered by CFP Board. Comments received will be posted below on a weekly basis.

Note: The views, expressions, findings and opinions expressed in the comments on this Web page are solely those of the author(s), and CFP Board accepts no responsibility for the content of the comments. Comments received via e-mail have been provided in full below.

Comments

Updated October 5, 2009


FRED AKERS, CFP®

Date: August 31, 2009

As a member of the CFP since 1988 I am writing for the first time since I am disturbed with the email received today.

As a practicing money manager and portfolio manager with a national wire house, I would like to suggest that the CFP board stop adding additional courses, and continuing education requirements to its members.

Many practitioners, like myself, already have continued education requirements that are mandated by the SEC, state regulators, and in-house compliance departments that add as much as 35-40 hours of additional work to our already full schedules. Each and every licensed agent and financial advisor is expected to give prudent advise subject to the needs and financial objectives of the client. Should the financial advisor fail to do so will expose him/her to possible legal action.

The board should STOP thinking about how to add more courses, training and work for their membership or future membership. It is a nice idea to offer a course for application of the concepts learned in the CFP course, but let that be a part of the curriculum not an additional course.

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TERRI AMERIO-BELL, ENROLLED AGENT, CFP®

Date: August 3, 2009

Hello – I am a Certified Financial Planner™ and Enrolled Agent. I support adopting a Financial Plan Development Course Requirement as a prerequisite for exam eligibility.

I am not a fan of the Board’s long standing practice of excusing “Individuals who have certain financial planning-related educational experiences or licenses – including those who hold a Ph.D. in business or economics, a Doctor of Business Administration, an attorney license or a CPA license” from the course work study that others must take in order to apply to sit for the certification exam. Although some persons with the aforementioned licenses and credentials are well-rounded and keep current in related fields, many do not. For example, in my experience, Enrolled Agents should either be included in the above group, or CPAs should be removed from the list. Attorney experience also does not necessarily give an individual experience beyond tax or estate planning into the other slices in the financial planning pie.

This is just a thought I wanted to pass on to the powers that be although I am not anticipating any change in this area.

Thanks for taking on the important task of preparing applicants to successfully represent the profession once they have obtained the prestigious CFP® designation.

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STEPHANIE E. ANABLE, CFP®

Date: August 3, 2009

I think it would be a good idea to add this class to the program. It is an important tool of any practice to be able to actually develop a plan.

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NICK ARELLANO, CFP®

Date: August 3, 2009

I think this is a great idea and should be included as a prerequisite!

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JESSICA ANDERSON, CFP®, CIMA, CPWA

Date: August 4, 2009

I do not feel it is necessary

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MELISSA L. ANDERSON, CFP®

Date: August 4, 2009

I think the Financial Plan Development Course should be added as a requirement. Not only is financial planning the center of what most of us do, it is a crutial part of being a CFP. I believe this course will add alot of value and education to certificants.

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NICK ARELLANO, CFP®, Investment Adviser

Date: August 3, 2009

I think this is a great idea and should be included as a prerequisite!

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JESSE ARMAN, PHD., VICE PRESIDENT, ACADEMIC AFFAIRS, COLLEGE FOR FINANCIAL PLANNING

Date: September 3, 2009

The College for Financial Planning generally agrees with the intent of this proposal and believes that this requirement is far more appropriately placed in the experience, rather than education, area. This is the same position advocated by our largest corporate clients, all of whom carefully vet CFP aspirants for plan creation and presentation abilities prior to permitting enrollment in the CFP education program.

For the extreme minority of CFP aspirants who are undergraduate, traditional-age students yet to embark on professional careers, it seems undeniable that creating integrated financial plans and providing related presentations is especially worthwhile. Even the most technically adept planner cannot succeed without the communication skills necessary to convey information and foster client trust. For this reason the College for Financial Planning requires a robust integrative capstone course in its Master of Science degree program that far exceeds the 45 contact hours required by this proposal.

Within the last few weeks, I have spoken with the training directors of the five financial planning firms that comprise the College’s largest sources of enrollment in the CFP education program. Each of these corporations underwrites CFP education study only for experienced planners. Depending upon the corporation, “experienced” is operationalized in terms of years in practice, production, assets under management, or some combination of these factors. Typically, the successful planners who comprise the College’s enrollment have a minimum of three years of active planning experience and at least 100 clients – and most have more.

The training directors described the requirements in the proposal as unnecessary and redundant in that their CFP-seeking employees have repeatedly proven their abilities to create and present plans. Additionally, these planners have done so in very high-stakes environments, with professional success on the line, as opposed to doing so in a low-stakes classroom. The training directors collectively question why their companies should pay for additional coursework, with the resulting delay in program completion, for an outcome that replicates what these students already do on a regular basis. Essentially, an inability to use the corporate-provided software required to create a plan, or inability to communicate such plans, leads in almost all cases to dismissal from the company long before a candidate is approved for CFP education. Accordingly, a very large majority of the students enrolled in the College for Financial Planning’s certificate program have already prepared a substantial number of plans and made hundreds of presentations to clients.

The proposal becomes philosophically, logistically, and financially problematic for larger certification programs. These programs would be compelled to increase tuition to clients, who view the proposed requirement as unnecessary. The College estimates that it would have to review an average of four plans and presentations each working day of the year. This represents a significant resource commitment, the cost of which would have to be passed on as a price increase to clients. The College expects that client resistance to such price increases would be immediate and vocal during a time of crippled training budgets. Perceiving no evident benefit to the requirement, training directors would likely consider other educational directions and designations for their employees.

As noted during the August Program Directors’ conference, such companies collectively send well over 4,000 CFP students annually to the three largest certificate programs. Related is the fact that these are the students who actually sit for the Certification Examination. Statistics provided at the 2008 conference indicate that approximately 95% of registered program sitters come from certificate programs, and only 5% come from degree programs (where program directors report that fewer than half of undergraduate completers actually sit for the exam). The proposal, therefore, seems to be concerned with a very small minority of actual sitters. I believe it is counterproductive to contrive a further disincentive to pursuing CFP certification at a time when the number of exam sitters has been declining annually since 2006 (in fact, there were 275 fewer sitters in March 2009 than in March 2008 – an almost 12% decrease).

Related to the foregoing is the recommendation to utilize CFP certificant members of the FPA to assess the plans and presentations. In return, these certificants would receive CE credits. Though well-intentioned, the suggestion is, at best, impractical. Assuming the previous estimate of four plans and presentations per day, the College would have to engage perhaps 200 different FPA members, each reviewing up to five plans per year. Recruiting, vetting, selecting, and monitoring qualified faculty among the FPA members, as well as scheduling and matching candidates with certificants, would necessitate the addition of at least one full-time position.

More importantly, the addition of 200 new faculty members—all of whom must be immediately available; grade quickly, fairly, and consistently; and all of whom must be willing to work for CE credits—is both an enormous and ultimately unsustainable logistic challenge. This model crumbles when a certificant’s more important commitments arise, when a certificant doesn’t get back to a student in a timely manner, when a student fails and wishes to contest a result, and inevitably when the certificant tires of working for free—or when he or she realizes that the time and effort involved to provide thorough, credible reviews is not worth CE credits.

For these reasons, the College’s position is that this requirement is far more appropriately placed in the experience, rather than education, area. The College believes that the three years of experience required of all certificants is more than enough time for new planners to prove their abilities to formulate and present plans. The ability to perform these tasks is infinitely more important and has more tangible and objective outcomes in a real, professional situation than in a classroom where actual clients may be years away.

CFP Board could validate this experience via affidavits from employers. In infrequent cases where aspirants have not completed or presented a plan within three years of entering the field, the Board could arrange to have the candidate present a completed plan to an FPA member.

The College appreciates the opportunity to provide input regarding this proposal.

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SAM ATTALLA, CPA, CFP®

Date: August 7, 2009

I read about the proposed financial plan development course requirement for CFP® Certification, and I agree with the proposal. That will give all financial planning candidates an opportunity to have an exposure to the financial planning process.

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MIKE BABIN

Date: September 27, 2009

I think it is another roadblock to preventing more people from becoming certified. The current system of annual testing and 3 years of practice is sufficient. Perhaps a written plan would be OK, if you can do it without adding additional cost to the process.

You appear to want to make CHANGE for the sake of change, just like Obama is attempting to do by changing our country into a communist muslim country.

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BEVERLY A BAILEY

Date: August 19, 2009

I think a real life financial plan should be required as part of receiving your certification. We all come to the program with different areas of expertise. Putting together a comprehensive plan will not only integrate all the course work but will also identify areas of weakness in our knowledge.

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MICHAEL T BAILEY, CFP®

Date: August 5, 2009

Do what ever you feel necessary just dont create any more work for me to do my job!

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MICHAEL W. BALDERSON, MBA, CFP®, Investment Adviser

Date: August 3, 2009

I think this is a good idea. My broker / dealer required me to complete a financial plan and submit it for review before we were allowed to work in this area with clients. It would make sure an advisor has a basic understanding of finance, budgeting, and forecasting before they sit with the public.

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TIFFANY B. BALLARD, CFP®, AIF®

Date: August 4, 2009

I fully support the Board’s decision to implement a Financial Plan Development Course prior to sitting for the exam. This is a wonderful idea and will help strengthen the profession.

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REGINA GALVIN BALLINGER, MBA, CFP®

Date: August 6, 2009

Sounds like a welcome addition to the requirements.

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AARON BATES, CFP®

Date: August 5, 2009

I think this proposed Financial Development Course is a great idea.

It seems to bring all the training together for the desired end result - which is the financial plan. If a CFP candidate can't bring it all together to do a plan than they are not ready to be a CFP Professional.

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DANIEL L. BEAUCHEMIN, CFP®

Date: August 10, 2009

I agree that this course should be incorporated into the curriculum. This would be a fantastic and incredibly useful addition to the knowledge core. Having recently passed the CFP exam and completed the educational component, the only aspect I felt lacking was how to develop a detailed financial plan for a client from A to Z.

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ANTHONY J. BELLOLI, CFP®, CIMA®

Date: August 4, 2009

I think overall this is a great idea and should be implemented in some way. Anything that makes the certification a bit more difficult to achieve, will also make it that much more respected and desirable. However, I don’t think it should be too much of a burden on individuals pursuing the certification. 45 contact hours seems a bit excessive. Also, I’m not sure how the board plans to listen to all of the oral presentations. Maybe a written case study will do.

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DUSTIN L. BENCH, CFP®

Date: August 3, 2009

I am strongly in favor of this course addition. Through my training and exam preparation, as well as in my daily practice, I find it difficult to find any real standard of how to present a plan to clients. If this course is done properly, I'm sure it would add value to any client's experience with financial planning. Furthermore, it would reduce the number of poor quality plans that are presented to clients currently.

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A. Raymond Benton, CFP®, CRPC®, EA

Date: August 28, 2009

I am writing to comment on the CFP board’s proposed Financial Plan Development Course and requirement. The course is a great idea, but the requirement should be more general and be in the nature of a “thesis” including an Oral presentation and the thesis could include a financial plan or an original contribution to the planning process.

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WILLIAM H. BENDER II, CFP®, CRPC®

Date: August 4, 2009

Having gone through the training program at Merrill Lynch I did much work on and training in the proposed field of making a Financial Plan, that being said if there are people who haven’t gone through this I feel it would not only be beneficial but necessary to fully grasp what it is a CFP® will be doing day to day.

I never once thought about that fact that some of the people I was testing with and now call fellow CFP® may have no training in actually preparing a financial plan.

I think this is a great addition to the curriculum.

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FRANCIS BERGMEISTER, CFP®

Date: August 3, 2009

Think this a great idea but it is very labor intensive and open to subjectivity in judging.

Are the folks doing the preparation doing the assessment?

Seems this could just become another course requirement.

I would argue and earlier have proposed that such a course be used to allow individuals to gain 6 months of experience.

The idea here would be to make it an attractive option for new financial planners.

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JENNIFER RAY BERTHEUSSEN, CFP®, CDFA

Date: August 4, 2009

GREAT IDEA!!!!!!!

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WILLIAM B. BISSETT, CFP®

Date: August 4, 2009

I support the decision to have individuals go through a course that requires them to write a comprehensive financial plan. However, I have concerns about forcing students to present it orally. Would we expect them to present the plan to their classmates? What would be the requirement for the student’s presentation? How much would the presentation represent in the overall score?

One of my primary concerns is that as the CFP® continues to grow, we are going to have more individuals who are seeking the designation that do not want to be practicing financial planning professionals. They may want the designation for many reasons other than working directly with clients. So by forcing students to present the plan, we may end up putting some students who do excellent analysis to perform at a level they are not comfortable with – public speaking. I would agree that everyone is well served with the ability to speak in front of an audience but I don’t think that we should be judging our future colleagues on it if it is not part of their plan.

On the other hand, if the curriculum required that the students work with disadvantaged families to create a comprehensive financial plan and then present the plan to that family, then I would support the decision whole-heartedly. This would have a huge positive impact on how the public view financial planning and it would not be unheard of for students to do this (after-all, dentists have to schedule their own meetings and look after patients there last few quarters in school). The benefits of working with smaller, disadvantaged clients are huge. Once you get the basics of the process, it becomes a building block process.

Thanks for your continued efforts for improving the education requirements of future financial planners.

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JASON BORMAN, CFP®

Date: August 4, 2009

I think any efforts which help maintain the highest standards is always positive. I endorse this additional educational requirement.

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MATTHEW P. BOYLE, CFP®

Date: September 9, 2009

I think this addition is a solid one that should be implemented. Being a Certified Financial Planner™ certificant should not be based on whether the applicant has the software programs or assistants to perform these tasks for them. Nor should this course be a means of making sure the planner can "make the sale" through presentation skills. The goal of this coursework has to be proving that the applicant has a sound understanding of all aspects of financial planning and not simply the ability to pass an exam, sell a product, or input data.

Keep in mind the old adage; Half of the people graduated in the bottom 50%. This is just as true of planners as it is doctors, mechanics or lawyers. Proving your ability to truly understand the various planning tenants and bring them together to build a cohesive plan should be - if not remain, a fundamental aspect of becoming a Certified Financial Planner™ practitioner. Otherwise you could always stop after taking the series 7.

During my studies for the exam, I did participate in an optional class which followed the general guidelines of comprehensive planning and problem solving. I found it to be a wonderful warm-up for the exam, as well as means of helping me integrate the various disciplines. And while mandating the class for new applicants would be a great benefit to ensuring competence, I would be against adding any additional CE requirement, or forcing existing certificants to complete the class. At this stage, any existing certificant has learned through trial and error how to provide comprehensive planning, and most CE courses (though as we know, not all) that cover the specific areas are designed to keep certificants proficient and knowledgeable of changes, regardless of when you passed the exam. However, there could be some call for requiring non-practicing certificants, who have not been actively involved in the planning industry and are now looking to re-enter, to become "re-certified" through CE. This could be done via a computer testing situation, similar to the existing FINRA industry level CE.

Going forward, instituting this new comprehensive planning module can help ensure that certificants continue to come from the top half of the world of financial professionals. Count me in.

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JAN L. BRAKEFIELD, M.S., CFP®, ASSISTANT PROFESSOR, PROGRAM DIRECTOR, UNIVERSITY OF ALABAMA

Date: August 3, 2009

I am completely in agreement with the proposed requirement. We have required a capstone case study course since the inception of our CFP Board Registered Program. Our students report feeling much more prepared and confident about their planning skills upon completion of the course.

 

Date: September 4, 2009

I attended the CFP Directors Conference in August in Arlington, VA. After hearing the many suggestions and concerns expressed, I am in favor of requiring a comprehensive individual case analysis of each person who applies to sit for the CFP® Exam. There are many students in CFP Board Registered Programs across the U.S. who never plan to sit for the exam. Asking them to complete the case requirement would serve no direct purpose, but would create undue hardship on program directors, especially those managing on-line courses.

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SHEILA BRAND, CFP®

Date: August 4, 2009

I like this idea and I think it makes sense.

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ADAM BRENNEN, CFP®

Date: August 3, 2009

I would like to comment on the proposed additions to the educational requirements in order to sit for the CFP® Exam. I think this is a great idea. If this was added as an undergraduate, or graduate level course required to obtain a degree, it would be helpful for this course to include case studies. This was the format of the certificate program I took at Rice University. It worked very well as it help to view a situation from a comprehensive viewpoint while integrating each of the discplines required for the Exam. Thank you for making the CFP® designation even more prestigious.

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RONNI BRETSCHNEIDER, CFP®, CRC

Date: August 4, 2009

I think it's a great idea. I got my CFP in 1989 when you actually wrote out a case study for all 6 courses. I could never understand how the new short answer 1 1/2 day exam equated.

In my opinion multiple choice questions don't really prepare you for writing and presenting a plan. I have been an adjunct professor in the program at Bergen Community College (Estate Planning) and also taught several of the courses at Charles Schwab and MetLife. All we wound up doing was teaching to the exam rather then teaching the practical things you need to know to do planning for individuals. Technical knowledge is great but what you use on a day to day practical basis is key.

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BRIAN H. BREUEL, CLU, ChFC, CFP®

Date: August 4, 2009

The proposed Course requirement would strengthen the curriculum. As we search for ways to provide a higher quality of advice and counsel to the public, programs that address the fine art and science of Financial Planning advance our efforts. I’m reminded of the computerized financial Plan that a major NYSE firm required of their brokers in order to earn maximum compensation under their payout grid. The “Plan” was satisfactory but very few of the brokers could deliver it because they lacked training in financial planning. One firm wanted me to remove the CFP™ designation from my business card because they didn’t want to give the public the impression they did financial planning. Naturally I went out on my own.

I’m not sure oral presentation skills should be part of the requirement. Many students will be back office or support personnel not making presentations. I would rather have them spend that time on the art of reasonable projections and expectations.

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SHAWN M. BRICKLER, CFP®, EA

Date: August 4, 2009

The addition of the proposed requirement seems like an attempt to actually dictate the knowledge of the prospective CFP® certificant in how to construct a financial plan based on strict financial plan building rules, similar to accounting rules, I do not support it. The proposed requirement that individually written and especially oral presentations be judged according to someone else’s thinking is not conducive to a financially open minded thought process imo. It seems there is some attempted ego building in our profession going on, and an attempt to make financial planning guidelines similar to CPA rules, where things are judged one way, similar to CPA accounting rules.

The purpose of the proposed Financial Plan Development Course requirement is to have individuals seeking to attain CFP® certification demonstrate their ability to integrate and apply the financial planning topic areas to a scenario based on the types of situations a practicing financial planner might be expected to address with clients.

Based on whose interpretation?? Any “Guided by CFP Board’s Financial Planning Practice Standards” judgment of a written or oral presentation is bound to be subjective (as financial planning is) based on the individual judgment of each “professor” unless strict interpretive rules are applied to the subjective standards. This does not promote the idea that there is more than one way to a future financial destination in my opinion. You will have some “professors” judging some presentations based on the letter of the “law” and some by the spirit of the “law”, on top of the fact they will bring their own opinions to their “judgments.”

It kind of seems as if what you are saying, is the current standard of education for CFP® certificants is or was not enough, and that you have to dictate to future CFP® holders how to construct plans in order to make sure they do it “right”. As though our CFP Board Financial Planning Practice Standards are not enough. A “standard” is not supposed to morph into a law in my opinion.

As someone having the CFP® designation for almost 18 years, it seems the intent is to create some strict standard of financial planning operation. I find the industry creating the same bureaucracies it once fought against. Clients aren’t served by bureaucracies, they are served by people, and in my opinion the client relationship determines the success of a financial plan, not the paper it’s printed on.

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CALEB BROWN, MBA, CFP®

Date: October 1, 2009

This is a terrific idea. It should be mandatory for people who want to become financial planners to develop and present a full plan as part of their training in becoming a CFP certificant. The implementation details within academia are going to be tricky, but a large # of programs already have this requirement in place so it definitely can be done. If done correctly, this could further help newer planners enter the industry better equipped with the skills firm owners are demanding for their entry level hires.

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CATHY M. BUCHANAN, CFP®, AAMS®, CRPC®, CEP®

Date: August 4, 2009

I support the proposed change to require the Financial Plan Development Course, provided it will apply to all candidates.

A proposal: CPAs and JDs, among others, can opt to apply for challenge status without coursework. This proposal is an addition to the education standards that conceivably could be outside the experience of CPAs and JDs and the others who can apply for challenge status. I propose that even those who apply for challenge status provide documentation of completion of a Financial Plan Development Course.

If it's going to be required, it needs to be required of all candidates.

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GARY D. BURGER, CFP®

Date: August 9, 2009

CFP® certificants should be able to present orally and written a comprehensive financial plans. However, the continuing education requirements each year of a typical CFP® certificant that is insurance and securities licensed is rigorous and expensive to say the least. At some point in time we do have to work in order to pay for the continuing education requirements each license requires. After passing the strenuous tests required to become a CFP® certificant, most planners understand how to construct and present plans. If the board were to make it an optional continuing education course and not required, the planners who do not feel sufficient in that area could choose to take the course as continuing education.

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CATHLEEN BURNS, MBA, CFP®

Date: August 4, 2009

I think it's a great idea and wholeheartedly support its implementation.

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JANICE CACKOWSKI, CFP®

Date: August 12, 2009

I think the Financial Planning Development course is a great addition to the CFP curriculum. It is a course that will pull together all of the topics discussed in each course and will help candidates be better prepared to offer financial plans to clients. I wish such a course were offered when I was studying -- when it is offered in my area, I may go back and take it to assist me in my own business venture.

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SANDRIA M. CALIO, CPA/PFS, CFP®

Date: August 27, 2009

I agree with adding a course to create a financial plan for CFP candidates. I think it is important for a candidate to understand financial planning from a wholistic point of view and how one decision could impact another area of a client’s financial plan. I believe the consumer deserves that wholistic knowledge when working with a CFP®.

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CONNIE CAN

Date: August 3, 2009

I support to have this requirement.

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SARAH CANNON, CFP®

Date: September 4, 2009

I believe the proposed Financial Plan Development Course will be of great benefit in maintaining the high standards of the CFP® designation. The ability to test well on content of the currently required courses does not assure the ability to apply that information to a financial plan.

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KEVIN P. CARSON

Date: August 4, 2009

Financial Plan Development should be part of working experience, like the CPA designation. At least 2 years documented experience in planning with a firm that has been approved by the CFP Board and under the guidance of a CFP.

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DR. INDU CHHACHHI, PROFESSOR OF FINANCE, DIRECTOR, FINANCIAL PLANNING PROGRAM, DIRECTOR, TVA INVESTMENT CHALLENGE PROGRAM, WESTERN KENTUCKY UNIVERSITY

Date: October 2, 2009

It is an excellent idea for candidates to be trained in subject material related to financial plan development. In a "Perfect" world without any resource constraints, that is where I'd end my comments. However, our programs are constrained by real resources (or lack thereof). As I attended the Program Directors’ Conference last August, this was one of the major concerns heard across the board—and it certainly IS a concern for us as well. This requirement represents a 20% increase in need for faculty time in the area of financial planning (we currently teach 5 courses that can be looked upon as either purely or largely planning courses). It is true that larger programs will not feel this pinch—or at least the impact will be less severe. However, for programs that are already bursting at seams and where faculty are being asked to do ‘more’ with ‘less,’ this requirement will become the proverbial straw that breaks the camel’s back.

Of course, there is a way for us to get this implemented without significantly increasing the resource needs—impose this requirement on ONLY the people that pass the CFP® exam. This would accomplish the goal of making sure that CFP® Certificants are, indeed, fully trained to deliver the product that they are certified for—without imposing the additional burden (on students, faculty, as well as programs) of this course on 20 -80% of other students who either don’t intend to sit for or are unable to clear the CFP® exam. Finally, as we expand the requirements there is also the real potential to scare off some students—who otherwise would have been good potential planners. As a profession we should always be cognizant of this possibility.

As a ‘new’ director of a very ‘old’ board registered program, I welcome the opportunity to comment on this and will hope that the comments (mine and all others) will, indeed, be given serious consideration as you finalize this decision.

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E. TYLOR CLAGGETT, PH.D., CFA, DIRECTOR, FINANCIAL PLANNING TRACK, PERDUE SCHOOL OF BUSINESS, SALISBURY UNIVERSITY

Date: September 8, 2009

We are in general agreement that ensuring a candidate’s ability to develop, write and present a viable financial plan is a desired attribute for CFP® certificants. However, we are not convinced that a course specifically dedicated to this purpose is necessary, or practical, particularly with the very limited information we have been provided regarding details of specific topics to be covered, the method of instruction, suggested rubrics to measure performance, etc. The truth is, after the recent Washington, DC CFP-Board’s Program Director’s meeting, it seems that even the original proposed course duration of 45 contact hours is still being debated. While it is desirable for CFP certificants to have the capability to develop and present Financial plans, one must remember that CFP® certification requires a 3-year related work experience, and one would assume these skills would most likely, and most appropriately be acquired during this work experience. Normally, one would expect educational programs, and particularly degree-granting programs, to provide the necessary academic preparation for financial planners, with additional practical skills acquired through work experience.

We have reservations regarding this proposal in several additional areas:

1) For an undergraduate degree program such as ours, a 45 contact hour course would translate to a one-semester (three semester hour) course. It is assumed the proposed course content would address how to write and orally present a comprehensive financial plan to a relatively complex client. Furthermore, it may be assumed such a course would require students to complete financial plans for actual clients, or perhaps one or more cases. To be able to do a credible job with a comprehensive financial plan, presumably students would take such a course AFTER all of the core financial planning courses. However, requiring such sequencing would add an additional semester to the typical undergraduate student’s course of study.

2) If we were to require each student to present a comprehensive financial plan as part of a course, and if one could reasonably expect each such presentation to take 30-45 minutes, assuming a typical undergraduate class size of 25-30 students, somewhere up to half of the 45-hour course would be spent in presentations alone, leaving essentially very limited instruction time for a meaningful outcome.

3) If the primary target is presentation skills, our business school curriculum, along with most others, already emphasizes oral and written communication skills. Good presentation skills are desired outcomes that we all pursue and assess. Most academic programs already have in place curricular initiatives to ensure these outcomes as part of the overall academic requirements. Therefore, having such requirements in a course specific to financial planning may be overly redundant, and impractical.

4) Finally, the addition of another specialized three hour course would undoubtedly result in fewer three hour electives for our students as we are committed to a 120 semester hour bachelor’s degree. Therefore, requiring another financial planning course will result in a reduction in the breadth of students’ training.

In closing, we believe requiring such a course will be impractical, and a hardship for the degree-granting academic programs and it is more reasonable to expect that the practical experience requirement should be the avenue by which to ensure CFP® certificants have the appropriate experience with preparing and presenting comprehensive financial plans.

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ROBERT A. COCHRAN, CFP®

Date: August 4, 2009

While this may serve some purpose, I strongly disagree that this should be a requirement for all persons seeking to take the CFP exam. The fact is that very few planning companies do complete plans. Most do modular plans, around a few topics. And a lot of companies do not provide written financial plans. Thanks goodness, since some of us can still remember the 2-3 inch thick binders we gave to clients in the late 70s and 80s, that sat on shelves, never to be looked at again.

Another facet is that many people who seek the CFP credential will never be involved in financial planning, per se. They will use their experience to work exclusively in the investment arena, or estate planning, or other areas where a complete financial plan may not be very useful. They may need to look at only a few aspects of a clients situation, such as lifetime income planning, etc.

I am all for making sure that folks who obtain their credential are qualified, but this new proposal strikes me as just another barricade to those who might be terrific in the jobs they do, but not want to go through the hassle of one more requirement that is of not much value to them. The current test is difficult enough, given the fact that folks have to work out problems in long hand their computers will be able to handle for them, or deal with specific mini-subjects and terms they will probably never encounter in real life. How about making the exam more real-life? This would be a step in the right direction, in my opinion. When I hear what some of the questions involve, especially the investment area, I just shake my head and wonder what the testing people are thinking. After working as a CFP practitioner for 20 years, I know some folks who are terrific planners that cannot pass the exam, while others who are much less capable pass the exam the first time. Something is not right.

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RITA D. CONLEY

Date: August 11, 2009

I believe an applied course that would teach students to actually develop a financial plan is needed. However, It would increase the number of hours students must take. It would also mean that FFP could potentially become a minor if this course and a capstone course are added. The students would have 21 required hours for the certificate we offer and an elective capstone course to total 24 hours. A minor in FFP may be attract some students at our university.

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SCOTT CONNOLLY

Date: August 3, 2009

I agree with adopting the proposed Financial Plan Development course as a prerequisite for all individuals wishing to take the certification exam effective 1-1-2012. I feel this added educational element will serve to better ensure candidates are able to meld the broad range of topics learned into an accurate and clearly presented (written and verbal) Financial Plan. The ability to effectively apply learned concepts is every bit as important as textbook knowledge and is integral to the advisor/client relationship.

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DOUGLAS R. CONOWAY, CFP®, ChFC

Date: August 4, 2009

This proposal completely “misses the boat.” Having worked with CFP student interns and hiring one, this is not where their greatest need is. The training they receive already prepares them to successfully develop a comprehensive plan and provides a thorough understanding of important financial concepts.

What they really are deficient in is an absence of development in interpersonal skills. While sufficient in technical matters, they haven’t learned the sales skills and people skills needed to successfully implement the plan nor develop client relationships necessary to “make” a client. This limits their ability to be hired and the pay they receive in the real world. The Board is doing these students a major disservice by ignoring this critically important skill set.

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SUNNE COPE

Date: August 3, 2009

Think the addition of a Financial Plan Development Course to the CFP certification requirements is an excellent idea.

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K. SHAUN COSBY, CFP®

Date: August 4, 2009

In my opinion I feel that the addition to the CFP® of a financial plan development course would be a positive step. While I have a background in financial planning and doing financial plans at my old financial services firm many do not have that same background. By having this requirement it would ensure that every CFP® candidate would have to learn how to build a financial plan prior to receiving their certificate and I feel that it would be good thing. To many registered representatives do not focus on the entire picture, I see this everyday and by constructing a financial plan one realizes the value that every CFP® should bring to their clients in every relationship they have.

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RICHARD L. COX SR, A CHIEF INVESTMENT MANAGER

Date: August 4, 2009

Financial Planning is an art as well as a science therefore everyone who completes a plan will use their current level of knowledge in both the review and preparation of the factual information, which depending on how it is interpreted by the planner may have very different outcomes.

So if we are going to test proficiency in financial planning we must educate to a desired level of knowledge, and even then we must have a range of potentially correct answers to encompass the application of the knowledge learned. This is similar to a case study which has stated facts and histories but given to seven different planners we will get seven different plans all influenced by their application of their experience, knowledge, and understanding of the information presented and each would be correct.

The oral requirement in this case would have to be required because the examiner would have to be able to question the student and determine if the subject matter was adequately mastered to the point that they felt the student could replicate the required skill level on their own.

The question this raises in my mind is the time required to complete the exercise, the back log of students wishing to finish the course, the number of oral examiners required to allow each student an individual interview, the cost associated to running such a program and developing acceptable standards for each examiner so that consistent results were maintained within the wide range of acceptable outcomes, the ongoing rotation of case facts to keep up with changing tax, legal, and financial regulations and an examiner versed to render accurate and consistent grading.

If we look to Academia to provide the examiners then traditionally their mindset of true/false or multiple choice questions may present a problem, in other words they rely on absolutes which prohibit relative answers as proposed. What we are discussing is practice management and therefore should require an examiner who has mastery of the subject matter and its actual “application” which is not normally found in American Colleges and Universities.

It would therefore appear that to have such a Master Examiner one would have to seek current practitioners to serve in the position to determine if the student has acquired the necessary skills. This of course would mean the CFP Board would have to develop a method to recruit existing CFP® Practitioners who would be willing to serve in this capacity, and in sufficient numbers not to have a backlog that defeats the purpose of the exam and within the geographical locations to the educational institutions themselves, and all similarly instructed on the grading methodology to ensure consistency.

While an acceptable answer may be found, I suspect more research and planning is required to fully understand the logistics of this additional component.

As a side note: Most Professions require the graduate serve under a residency program for a stated number of years before allowing them to practice unsupervised, this may also become true for the future CFP® Certificant to provide the expected level of proficiency, and possibly the CFP Board should consider such a requirement change to the experience requirement to include an apprentice period for graduates who focus on being a practitioner.

This may put at odds those CFP® Certificate holders who are Practitioners and those who are not, but personally I do not see any problems between a MD who practices medicine and one who teaches medicine, same level of education different application, however both had to complete a residency program.

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GEORGE CULLINAN, CFP®

Date: August 4, 2009

This new Financial Plan Development Course sounds like another road block to certification. Case studies are already a part of the certification process.

The purpose or goal of this additional course work is not at all clear.

Most Financial Advisors already have some kind of presentation or proposal format that they are comfortable with. Is the purpose of this new requirement to make proposals or “financial plans” homogenous throughout the industry? If that is the case, I don’t think it’s an attainable goal, nor would it be beneficial.

Each of us has a process that we use with clients and prospective clients and I see little value in trying to make my process or proposal look just like my competitors’.

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GEORGE DANUSIS

Date: August 3, 2009

I am pleased with your direction.

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KEITH R. DAVENPORT, CFP®

Date: September 16, 2009

I’m in favor of a financial plan development course being added to the CFP curriculum as if would allow students hands-on practical experience in developing a comprehensive plan that now is the norm for many financial services and wealth management firms.

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BARBARA J. DAVIS, CFP®

Date: August 5, 2009

I think this is an EXCELLENT addition. As all CFP® practitoners are not from the same background, experience level, or perform all of the duties of a CFP® on a regular basis in their careers, this would provide an opportunity to see that the CFP® candidate is capable of using all available planning options, has a degree of understanding of all issues - tax, insurance, investments, etc. and can use them in practical application. It ties all of the information together. A case study/presentation, especially oral, would demonstrate the candidate's ability to explain a complex ideas and legal requirements in plain english, or so that an average client would understand and therefore benefit from the CFP®'s services.

I would envision 12 cases created by the testing Board with a point scoring method for presentation of the CFP® standards:

  1. explaination of the CFP® duties and contract with the client and legal limits plus compensation, 10%
  2. the items covered with in the detailed plans, including outline of issues and methods/products used to solve, taxes, etc. 80%
  3. the presentation itsself 10%.
  4. with a 10 minute time for questions from the panel of judges.
  5. a panel of 3 existing CFP®s with no affiiliation with the candidate can score the plan. I would also impose a time limit for the presentation.

Since thinking outside the box may occur, I feel an oral presentation gives merit and allows for explaination on why on method was chosen over another. And with the plethora of computer programs available that produces hundreds of pages of charts and graphs and numbers- often overwhelming both the planner and the client- oral presentation allows for the candidate to demonstrate his or her knowledge of the plan.

The difficulty in designing the cases to be used, in my opinion, would be in allowing the candidate to either assume certain facts not given, or better yet, give them a way to ask additional questions to gain the knowledge needed.

If we are as CFP®s, to truly benefit our clients, and ensure that the designees are following the standards of the mark, we need to ensure all of the steps in the financial planning process are being taken. Every CFP®, no matter their background or current job duties, meets legal and ethicial requriements when doing so.

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DAN DECAMBRA, CFP®, ChFC, MSFS

Date: August 3, 2009

I am for the new requirements.

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ANDREW DEL BEATO, CFP®, AAMS®

Date: August 3, 2009

Dear Board, adding additional requirements to the educational standards will only enhance the competency of the individuals opting to pursue the certification. My only concern is how will the additional course be any different than the current required courses? Will the course be administered by the Board or by outside institutions such as the American College?

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SARAH N. DEWING, CFP®

Date: August 5, 2009

I do believe that implementing a Financial Plan Development Course requirement would be beneficial to the industry. Having book knowledge of the financial planning concepts only goes so far. By taking it to the next level of demonstrating one’s ability to apply the knowledge by developing a financial plan would not only build an individual’s confidence level but also add to the public perception that an individual who has met the requirements the CFP Board has established knows how to plan “in the real world”. I know the exam is designed to test one’s ability to apply the financial planning principles but I think a full course on financial plan development is an excellent idea and would take educating and developing future financial planners to the next level. In fact, although I’ve already met the requirements and am practicing as a financial planner, I wouldn’t mind taking the course.

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JOHN DIAK, CFP®

Date: August 3, 2009

I believe this course is a great idea to integrate into the steps to becoming a CFP® certificate.

The only modification I would make is that the course be after the test is complete. The focus, time, effort and energy that one applies to study for and passing the CFP® test is intensive. The review process allows for the applicant to "pull it all together" and is further confirmed by the passing of the test. Once an applicant has passed the test, then the focus should be on projecting that knowledge by creating and delivering a plan. If the course were to come before the passing of the test, any process learned may be quickly pushed aside in the successful pursuit of a passing grade of the test and applicants that take the test more than once may not retain the necessary knowledge.

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MICHAEL J. DIGRAZIA, CFP®, CIMA®

Date: August 4, 2009

While a good idea to increase the competency of our profession, I believe that it should be mandatory for new recipients and you should allow certified CFPs to have a choice. If they comply then they would get some sort of "different designation" or "asterisk" signifying that they took an addition requirement that show their competency in planning. (new recipients would get it as well)

I would do the extra requirement... but to make it a requirement for the masses is too much especially for the folks that do not do plans day in and day out.

Thanks for allowing us to comment.

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KIRK DOBSON, CFP®, ChFC®

Date: August 3, 2009

I am in favor of the proposal.

In order to maintain the high standards associated with the credential, changes must be made from time to time to stay ahead of other programs or upcoming legislation.

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BRANT DONIS, CFP®

Date: August 12, 2009

After reading the Request for Comments proposal for a Financial Plan Development Course as part of the CFP® certification process, I am in favor of such a course being part of the curriculum, prior to being eligible to sit for the exam. I think it would be extremely valuable to the profession, and aid in it being considered a profession by the general public.

I do, however, have concerns about the fact that all programs are not created equal and wonder who will make sure that the experience will be consistent, program to program. It would also appear assessing an individual’s plan is somewhat undefined under the proposal. Will the instructors at a Board Registered Program be the sole judges, and what may make them qualified to judge an entire plan, given many are specialists themselves? Will the criteria come from the Board of Standards? The proposal does not specify how the clients are to be obtained for the contact hours, which could be difficult for some seeking certification.

I also feel a thorough re-evaluation of the content of the curriculum is in order and ranks above this requirement in importance. The immense problems caused by the lack of understanding of mortgages, credit and leverage seems to have gone unnoticed by the Board of Standards—but no reasonable person can deny the severe economic repercussions over the last 2+ years. Approximately two-thirds of Americans, at some point in their lives, will utilize the credit markets to obtain the financing to afford the largest investment they will ever make. The current curriculum pertaining to these topics is, to be blunt, embarrassing. Including a variety of topics in the curriculum that are so arcane and geared toward such a tiny fraction of the population that even the instructors have never run across them in reality at the expense of everyday topics affecting so many is counterproductive to establishing the brand of the CFP® certificant as the generalist to consult for financial advice.

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JOHN P. DONOVAN, CFP®

Date: August 7, 2009

Alternatively to the proposed plan, the Board could replace one or both of the first 2 year CE cycles post certification with a requirement to complete a program approximating the proposal.

If cost and complexity to complete CFP® programs continue to rise, there will be less CFP® designees at a time when more are needed.

Date: September 4, 2009

I think this is a poor idea. It continues to appear that those who hold the CFP and run the organization that awards it are intent on continuing to make the earning of the CFP much harder than it was for those who already have it, almost as if born out of a paranoid desire to limit the “ranks of the club”. Very sad.

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CHARLES DURHAM DODDS, JR., CLU, ChFC, CFP®, CIMA

Date: August 3, 2009

sounds-- like a good idea to me.

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BOB DOXEY

Date: August 3, 2009

I think the Board should not generate any more requirements for the CFP. The same thing is happening to you as in our government. You are generating "make work" to keep busy. Just leave it alone!

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THOMAS EDDY, CFP®

Date: August 4, 2009

Bravo! I like this and wish it had been in place when I did my coursework. Fortunately our firm has great resources pertaining to the planning, but I have come across many planners that I don't believe could actually put a plan together.

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MIKE ELLIOTT

Date: August 4, 2009

As a recent student of a CFP program I would have liked to have received more time in the actual Financial Plan Development phase. We covered it as part of the introduction program. This must be weighed with the resulting increase of time and probably money needed to complete the course work for the CFP requirements.

I think overall this additional course will help with the exam and more importantly help us serve our client's needs better.

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LUTHER ENGLER

Date: August 3, 2009

I believe that the current requirements are sufficient to insure that a future CFP will be qualified.

I would like to see a Financial Plan Development Course available to current CFP's as optional so those of us who feel a little rusty can brush up on the latest techniques.

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LINDA P. ERICKSON, CFP®

Date: August 4, 2009

I am interested to know how this course will integrate with comprehensive exam. This is already a very tough hurdle for proposed registrants. I am against making it even more difficult in a very subjective area. 1) How will adequacy be judges?, 2) If written plan is not part of comprehensive exam, how does this course play into the final pass/fail equation?

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RICH ERICKSON

Date: August 5, 2009

I favor the proposal because it will enhance the value, both real and perceived, of the CFP designation. The CFP certification should, and eventually will, be a requirement for anyone holding themselves out as a financial planner in any capacity.

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KARIN ESHELMAN, CFP®

Date: August 4, 2009

This message is in reply to your request for comments on the proposed requirements.

In theory the new requirement sounds acceptable. However, I think logistically this will be very difficult to administer and will be very subjective. It is easy enough to ask people to take several self study course, and then go to a conveniently located proctor and take a multiple choice exam on a computer. This is very objective as well. It is quite different to require a written and verbal presentation beyond this. Here are some of my concerns:

  • How will this be proctored? Will the candidate have to travel out of town or out of their home state to deliver this requirement? This is placing quite a strain on the candidate. Several of the candidates work full time, so asking them to travel to meet this requirement on top of traveling to take the certification exam is quite an imposition. I fear the only people who will complete the process are recent college graduates with no time commitments or those who are in cities large enough to proctor the exams and development course requirement.
  • How will you keep this objective? An oral presentation is about 10% content and 90% how it is presented (did his tie clash with his suit? was her make up just right?) My fear with this is that the only people who will meet the certification requirements are good looking people who can schmooze the audience.

Unless you can guarantee objectivity and have at least one proctor in every state then I don't think this should be pursued.

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JESSIE X. FAN, PH.D.

Date: August 31, 2009

I think the general idea is a great one. However, intead of requiring an individual oral presentation, could the Board consider either (1) a group project oral presenation, or (2) an individual project without the oral presentation requirement (use a writting report or a poster format instead).

If an inidivual oral presentation is required it will not be practical to do that in a large class.

The 45 contact hour requirement seems to be too much as well. We can incoporate this in the capstone class, which is 45 contact hours. However, there are other things we would like to cover in the capstone class as well.

Thanks for the opportunity to comment.

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MARK FERRIS, CFP®

Date: August 4, 2009

I think this is a great idea. We don’t have an apprentice path or resident program before someone can just hang out a shingle.

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MARK FIELD, CFP®, ChFC, CLU, RHU

Date: August 4, 2009

I feel this is an essential part of financial planning and should be part of the education process. I also feel that anyone who currently holds the CFP designation should be exempt from this requirement. Our practices and current continuing education requirements are enough.

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SARAH YOUNG FISHER, CFP®, ChFC, MSFS

Date: August 5, 2009

I approve of the change. Even if you aren’t providing financial plans as part of your current services, it’s something that should be learned to be a CFP. A CPA must know tax and audit, etc even if they specialize in only one area. Same with being a CFA.

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MARC R GENEREUX, CPA, CFP®

Date: August 5, 2009

My few comments on the proposed "Development Course are as follows:

I am, or was at one time, an "Adjunct" CFP faculty member. When I taught various CFP courses, some 10 or so years ago, I required a written "financial plan". A a significant portion of the class grade, was a project where each student had to develope and prepare a finaincial plan and report for a real existing person whom they needed to interview. The purpose of the exercise was to demonstrate knowledge of the course subject matter and the ability to apply it in a practical situation including the report presentation.

I content this is a critical skill that interjects some "real world" flavor into the learning environment and is helpful in the development of a CFP.

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PETER GENUSSO, CFP®

Date: August 5, 2009

Given that a well designed plan can address a variety of concerns using different approaches, I think it may be difficult to develop a program that can be graded objectively. I feel the existing requirements of work experience, mastery of topical skills demonstrated through the completion of the CFP course of study and the qualifiying exam as well as a strong knowledge of the ethical and practice standards are sufficent to ensure professional integrity in the financial planning field.

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JUSTIN GILLHAM, CFP®, CRPC®

Date: August 3, 2009

I like the idea of integrating this into the curriculum for the candidates to have to complete. I like the reason because I feel it makes the candidates more aware of how all the areas of financial planning fit and work together. The individual modules are great and make it easier to learn the material, but a requirement that would bring it all together is a great idea.

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W. STEWART GRAHAM, CFP®

Date: August 6, 2009

I think this is a great idea. I am wholly responsible for all the fee-based work we do in our office. Applicants should be tested on how to do this in a practical setting.

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DON GRANT, CFP®

Date: August 20, 2009

Go ahead - add another requirement to the courses that CFP applicants must pass before becoming practitioners. However, require it for all current CFP designees as well.

I believe that a financial planning practitioner will develop her/his own financial plan out of necessity to serve their clients. Developing and implementing a financial plan presentation 'system' is an organic progress that successful advisors must do on their own. Or, they will work with an organization that has a template and/or set of standards for financial plan development. Therefore, I don't think that additional requirements should be placed upon those working to achieve their CFP designation. Bottom line - they will do it on their own, or it will be provided for them.

I am certain that you will receive overwhelming support for the suggested requirement - primarily because those you are asking - have already achieved their CFP designation. If, however you require that CFP designees add this course to their list of CE to maintain their CFP status - I believe that you will find a much different response.

Why add a requirement for new applicants… but not require current designees be held to the same standards? How will the consuming public designate between the 'educated' CFPs and the 'uneducated' ones? Will you launch an advertising campaign that directs consumers only to those 'newer' CFPs who have passed a test on Financial Plan Development?

What is the real reason for this application? If the board is attempting to make the designation more 'practical' - I would be more than willing to help eliminate elements of the current curriculum that I have found to have no application whatsoever to my ability to provide superior financial planning.

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CAROL GROSS

Date: August 7, 2009

Good idea.

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GORDON W. GRIMES II, CFP®

Date: August 4, 2009

I am in support of adding the Financial Plan Development Course Requirement to the CFP® designation. I feel this is a critical step in the financial planning process. Having the best financial planning information is useless unless you can communicate this information to the client effectively.

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H. L. HACKNEY, CFP®, CLU

Date: August 3, 2009

I fully support the new standards as proposed.

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DONALD L. HAISMAN, CFP®

Date: August 5, 2009

As a long practicing CFP® practitioner, I am in complete agreement of the necessity to add a financial plan development course to the CFP curriculum. This will go a long way to closing the gap between "knowledge" and "practice."

I recommended that the course include the analysis of an existing portfolio of various securities.

A comprehensive "Financial Plan" should be required. Such Plan should include the following:

  • assessment of goals and circumstances
  • setting of long-term financial objectives
  • planning of asset allocation
  • selection of an investment approach
  • building of an investment portfolio(s) to meet each financial objectives
  • retirement analysis and projections
  • estate tax calculations and projections

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CYNTHIA L. HARDMAN, M.S., CFP®, CRPC®

Date: August 4, 2009

As someone who has taught the Retirement Planning portion of the CFP certification program I think the proposal is a good one as no one area stands totally alone.

Retirement Planning means considering investments and estate objectives; which may or may not include insurance, but does necessitate review, just as an example.

Also, as a graduate of the College for Fianancial Planning's master's program I found the capstone class to be very useful so preparing students to think about the entire financial picture whether they do full planning or work with others to help client's meet their financial goals is worthwhile.

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PAT HARRIS

Date: August 4, 2009

There are already too many requirements put upon financial advisors these days. I don’t believe an additional requirement is a smart idea to advisors who are already trying their best in a difficult environment.

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STEVENSON HAWKEY, PH.D., DIRECTOR OF THE FINANCIAL PLANNING PROGRAM, DEPARTMENT OF FINANCE AND ECONOMICS, GOLDEN GATE UNIVERSITY

Date: August 5, 2009

I’m unable to attend this year’s program directors’ conference, so I appreciate this opportunity to comment on, and to inquire about, the proposed financial plan development course requirement.

Let me begin by saying that I am fully supportive of the notion that graduates of financial planning programs must have exposure to and experience with the development and presentation of comprehensive financial plans. Such an expectation has been embedded in our master’s degree program for many years. Nevertheless, I have some concerns about the approach the the Board proposes in order to ensure such experience, and I would like to share those with you.

First: Golden Gate University’s graduate financial planning certificate is a six-course (18 unit) program that covers all the topic areas specified by the CFP Board for registered programs. Most students aim to complete the certificate in three semesters, one calendar year. The requirement to add a seventh course in plan development will have the effect of lengthening the program by one semester and of increasing the price by about 17%. You will understand that I am concerned about the impact that this is likely to have on program enrollments. In an increasingly competitive environment for financial planning education, I hope the Board has given careful consideration to the effect this proposed change will have on higher-priced, graduate-level programs like ours.

Another area of concern: the Board has registered many distance-learning programs. Typically, these programs are designed either as self-study curricula or internet-mediated structures. Golden Gate’s graduate certificate and master’s degree in financial planning are offered as traditional in-class programs, but both can also be completed, in whole or in part, through on-line “cyber” courses; many of our students live and work in locations distant from the San Francisco Bay Area and take all of their courses on-line. For students in programs of this kind, the requirement that a plan development course include an oral presentation presents obvious difficulties, difficulties for which no practicable solution currently exists. I wonder, therefore, if the key objectives of the CFP Board proposal couldn’t be realized by requiring that the presentation element of the course be met through oral or written presentations, a modification that would provide a mechanism for distance learning programs to satisfy the Board requirement.

Finally, a question: when will this plan development course requirement go into effect? I understand that the current proposal will require all registered programs to include a plan development course by January 1, 2012, but at what point will certificate applicants be required to document the completion of such a course? For example, a student who registers in GGU’s graduate financial planning certificate program in June, 2011, will expect that completion of the current six-course curriculum satisfies the Board’s education requirement for certification—but does it, given that the student will not complete the program until June, 2012 (or later)? Can any student who is admitted to a registered program prior to January 1, 2012 be confident that the lack of a plan development course will not be a bar to certification?

Thanks for considering these questions and concern. I look forward to following the discussions among the program directors and certificants as this proposal moves towards implementation.

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MARK G. HENDRIX, CFP®, CRPC®

Date: August 4, 2009

I agree with adding course requirement of developing a financial plan for all CFP candidates. Satisfying this requirement will only strengthen our practice.

Retirement Planning means considering investments and estate objectives; which may or may not include insurance, but does necessitate review, just as an example.

Also, as a graduate of the College for Fianancial Planning's master's program I found the capstone class to be very useful so preparing students to think about the entire financial picture whether they do full planning or work with others to help client's meet their financial goals is worthwhile.

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WILL HERNANDEZ

Date: September 26, 2009

Please note that some of your programs,such as the University of California at Riverside, already has this type of a course. By making this a standard it would standardize the requirements and make it more likely that folks across the nation will have a more uniform level of understanding as they become a Certified Financial planner. Also, anything to ensure that the level of knowledge of those wishing to test more thorough can only enhance the reputation of these 3 letters after our name.

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THOMAS HODELL, JR

Date: August 5, 2009

As an advisor for 14 years, I recognize that the best plan in the world is worthless if the advisor cannot communicate the ideas, strategies, and principls in an understandable and meaningful way.

I work for a company that requires all financial planning advice to be delivered to the client in a written format and feel that this sort of course could be quite instructive if properly designed.

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CLYDE G. HOHENSTEIN, CFP®

Date: August 12, 2009

I heartily agree with the concept of adding a Financial Plan Development Course requirement to CFP Board-Registered Programs and for all individuals who wish to take the CFP® Certification Examination.

I would also suggest that the Board consider requiring all CFP® practitoners to take a reexam every 10 years that would include a demonstration of their ability to write an integrated financial plan. This would be similar to certain medical professionals who must take periodic reexams to maintain their certification.

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ROBERT L. HOLLAND JR., CFP®

Date: August 5, 2009

I think the Financial Plan Development course requirement would be a good thing. The thought of a capstone course requirement will benefit the certificants in the practice of financial planning, especially as they move forward, with a sound process in place at the onset.

Thanks for the opportunity for input. I wish I would have had access to a course like this during my education program.

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RICHARD HORNE

Date: August 4, 2009

The ideas presented in the proposal make sound sense. Having just finished a course last year at the Lowcountry Graduate Center in Charleston, SC(affiliated with the College of Charleston), I gained a great deal of perspective and understanding of our roles as advisors and planners by working in a group with a banker, a trust officer and a P&C agent on our group class presentations and even on our test prep studies. Working with experts in a variety of interconnected fields is one advantage the classroom setting gives that a virtual classroom cannot. Notwithstanding, the idea of individuals making oral and written presentations that encompass all the trained skills of a CFP® will better equip the candidate when he and she enters the marketplace as a practitioner and actually interacts with the client or prospect. I like the idea of the presentations being made before teachers as well as other students with a mandatory feedback from the students to the presenter so that he latter can gain from the different perspectives of the other classmates! Some developed CFP® programs are already implementing these practices into the General Principles part of the course curriculum but on a more informal basis. Let's make it a formal part of the training and certification process!

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SAMUEL P. HULL, CFP®

Date: August 18, 2009

I would like to suggest that we–the Board, the certificant community and the registered programs - all step back a bit and look again at what are the primary objectives of the CFP Board in adding a Comprehensive Plan Preparation and Presentation requirement to the CFP certificant licensing process.

My primary comment is to suggest a change in perspective. As has been done with the Ethics requirement, why not make completion of the Comprehensive Plan Preparation and Presentation requirement the responsibility of the applicant, not the registered programs?

I applaud the Board in taking bold action to correct what has long been a weakness in the certification process. The incredible power of the six-step financial planning process lies in its ability to see beyond the dynamics of one individual segment –insurance, investments, etc. -and to integrate the client’s life objectives and goals with the rich technical expertise of the planner. It is a disservice to the public not to have such a requirement be part of the certification process, as is now the case.

However, the current suggestion to place the onus on the registered programs to come up with a Capstone –or Comprehensive Plan Preparation and Presentation- course seems to me a Procrustean solution. Rather than force the individual programs – which vary in focus from degree-giving institutions to distance-learning programs to community college certificate programs- to come up with a solution, why not allow the free market to find a way?

There are currently nearly 60 Board accredited providers of programs that allow a certificant to satisfy the Ethics requirement and the Board has long accepted that they do an adequate job of determining that the applicant meets the Ethics requirement. I am also certain than many of the same providers who offer Board-approved live, on-line and webinar Review Course and other CE programs could come up with a satisfactory solution that would allow certification applicants a way to demonstrate their ability to meet the Comprehensive Plan Preparation and Presentation requirement. It would only remain for the Board to establish the content, standards and criteria for the requirement, as well as to monitor the registration approval process.

Date: September 4, 2009

My primary comment is to suggest that you make the decision as to how to complete the Comprehensive Plan Preparation and Presentation requirement the responsibility of the applicant, not force all the registered programs to use one model developed by the Board?

I applaud the Board in taking bold action to correct what has long been a weakness in the certification process. The incredible power of the six-step financial planning process lies in its ability to see beyond the dynamics of one individual segment in the body of knowledge –insurance, investments, etc. -and rather to honor the uniqueness of each client’s life objectives and goals through the integration by the planner of all the areas of their expertise. It would be a great service to the public to have such a requirement as is now being proposed as part of the certification process. I commend the Board on taking this step.

However, the current suggestion to place the onus on the registered programs to come up with a Capstone –or Comprehensive Plan Preparation and Presentation- course seems to me a procrustean solution. Rather than force the individual programs – which vary in focus from degree-giving institutions to distance-learning programs to community college certificate programs- to come up with a solution, why not allow the free market to find a way?

There are currently nearly 60 Board accredited providers of programs that allow a certificant to satisfy the Ethics requirement and the Board has long accepted that they do an adequate job of determining that the applicant meets the Ethics requirement. I am certain than many of the same providers who offer Board-approved live, on-line and webinar Review Courses and other CE programs could come up with a satisfactory solution that would allow certification applicants a way to demonstrate their ability to meet the Comprehensive Plan Preparation and Presentation requirement. It would only remain for the Board to establish the performance standards and evaluation criteria for the requirement, as well as to monitor the registration approval process.

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ERIC JOHNSEN, M.S., ChFC, LTCP, CFP®

Date: August 24, 2009

I feel I am in a unique position to comment on this topic as I am both a practicing financial planning professional as well I am an adjunct instructor in the board certified program at Virginia Tech. I have been involved in the investment/planning counseling arena for 12 years. I became a CFP® certificant in June of 2004, however as a full time State Farm agent, because of corporate considerations and decisions, I voluntarily relinquished my designation in December of 2008. My academic background includes a B.S. degree in finance and a M.S. degree in the financial planning program both from Virginia Tech. I have continued my academic development by attaining my ChFC and LTCP designation as well, I am one course shy of completing my CLU designation from the American College.

From a practicing professional and in preparation for the CFP® exam, I strongly see the value in personally and individual preparing, developing and presenting a comprehensive financial plan. The more experience the better. As a young 23 year old starting with a major brokerage firm in the grand scope of the financial arena, I had a finance degree, but I did not know how to comprehend what was important to my clients. I understood I had to sell something to generate a commission to make a paycheck. Today, 12 years later, I have vast real world experience working with clients, as well as having continued my education relevant to financial planning. Understanding comprehensive financial planning earlier in my career would have allowed me to be a better advisor to my clients sooner.

From an academic standpoint, I have a different thought. I am an adjunct instructor of finance in Virginia Tech’s Pamplin College of Business department of Finance, Insurance and Business Law. I teach a class, Risk and Insurance, to academic juniors who are CFP® track students from both the Finance department as well as the Agriculture Economics department. My concern here is the academic ability to facilitate this course and the financial burden on the department to support this class. Essentially, I teach 60-70 students a year. Currently, my class is offered only once a semester. Typically an academic semester is 45 hours in length. If this class was taught twice a year in our program, which I understand is one of the larger programs in the country, there would be approximately 35 students per semester. If each student individually prepared and presented their comprehensive plans, I reason 30-35 students with one hour each for presentation is 30-35 hours or more are already committed of the 45 semester hours just for presentations. Where would time be found to help students develop plans and comprehend a clients total financial picture. It seems that some students could be presenting plans within the fourth week of a 15 week semester and then be finished with the class. While others would have to “wait their turn” and may not present until the 15th week where they had to “serve the full term” of a semester mostly just waiting. Finally, the written plans each likely being minimally 15 pages and ranging up towards 50 pages would need to be reviewed by the professor. This means another 1700+ pages that need to be read and reviewed by the professor. Reading 1500-2000 pages with the integrity and respect they deserve is at least a 30 hour commitment by the instructor. In today’s academic worlds, I don’t know how many departments can support a full time academic for one program class. Typically full time professors teach multiple courses and class times, at my institution I understand they typically have 100 plus students a semester. With required prep time, class time, grading time, student time and administrative duties expected of professors today, this seems like a substantial burden to place on an academic program. My program currently offers a comprehensive planning class, however, the final plans are developed and presented as group projects consisting of 3-4 students. The final presentations are 15-30 minutes each and are typically related to one area of the total plan. The professor then has the duty to read and review the entire written plan for each group. With a program the size of mine, the latest class of 32 students in the comprehensive plan class took 3 hours to present their “slice” of a plan. Again, this was followed by 20 plus hours of reading and reviewing the 1000+ pages of group plans by the professor.

Even a smaller class with 10 students in it to give fair time for academic development, plan preparation, and finally plan presentation. 10+ hours of the 45 hours are committed to plan presentation. Almost 25% of the entire course is plan presentation. In a program like Virginia Tech’s this would require 3 or 4 course times being offered to instruct 30-35 students per semester. Again, this means one full time educator committed to teaching one program course. I question the reality and likeliness in today’s financially challenged academic world of that happening. In a smaller college program, 10 students in one class may only allow for that professor one additional class per semester because of the work and time load required by this CFP® possible standard requirement. Can a smaller college program support one professor teaching only two classes a semester, I don’t know, that’s part of my concern.

Again, I appreciate the idea, I just don’t know the reality of the academic commitment from programs to support this one course. I feel that the academic requirements of having a base understanding of the concepts related to financial planning are the important foundation of the program. Investments, insurance, tax, retirement, education, estate and business continuation planning understanding are the important pieces. Developing the comprehensive plan is ideal, but it’s not the overall requirement. Without understanding the pieces of the puzzle a comprehensive plan cannot be generated. But understanding these pieces will more easily allow a student and one day practitioner to put the puzzle together. The emphasis, as it currently is, should be on the academic knowledge of the planning pieces. Process and the comprehensive planning is more real world applications rather than academic understanding. We all know each case is different, each person, family, business and situation is different. Each academic program will have their variations. I believe the boards need for real understanding of the academic institutions new burden because of this requirement will need to be understood before the expectation can be placed on the institution to provide an important but not the most important piece to the financial planning education requirement.

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JAMES E. KEARNEY, CFP®, CTFA

Date: August 11, 2009

I have been a CFP® for over 10 years and support the addition of a financial plan development course to expose candidates to a real world experience.

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KEIR EDUCATIONAL RESOURCES

Date: September 25, 2009

Keir Educational Resources would like to submit the following comments and suggestions about the proposed Financial Development Course. Our comments are in no particular order.

1. Currently, the total number of required contact hours for a CFP Certification Education Program is 225. The proposed case course would add 45 contact hours. This would bring the total number of contact hours to 270 for the entire program. This is a 20% increase in the length of a program. We are concerned this 20% increase will discourage potential candidates from pursuing the CFP® Certification. Can the number of contact hours required for the case course be decreased to 15 or 30 contact hours?

2. Several CFP Certification Education Programs already include a case course in the 225 contact hours required for the program. The average amount of contact hours for these programs is 24 to 28 contact hours. These programs would have to add 45 contact hours to their already existing program. If these programs can already cover the existing curriculum and a case development course, why can’t the rest of the CFP Certification Education Programs also add a case course within the current 225 contact hours?

3. Would it be possible for the CFP Certification Education Programs to incorporate the case development case into each of their current classes? For example, a student would be given one fact pattern when the student takes the General Principles of Financial Planning course. The student would write and present the part of the financial plan that relates to the general financial planning issues during this first course. The student would then write and present the part of the financial plan that relates to the insurance issues during their insurance course. They would continue with this client fact pattern all the way through to the estate planning course. By the time the student finishes the last course, the student would have written and presented the entire financial plan. We also believe the integration of the case in each of the classes might encourage more students to complete the program and sit for the CFP® Certification Examination. The integration of the case in the first course would bring a more real world experience to the student earlier in the process and hopefully keep the student interested in the financial planning profession.

4. We are concerned how online programs will be able to have their students present the financial plan. For example, we have worked with students from different online and distant learning programs who are currently overseas with the military. It is not practical for these students to fly back to the United States to present the case. Can these students present the case to their boss and send a video recording to the instructor to then grade? How can these instructors challenge the case presentation if it is recorded rather than a live presentation? We believe the case challenges are a great learning opportunity for the students.

5. How are instructors with large classes going to be able to watch and grade all of their students’ financial plans? For example, a class with 10 to 20 students would be a lot of work, but it is manageable. However, a class with 50 students would be almost impossible. If you assume each presentation averages 30 minutes, the student presentations would take 25 hours. Is it possible for group presentations in order to be able to manage the number of presentations? Alternatively, can the student present just part of the financial plan in order to decrease the time required for each student.

6. Where are the CFP Certification Education Programs going to find instructors who are willing to review all of the written and oral presentations? Some programs will have to hire more adjunct faculty in order to handle the extra work load. Where are the programs going to get the money to pay for these additional instructors? Most likely, these programs will have to increase their tuition which will potentially turn more students away from pursuing their CFP® Certification.

7. How are CFP Certification Education Programs going to handle grading all of the financial plans at the end of the course? It will take a significant amount of time to grade the financial plans. Some students may end up missing a registration deadline for the CFP® Certification Examination if the instructor has not finished grading all of the plans. This concern grows exponentially for online and distant learning programs that allow students to complete the course at their own pace. We know from years of experience that numerous students finish their last online or distant learning course within days of the CFP® Certification Examination deadline. It is impossible for the online and distant learning programs to be able to grade 50 or 100 written and oral financial plans in a couple days. Without a doubt, some of these students will miss the CFP® Certification Examination deadline.

8. Under the proposal, programs will have to start offering the case course by January 1, 2012. However, candidates sitting for the CFP® Certification Examination will not be required to have taken the case course until some future date. We would like this date to be officially announced when the proposal is passed. We would also like it to be clear if it is just candidates who were already in a CFP Certification Education Program before January 1, 2012 that are not required to take the case course or if it is all candidates are not required to take the case course until this later date. We recommend that the later date apply to all candidates to keep it as simple as possible.

9. Is it possible to have professionals who already prepare financial plans as part of their job to be able to submit a client financial plan to the CFP Board (or a CFP Certification Education Program) for review in lieu of having to take the case course? We are concerned that companies might not want to pay for the case course given tight budget issues if the employee already prepares cases as part of his or her job. We anticipate that the CFP Board (or the CFP Certification Education Program) would be able to charge a fee to review the plan in order to get the candidate exempted from having to take the case course. We anticipate the case course will be an issue for candidates who currently challenge the exam with another designation like a CPA. Although we acknowledge that there are a lot of CPAs who do not prepare financial plans, it would be very helpful if the CPAs (or other challenge candidates) who do prepare financial plans can be waived out of the case course requirement by submitting a financial plan for an actual client. To protect client information, the financial plan could be altered to remove the client’s real name and other confidential information.

10. Currently only a small portion of the students who start a CFP Certification Education Program end up taking the CFP® Certification Examination. Given the concerns listed above about the cost and number of hours it would take to grade a written and oral presentation of a financial plan, would it be possible for candidates to take the case course after they pass the CFP® Certification Examination? This would bring the number of individuals needing to complete the case course down to a more manageable number. The candidates would have time to complete the case course (or maybe even challenge out of the case course by submitting a real client financial plan) while the candidates complete their work experience.

11. Some students take the five or six courses at a CFP Certification Education Program knowing they will never sit for the CFP® Certification Examination. In order to encourage these students to still complete a certificate program at a local university, could the case course be excluded from the requirement to obtain the certificate? This would help to keep the workload more manageable for these CFP Certification Education Programs while still encouraging students who never plan on taking the CFP® Certification Examination to still sign up for the courses. Of course, these students would need to take the case course if they change their mind and decide to sit for the CFP® Certification Examination.

12. Would it be possible for companies who do not run a CFP Certification Education Program to offer just the case course? For example, could a review course provider offer just the case course? This could potentially be a solution for universities who might have to shut down their program if they have to add the case course.

13. We would like to see additional guidance on the main learning objectives of the case course. We anticipate the main purpose is for the instructor to teach how to write a financial plan. However, a class with 50 students would spend the bulk of their time hearing other students present their financial plans. Although hearing other student presentations is a good educational experience, it does not help the student learn how to write a financial plan. If evaluating other student’s financial plans is part of the learning objectives, this will be an issue for self study courses or online classes. We believe the CFP Board needs to provide clear guidance on the ultimate goal of the case course. Without this guidance, the experience of a student in a small class verses a large class or an online/distance learning class would all be very different. We expect instructors designing these courses would also appreciate this additional guidance as it could give them the class framework.

14. Would it be possible for the CFP Board to provide a couple sample financial plans as an example of the level of detail the CFP Board expects a student to produce in the case course? These examples could help to make this course more of a science rather than an art form.

15. Would it be possible for instructors to give multiple choice questions about the case fact pattern in lieu of challenging the student during the case presentation? This could be a solution for the online and distant learning programs where students would not be able to present the case in a live format. This could also be a solution for time management issues for large classes as it would minimize the time spent on each student’s presentation.

16. Will there be any restrictions or guidelines on who can teach the case course and/or grade the written and oral cases? There was a lot of discussion during the Program Director’s meeting about teaming up with the local FPA chapter to get the resources needed to grade the written and oral cases. However, not all volunteers would have the same skill set or experience as an instructor. We anticipate there could be issues if a volunteer grades a couple financial plans per class as it might take them longer to complete the grading which could cause a student to miss the registration deadline for the CFP® Certification Examination.

17. Would it be possible to get guidelines on grading the written and oral financial plan? Without this guidance, we expect some instructors will grade easier or harder than others. It would be nice to have a minimum level required similar to the minimum competency required to pass the CFP® Certification Examination.

18. We would also like to recommend that the preparation of a financial plan be an option and not a requirement. When attorneys get their license to practice law, they are given a written test and are not required to review a contract, write a will, present a case in court, or argue an appeal. Those were things the attorney did in law school, but they were optional. The presentation of a financial plan seems to be essentially similar. We know that not every financial planner will use the CFP® Certification to prepare and present financial plans. Perhaps the case requirement should be an option as part of the course work rather than a requirement.

Keir Educational Resources

Henrietta Nye, CFP®, ChFC®, CLU®, CPCU, President
John Keir, J.D., Chairman of the Board
Debra Sawyer, CFP®, CPA, ChFC®, MST, Editor and Instructor
James Tissot, CFP®, Editor and Instructor

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LAWRENCE P. KENNARD, CFP®, CRPC®

Date: August 3, 2009

I think it is an excellent idea.

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DONNA KEYS

Date: August 27, 2009

If you want to require specific courses be completed by CFP’s then may I suggest you provide us with more organizations willing to present the course in a lecture type atmosphere. Many of us are not near major cities so perhaps you could use local community colleges. From prior experience, I feel that using the on-line courses are not nearly as rewarding as an on site course.

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JOHN KINGSTON, MBA, CFP®, CDFA

Date: August 4, 2009

YES, to the proposal for a FP Report element to the curriculum.

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JAMES M. KNAUS, CFP®

Date: August 4, 2009

Please accept my comments regarding the proposed Financial Plan Development Course below:

  • In my opinion, you have provided adequate time for the additional requirement.
  • Development of acceptable specifications for the course should result in a brief but coherent set of guidelines that allow instructors in registered programs the latitude to conduct the course using their own preferred methodology.
  • CFP Board should supply registered programs a continually updated list of textbooks and instructor’s manuals that are deemed acceptable for the course.
  • The Board should clarify which designations and degrees, if any, will be allowed to obviate the new requirement. In addition, the Board should consider again whether we should have the challenge status at all for any designation or degree.
  • The new course requirement should be rigorously enforced.
  • Registered programs should be provided a mechanism to avoid potential legal liability for having passed a student who ultimately engages in activities in violation of the Practice Standards or Code of Ethics.

It is likely that the current community of CFP® professionals will welcome the change, but that candidates will generally be opposed, as it requires an additional expense, both monetary and in terms of time. We will all need to reinforce the wisdom of such a new requirement, and make analogies to other professions that use similar requirements.

We may also encounter situations in which a student is either incapable or totally unwilling for personal reasons to present orally the financial plan. (I personally observed one such occurrence when I taught our Advanced Case Study course.)

Finally, I have begun creating a text and instructor’s manual for usage in the proposed course. I will need guidance as to whether my product will satisfy the requirements.

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RICK H. KOFF, CFP®, ChFC, MSFS

Date: August 3, 2009

I feel this type of course would be an excellent addition to the current curriculum and would add value to those working to achieve the CFP certificant status. Thank you.

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JAMES M. KOLLER

Date: August 4, 2009

After more than 20 years in corporate finance, typically in the CFO or VP Finance role, I changed careers in 2003 to become a financial advisor at Morgan Stanley and later at Banc of America Investment Services (BAI).

During my five years as a financial advisor at Morgan and BAI, I completed the requirements for CFP® Certification and was awarded the designation in January 2008.

In April 2008 I joined Charles Schwab & Co. as a full-time, dedicated financial planner. Over the past fifteen months, I have spent 40+ hours each week doing nothing other than preparing financial plans for Schwab's higher net worth clients, typically those with more than $2 Million of investable assets. Schwab's Plans are comprehensive, addressing asset allocation, retirement, education, life, disability and LTC insurances, and estate planning.

I write to express my support of the proposed Financial Plan Development Course requirement for CFP® Certification. My CFP® course curricula provided me a sound basis in the principles of financial planning but not for the actual application of creating financial plans. That was something for which Schwab invested considerable training in me. I believe that a financial plan development course would enable the CFP® certificant to better serve both his clients and his employer, thereby raising the value the designation in a meaningful way.

I hope you find my comment helpful in your consideration.

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LINDA KOUBEK

Date: August 13, 2009

Are you receiving complaints regarding the plans being written? Our clients' situations are so diverse in this economic environment it would be restrictive to develop a "sample" financial plan. There are many examples out here available from employers,associates, etc. to use. One more thing to test on is unnecessary.

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HOWARD A. KRAMER, CFP®

Date: August 7, 2009

My thought is that the timing is not right to present this great idea. You've picked a very strange time to indicate that there is currently something wrong with the qualification standards for CFP®®’s that have been established and used up until this point. Again, requiring new CFP®’s to present an oral and written financial plan is a great idea. However, the take away will be that there are tens of thousands of us existing CFP®’s who have not done so, therefore giving the media, the regulators, and the public an opportunity to delineate between how our existing CFP®s might not be as qualified as CFP®’ will be in the future.

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MICHAEL T. KRISE, CFP®

Date: August 7, 2009

I feel this is an excellent idea. There is no reason that this will be anything but beneficial to those of us who already hold the certification. It is my belief that it will add another layer of credibility and give a “real life” scenario that can be put in practice immediately. Also, the level of professionalism that is observed by the client is of the utmost importance. You want to have “systems” in place that give consistency to your practice, which helps out in every level of client interaction.

Also, I don’t know what the status of the requirement that people who call themselves a “financial planner” actually hold the CFP® designation, but I ran into that yesterday and it irked me a little bit. All of us who have gone through the process can appreciate the level of education, work experience, ethics requirements, etc. that it takes to get the CFP® designation and it seems to cheapen it a bit when I see this. So, anything to disseminate to the public as far as showing the differences and what it takes to become a CFP®®, I feel would do nothing but add credibility to our profession.

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MARK F. KRIVONAK, CFP®

Date: August 4, 2009

Seems like a sensible requirement since it will add a minimum level of competency to demonstrate ability to put into practice what a candidate understands. Would be useful for potential employers to read what a candidate submitted to show they have some understanding. Of course there will be some need to ensure the candidate did the work for him/her self. I like your forward thinking on this.

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LYNN KUHLMAN

Date: August 26, 2009

I think the requirement to include the course is a good idea.

I sat for the CFP Board exam in November 2005 and will retake it in March 2010.

In addition to this requirement, however, should be a requirement that program course providers cover the case study materials that are already offered though the recognized course publishers.

Requiring a financial plan development course to be included in the curriculum adds value to the student, the program provider, the industry, and the people we serve.

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JEFF LACOURSE

Date: August 23, 2009

I do not support this idea since thee exists too many software programs available to the task. In fact, the exam should return to a P/F basis for each course in the certification area.

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AMY JO LAUBER, CFP®

Date: August 5, 2009

I think the concept of requiring CFP® candidates complete a financial plan development course is excellent. The course, properly designed and ideally required at the conclusion of the six-courses, should provide the tools needed for a CFP® certificant to develop a financial plan with competence and confidence.

It wasn't clear what tools (software) might be used in the course, however. While the most crucial component of our financial plans is the "recommendations & action plan" section, the client often benefits from viewing the projections, graphs, charts and the like generated from our financial planning software. Those pages help us, as planners, communicate our message visually. If the course is mainly focused on the recommendations of the planner, I imagine Microsoft word would suffice. But in the real world, most planners use some form of financial planning software.

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ROBERTA LEE-DRISCOLL

Date: August 3, 2009

I applaud your effort to add some practical element to certification.

I believe that the time of the requirement should be changed from “prior to taking the exam” to “prior to certification”. I believe it depends on the purpose of the requirement. Is this an academic exercise or a practical exercise? If purely academic then the timing of the requirement does not matter. However if it is a practical requirement then having the candidate finish their three years of experience should make this requirement more meaningful.

Thank you for allowing me to comment

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CHRISTINE LEMOND, CFP®, MBA

Date: August 10, 2009

I am writing in response to the Proposed Financial Plan Development Course Requirement. As a CFP® certificant for the past two years, I believe that this proposal would be an excellent addition to the curriculum.

Modular planning to comprehensive planning encompasses a broad spectrum of financial topics. It is my opinion that identifying the areas of need and their respective solutions is easier than formalizing structured, cohesive personalized reports clients can take away with them knowing that they have received something not only in form but with substance.

I am in the process of preparing a financial plan for NAPFA as part of its requirement for membership. Integrating all the elements of financial planning into one comprehensive report is not as easy as one would think upon the successful completion of the CFP® Certification Examination. If it were that easy, I suspect I would currently be a member of NAPFA instead of still working on its financial plan requirement.

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ROBERT D. LIVINGSTON, CFP®

Date: September 9, 2009

I am not a fan of the new Financial Plan Development course requirement as it is proposed. Anyone who has completed the six modules of CFP training should not be subject to this additional requirement. By completing the course work they have become very familiar with the key elements of a financial plan. However, I do not believe this is not the case with those applying for a waiver/challenge status. I think the Financial Plan Development course requirement should be added for those who apply for challenge status, such as CPA’s and Attorneys, as they have not completed the formal CFP training curriculum.

The CFP Boards Financial Planning Practice Standards provides us with all the necessary framework we need to develop a proper financial plan. The current CFP exam tests for that knowledge of the practice standards.

Beyond meeting the practice standards requirements (which we all agree to abide by,) the plan development and format becomes ‘stylistic’ to the individual practitioner producing the plan. As many different CFP Practitioners there are, there are that many different stylistic approaches to writing a financial plan. To say one’s stylistic approach is better than another is simply in the eyes of whoever is selected to ‘judge’ the plan. Therefore, it seems judging written plans (or oral presentations) would be very subjective and inconsistent.

As practitioners we are hired to provide sound financial advice. In its most simplest format the written plan is an outline, a tool, from which we will have a deeper conversation with the client. The quality of that conversation is based on our individual knowledge and experience of the subject area – not on the stylistic format of the written plan. Let’s face it, it is the CFP practitioner that motivates the client to implement the recommendations – not the format of the written plan.

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GLEN LOTHARY, CFP®

Date: August 4, 2009

While I think this is a valid addition to the course work, I tend to believe you are doing this only to increase the revenue generated to the organization. If this is added to the course of study at NO additional cost to those completing their studies for the CFP then I would say well done. My cynicism about the CFP Board of standards has grown by leaps and bounds since you moved your offices from Denver to D.C. where it seems you have become lap dogs of Congress. Get your act together and start representing the good people that have worked hard to obtain the CFP designation and who pay your salary with their dues, not morons like Barney Frank et al.

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HANK LUCAS

Date: August 3, 2009

I'm not sure about the contents of this course, but it seems like a good idea. To many of our planners have become "investment advisors" and not true financial planners. You are definitely going in the right direction.

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JIM MACGILLIVRAY, CFP®, CDFA

Date: August 3, 2009

I think this is a good idea. We have two relatively new CFPs in our office and my impression is that they are not as comfortable developing a comprehensive plan as I was when I completed the CFP curriculum in 1987. The final exam, as I recall when I took it, included case studies. I question the necessity of oral presentation. I think there are planners who present themselves very creditably in front of a client who may not do well in an exam circumstance.

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WARREN J. MACKENSEN, CFP®

Date: August 4, 2009

It is about time that the CFP Board institute a requirement to demonstrate knowledge in a financial plan.

Good move.

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DAN MAUCK

Date: October 2, 2009

Although the general philosophy behind requiring candidates to prepare and present a comprehensive plan is well-founded, it faces clear challenges to effective implementation – “effective” being the operative word. That is, the implementation must be one that not only installs the requirement, which is easy enough to vote-in such a mandate, but one that actually accomplishes the intended educational purpose for which it was executed without creating extensive collateral damage to the existing curricular framework or excessive cost burdens, both of which in the end would be counterproductive to the CFP Board’s, and indeed the profession’s, goals.

The challenges should be obvious to us all: While some of the current programs accredited by the CFP Board already include such a requirement, most programs do not and would therefore face significant burdens of time and cost, both up-front and continuing, in adding such a requirement into their certificate/degree plans. Moreover, most of them already are under strict budgetary constraints, to say nothing of the effects of the ongoing economic turmoil. Stated simply, the number of current faculty in the majority of programs is working at full capacity already (thus ill-equipped for the task of developing additional curriculum, overseeing plan preparations, and evaluating the numerous final presentations) and the academic budgets cannot soon enough contemplate the addition of new faculty to shoulder the burden (as if an adequate supply of suitable faculty on this scale existed, which it does not). Therefore, “flipping a switch” with the expectation that accredited programs will be able to comply could have serious backlash, even providing the unintended consequence of some schools dropping their accredited programs altogether. That would be very bad indeed, crippling the overall production of competent CFP® professionals for the marketplace.

I have heard of other possible solutions to this dilemma, which beg their own questions. Among them: (1) enlisting the voluntary efforts of local CFP® professionals to supplement shorthanded faculty and (2) “outsourcing” the requirement by funneling candidates through the FPA Residency program. While these offer some interesting aspects, neither poses an adequate long-term solution in my view.

1. Having CFP® professionals supplement shorthanded faculty in their respective local area effectively subsidizes the problem rather than solves it. To me, the primary problem with this is that the volunteers would have zero economic impetus to sustain such a system for long, and once they are burned out, the burden would return squarely onto the schools’ shoulders (see aforementioned argument). Also, some geographical areas undoubtedly would have a mismatch in the number of willing volunteers versus the number of students/candidates – a smaller kink, but one nonetheless. More significantly, quality control measures would need to be incorporated, as this method would be asking a practicing professional to shift into an educator’s role. What determines whether a volunteer is qualified to evaluate the students’ work? Just because they themselves met (perhaps long ago) the minimum standards for earning the CFP® certification, should that equate them with a career educator holding a PhD? While I agree that our particular constituency is one of the most generous of their skills and time, expecting busy professionals to add “grading papers” to their list of tasks is shortsighted and an unreliable long-term solution.

2. Let me first say that I am a huge fan of the FPA Residency program, as well as a graduate of it. Without question, it is the “precious gem” among the activities available to young CFP® candidates/certificants. That said, its focus – and the reason it is so valuable to a young professional’s development – is because it provides so much of what is NOT available through the CFP Board-accredited programs – that is, the interpersonal communication aspects of handling client relationships. While this intensive week of activity executes its objective well, there is no extra time for devoting to the more intricate technical planning that is required when creating a comprehensive written plan, and certainly no time for Residency attendees to deliver oral presentations of their plans. In my opinion, this would jeopardize the valuable mission for which FPA Residency was originally created. A second concern is the cost of Residency, which is relatively steep. Although I haven’t personally validated it, I’ve heard that FPA does their best to keep the costs down; supposing that is true, it would be cost prohibitive for the most students to bear the additional burden of Residency’s tuition, thus preventing them from “crossing the finish line” of fulfilling the FP Development Course Requirement.

I would be remiss to only make these criticisms without proposing an alternative solution. Therefore, I humbly urge the CFP Board to consider shifting the mandate from a classroom-based requirement to an internship-based requirement. Indeed, this format has found traction across the nation not only within our profession (implemented largely on an elective basis already at many of the accredited programs), but many others as well – and for good reason. This would offer the following advantages:

  • Avoids placing excessive, unnecessary burdens of time and cost on existing academic faculty and staff, and therefore would not require massive, unrealistic adjustments to existing departmental budgets at accredited programs. However, programs would still need to provide final approval that internship/course requirements were met and award the credit hours/units. Since some leading programs already have such a requirement in place (Texas Tech Univ, for example), they could serve as initial models to programs who lack such formal structure as yet. Perhaps with their practical insight and advisement, manageable formats could be brought to scale befitting the smaller accredited programs nationwide.
  • tilizes the large body of practicing professionals within the environment/role to which they are accustomed. They need not be re-trained or cross-trained to do the work of an educator; they merely oversee the intern just like they would new staff. Side benefits: firms get a good look at new talent and interns get a great opportunity to showcase their skills – this is a much better entrance to their career than most of them face today. If the Board feels that firms would balk at the added cost of hiring temporary interns, the Board (perhaps in partnership with FPA) could initiate an ad campaign emphasizing what I’ve called “side benefits” above. Also, with all due respect, far be it from the Board to issue this new mandate without having true economic skin in the game – perhaps the Board could offer nominal discounts on certification renewals for CFP® professionals that sponsor an intern once every two years. (Just an idea.)
  • Provides students with lots of real-world experience. Most current internships are 6-10 weeks of 5 days/wk – much more exposure than 3 credit hours/units would provide. The CFP Board could stipulate the minimum length of weeks (or work hours) for the internship and, with the input of a Internship Advisory Board composed of academic faculty and CFP® professionals, a list of the various competencies or tenets required during the experience (for example, documentation of the intern’s activities such as a work log and signed overseer-verification of the intern’s extensive involvement in a written plan’s design, construction, and presentation to the client).
  • From a cost standpoint, some burden would still exist – of course, there’s no way to implement this requirement without costs of some form! But firms paying interns is a fair approach (honest day’s work for an honest day’s wage) and spreads the cost impact as widely as possible: across the whole nation (or world?) of practitioners. For accredited programs, this is the least burdensome cost structure – they only need to create a ratification process whereby they sign off final approval of the student’s internship for credit.
  • Students would have their choice as to where they fulfilled their internship requirement, offering them endless variety of opportunities to pursue. This degree of breath would have numerous positive impact on our profession and the individuals who comprise it.
Given even more time for consideration, I have no doubt that additional advantages would become apparent. I hope that you will consider these thoughts with earnest regard.

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ANDREW MCVAY

Date: August 5, 2009

I am in favor of the CFP Board requiring a comprehensive financial plan development course as part of the educational requirement for sitting for the CFP exam. I would only mention though that having an oral presentation requirement may be difficult or unwieldy for those who take their CFP courses online.

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LINDA HANNA MARTIN, CRPC®, CFP®

Date: August 4, 2009

I heartily agree with the addition of this requirement. I feel that most people now take the cram course to pass for certification. This is not nearly as expansive as I feel it should be. When I received my Certification in 1986, there was a section in which we wrote a financial plan. This was, of course, the most difficult part. It put all our education to use.

Since we have drifted away from this, I think we should put it back in. The oral part may prove to be difficult and expensive to implement.

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TOM MARTIN, CFP®

Date: August 4, 2009

Fully in favor of a plan development course. This is the missing link in the CFP as it now stands.

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JOSEPH M. MASIELLO, CFP®, ChFC®

Date: August 3, 2009

I think this is an excellent idea and should be implemented.

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MICHAEL J. MATHEWS, CLU

Date: August 4, 2009

I would support this new educational requirement.

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MARY LOUISE MAVIAN, FORMER CFP® CERTIFICANT

Date: August 4, 2009

I think this is an excellent requirement to instill into the process. All CFPs should prepare a detailed financial plan covering all areas of financial impact on a family or individual.

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DON MAXON

Date: September 4, 2009

The requirement of a Financial Plan Development Course is a valuable addition. I am currently taking such a course at Golden Gate University as part of the MS Financial Planning curriculum. The preparation of an actual plan for a real client is excellent experience to add to the academic preparation for financial planning.

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EJ MCCARGAR PHD, CFP®, CDFA

Date: August 3, 2009

As a former instructor of the CFP education curriculum, I am in favor of the proposed Financial Plan Development Course. This has been the missing piece of the education curriculum that needs to be thoroughly developed and implemented into the education programs throughout the country. This would integrate the various principles and hopefully create greater understanding of plan design and implementation. Secondly, it would raise the bar and assure that those trying to obtain the CFP mark are genuinely interested, and understand the responsibilities of using the mark.

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SCOTT A. MCCASKILL, CFP®, RFC®

Date: September 30, 2009

Personally, I think it would be a great addition to the CFP® curriculum.

The ability to both create and present a financial plan should be considered an integral part of being a Certified Financial Planner® practitioner.

The other courses provide the knowledge needed to design the financial plan. This new course will provide the ability to communicate said knowledge to the public.

I am definitely in favor of the proposed Financial Plan Development Course Requirement.

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JOHN D. MCEWEN, CFP®, MBA, MS

Date: August 3, 2009

While I am all in favor of the concept there is one part of the proposal that if enacted would have prevented me from obtaining my CFP. It is the word "oral" on the presentation. I graduated from Kansas State with my Masters in Financial planning. I did this while living in Wisconsin. This program, as you are probably aware, is through the great plains educational system whereby the course work is done on the internet. Having to present orally would have required an 11 hour drive to Kansas. By the time you get 3 years of course work into a masters program, chances are (although we can all think of exceptions) you can present your work. Understand the validity of the requirement, it just that it presents roadblocks for those who are working and going to school.

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JANE MCGINNIS, CFP®

Date: August 3, 2009

I think this is a superb idea and my comment is: “It’s about time”. I received my CFP at the end of 1984 and have focused on comprehensive financial planning ever since. Fortunately for me I have worked with many “new” CFPs and some with many degrees and credentials. I, however, do not think there should be exceptions for someone with a PhD, law degree etc. Trust me, unless mentored, or working for a comprehensive financial planning firm, how would one know how to put together a financial plan, present the plan, and do the pertinent follow up to make sure it is properly implemented? There is way more to financial planning than the plan itself. Thank you!

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KEVIN D. MCLOUGHLIN, OPERATIONS MANAGER

Date: August 4, 2009

What if a person has not passed the CFP exam, but has completed the education requirement already?

This rule, I would hope, would not be retroactive, because the tuition for many of these programs is already high.

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KAREN MELO, CFP®

Date: August 3, 2009

As a new CFP® certificant, I think it would be an excellent idea to require this course of all programs. This IS what we do as planners, and it would help our industry as a whole become more cohesive in the service we provide. Although Bentley incorporated this in part with many of its classes, I’m not convinced that other programs do the same. It would have been very helpful for one of my required courses to have an entire section on how to build a plan and present a plan, including the “selling” of this service, as many consumers still believe that they can get a “free” plan from their product representatives. It’s a huge misconception that I would like to see the CFP Board work towards clearing up.

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JEFFREY B. MERSHON, MBA, CPA/PFS, CFP®, CHAIR FOR FINANCIAL PLANNING, KAPLAN UNIVERSITY, ONLINE CERTIFICATE IN FINANCIAL PLANNING

Date: September 17, 2009

As Assistant Executive Director of CFP Board for five years, I am quite familiar with the historic, customary process of the creation of a task force by an entity within CFP Board. The creation and operation of the Task Force on Education has been no exception. Typically, the task force created is obliged to return with some meaningful recommendations for the consideration of the entity within CFP Board that created it. This places the creating entity in the position of having to evaluate the task force’s recommendations and understandably it is quite reluctant to fail to endorse the recommendations made. In the case of the recommendation to require the addition of a course on financial plan development and presentation, it was probably very easy for the Council on Education to endorse such an academically sound recommendation. When one considers the composition of the Council on Education, this comes as no surprise. To my knowledge, every member of the Council is associated with a not-for-profit, traditional classroom, generally degree-awarding educational institution. As I understand it, there is no representation on the Council from a for-profit distance education/self-study educational institution. And yet only three such institutions provide approximately 60-70% of the annual CFP certification exam first-time test takers. These institutions are the College for Financial Planning (owned by Apollo Group), the American College, and Kaplan University/Kaplan Professional (owned by Kaplan, Inc. and, in turn, by The Washington Post). It would seem appropriate when considering a proposal of this magnitude that the feasibility and practicality of implementing this recommendation at all types of educational institutions should be considered—particularly those that provide such a major portion of the test takers.

Indeed, in the question and answer session with the Council on Education at the 2009 Program Directors’ Conference, the approach of the Council seemed to me to be not one of hearing reasoned objections to such a proposal but rather for each educational institution to figure out how to comply with it, regardless of what type of institution is involved. It appears to be a “one size fits all” approach. A traditional classroom, not-for-profit, degree-awarding educational institution generally employs either full-time or part-time faculty and if those faculty members are required to teach a course involving an oral presentation of a case developed by their students, such an institution should have little difficulty doing so in its classroom setting and, most likely, at little if any additional cost to the institution. Such is not the case with a for-profit, distance education, self-study, educational institution. I cannot speak for the College for Financial Planning (even though I served there as Director of Curriculum Development) nor for the American College, but typically such institutions use adjunct faculty who are generally paid on an hourly basis. Even if it were feasible to conduct an oral presentation in a distance education/self-study environment, the additional faculty hours required to do so would be substantial. In the case of our institution, we estimate an additional charge to our students of approximately $1,000, representing an increase in the price of our program of approximately 30 percent. Particularly, in the economic situation we all currently find ourselves, this would result in a substantial reduction in our financial planning program enrollments.

To quote from CFP Board’s core objective focused on education in its strategic plan, the role of CFP Board is “supporting the marketing initiatives of registered programs and improving CFP Board’s support of the “pipeline” of potential CFP® certificants.” Requiring its major providers of test takers to increase the price of their programs by 30 percent or more and to suffer the consequent substantial decline in enrollments does not constitute “supporting the marketing initiatives of registered programs”. And if CFP Board wishes to see the “pipeline” of potential applicants dry up, then by all means impose this proposed requirement. Our marketing managers indicate that we are already at a price point where additional price increases could result in decreasing enrollments. Adding an additional course to our programs under the conditions we need to operate as a for-profit distance education/self-study educational institution would result in a major hit to our current and future business.

It is easy to find fault with a proposal but more difficult to offer constructive suggestions to accomplish to proposal’s goals. Inasmuch as Kaplan agrees with the soundness of implementing such a requirement, the question becomes how it can be implemented in a realistic, practical, and feasible manner. It may be beneficial to look to the Certified Public Accountant model. In such a model, a person is required to complete a period of employment with employers that provide a specific type of experience (typically auditing) and to document that experience. Presumably those who have completed the requisite education (five years in many states), passed the uniform CPA examination, and also have completed the requisite documented experience, are considered worthy of licensing and therefore able to deal with clients. It would appear that CFP Board’s experience requirement as it now exists could be easily modified to require experience in the development and presentation to clients of a comprehensive financial plan. A key question that the Council on Education and, in turn, the Board of Directors needs to deal with is “Is it the proper role of a certifying body to determine if an applicant for certification is fully prepared to develop and present a financial plan to clients or is this more properly the role of the certificant’s employer?” Again, if the CPA model is followed, the ability of a CPA to perform an audit is not provided through the CPA education requirement but rather through the CPA experience requirement wherein a candidate for the CPA license must have obtained very specific experience through an employer that must document the required experience in writing. It appears to me that there is a very strong parallel between the CPA model and the CFP® model in terms of what skills must be confirmed by documented on-the-job experience with an employer. Presumably, CFP Board could permit satisfaction of the financial plan development and presentation experience requirement by completing such an academic course at a CFP Board-registered educational institution—specifically a traditional classroom, not-for-profit, degree-granting institution.

When considering a proposal such as this, it is often instructive to look at the likely effect on the profession. While, on the one hand, increasing the perceived rigor of obtaining the CFP® certification will add to the prestige of the certification, this must be balanced with the increased expense to students and the addition of yet one more hurdle for them to overcome. This is a tradeoff that CFP Board must evaluate to determine the appropriate balance between increased perceived rigor and the imposition of expensive and increasingly arduous requirements—the direct result of which may be a significant decline in both the pipeline of test takers as well as the number of certificants. Further, it would appear that implementing this proposal will have a similar effect on the number of challenge students. It seems clear that a certain percentage will choose not to sit for the exam due to the fact that they will have to also complete this proposed requirement in order to gain certification. This is particularly true in the case of CPAs who have historically been the best test takers.

Moreover, the types of students in traditional classroom, not-for-profit, degree-granting institutions differ markedly from the types of students enrolling in the education programs of the major providers of CFP® certification examination test-takers. In the former type of education institution, probably a majority of the students are between 18 and 21 years of age who have little or no experience in financial services. This type of student certainly needs to receive instruction in how to prepare and orally present a comprehensive financial plan. This is almost exclusively not the case with students who enroll in the education programs of for-profit, distance education/self-study institutions. The vast majority of these students have been employed with a major financial services institution and the reason they enroll in these programs is either because their employer requires them to do so or because they know that their potential for advancement will be greatly improved by completing a CFP® education program. These students are older and many are heavily experienced in the financial services field. They have been hand-picked by these prestigious firms and many have been trained by their employers in the development and presentation of a comprehensive financial plan in the manner that the employer deems appropriate to how it does its business. Many of these firms would be able to provide written documentation of this experience to CFP Board. To require this type of mature, experienced student to complete an additional course in the preparation and presentation of a comprehensive financial plan seems like a solution in need of a problem. And, as mentioned previously, the cost of such an additional course will need to be added to the cost of the entire program thus seriously impacting the group and other enrollments of these programs and accordingly resulting in significantly fewer test-takers.

I ask the Council on Education and, in turn, the Board of Directors of CFP Board to give serious consideration to the points made above concerning the proposed financial plan development requirement. If the Council on Education is willing to explore a compromise position on this proposal, Kaplan is ready and willing to provide the benefit of its many years of educational experience in helping determine such a position.

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ERIK F. MILLER, CFP®, ChFC, CASL™

Date: August 3, 2009

My only comment on it is that it would be wise to install this kind of module so that those that have never been in the industry gain an understanding of what a formalized written plan actually looks like.

You would have to be careful not to endorse any specific software vendors or styles (MoneyTee, Naviplan, etc.) but I am sure the CFP Board has thought of this. Thank you!

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KEVIN MILLER

Date: August 4, 2009

I think it would be very beneficial and I like the idea.

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STAN MOCK, CFP®

Date: August 3, 2009

I am very much OPPOSED to further requirements. Taking and passing the certification course satisfied the requirements to become a Certified Financial Planner. In addition, you REQUIRE that each CFP attend CE workshops or correspondence courses. I believe enough is enough.

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DOUGLAS MOLSTAD, CFP®

Date: August 6, 2009

Overall, I feel that the new requirement would be a welcome addition to the prerequisites for taking the CFP examination. It is critically important that a candidate for the CFP license show the ability to integrate the different areas of financial planning into a comprehensive financial plan that is easily understood by clients.

However, I do not agree that part of the requirement should be an oral presentation. There are some financial planners that do not ever directly interact with clients because their jobs are to create plans while other individuals meet with the clients. I feel it would be wrong to impose on these planners a requirement to do something that they have not done and will not do because of the way their jobs are defined.

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NANCY MORGAN, ChFC, CPCU, CASL

Date: August 3, 2009

I think the industry is going too far with requirements. I personally did not renew my CFP due to the new “fiduciary” standards. I place my clients needs above all, but the fiduciary standard is going too far. We can’t force clients to implement a plan we recommend and to be held liable when they fail to heed advice is foolish. The same with this new proposal. The requirements to obtain and maintain a CFP designation are the most stringent in the industry, and adding to that is unnecessary. What needs to be done is stricter action and penalties on those in the field that compromise their ethical standards. Instead, the board makes it more difficult for everyone including those who already practice in an ethical way.

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JEAN MOTE, CFP®

Date: August 10, 2009

The requirement for a Financial Plan Development Course for the CFP® preparation is excellent. However, the necessity for both written and oral presentation of it seems excessive. Because many courses are offered online, and because many areas of the country do not provide classroom access to the program, an oral presentation would be very difficult or even impossible.

I appreciate the continued review and enhancement of the CFP® requirements. They must change as our industry changes. It is important that the needs of the consumer are met and that the CFP® mark retain its reputation for excellence.

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BOBBIE D. MUNROE, CFP®

Date: August 4, 2009

I think this is a fantastic idea as, without the FPA Residency Program, I wouldn’t have had any guidance on creating and delivering a comprehensive plan. I’m not sure it would take 45 hours. Rather, I envision 3 hour classes on:

  1. Introducing the facts of the situation (perhaps roll played by a couple in the classroom)
  2. One class on each module and how it applies to the plan
  3. One class on other issues
  4. Presentation – this is what could eat up the time. Perhaps this would be done one on one as the “test” for this part of the requirement.

Also, the CFP programs should offer this module as a stand alone so that those who are opting out of a certification program can still fulfill this requirement.

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CHARLES MURPHY II

Date: August 7, 2009

I think it would be a good idea

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JACK MYERS, CFP®

Date: August 3, 2009

Let me keep this simple. NO.

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STEVE MYLER

Date: August 4, 2009

Excellent addition to the program qualifications.

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CHUCK NEFF

Date: August 3, 2009

I think this is a good idea – being able to integrate the major financial planning areas into a comprehensive plan for clients should be a prerequisite for becoming certified.

In addition, I believe increasing the requirements adds value to the designation.

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EDGAR NORTON, PH.D., CFA

Date: August 20, 2009

I am not in favor of this proposal for several reasons:

  1. Practicality: many undergraduate or graduate programs are squeezed on credits as it is. This would require another 3-credit course and may cause some programs to surpass university-mandated limits on credit hours (e.g., 120 hours or 124 hours for a B.S. degree).
  2. The focus of the exam is not on a full-case analysis and presentation. That comes with experience and learning-by-doing with the guidance of a mentor. CPA candidates do not need to run an audit in order to sit for the CPA exam.
  3. It delays taking the exam for otherwise qualified and exam-ready candidates.
  4. Uniformity: who will grade/judge whether a plan passes muster or not? My grading scale may be more or less rigorous than someone else’s.
  5. The bar exam, CPA exam, CFA exams, etc…some have a work experience requirement, like the CFP exam, but none have such a requirement of completing a project, analysis, or plan before a candidate can even sit for an exam.
  6. This assumes the old model for creating financial planners—get them trained and out the door to attract clients. The new model is (or should be) similar to that of law firms and CPA firms. Newly-minted lawyers and CPAs are not put in charge of cases or audits, or attracting clients. They are part of a team, are mentored, and grow professionally until they, too, can increase their responsibilities and/or gain clients. New financial planners/CFP certificants should not be assumed to be writing client financial plans—yet—based upon where they are in their careers.
  7. Doesn’t the 3-year work experience requirement cover this already….3 years of growing in the discipline, with mentors—should be sufficient in many cases.
Thank you for the opportunity to share these thoughts.

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NATIONAL ASSOCIATION OF PERSONAL FINANCIAL ADVISORS (NAPFA)

Date: September 11, 2009

Download the letter submitted to CFP Board by Ellen Turfy, CEO of NAPFA, and Susan MacMichael John, CFP®, Chair of the NAPFA Industry Issues Committee (PDF format)

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GREGORY OCHALEK, CFP®

Date: August 4, 2009

I am not in favor of the proposed financial plan development Course requirement as I understand the proposal because many CFP do not directly practice general financial planning. Many of us are specialists in specific areas of financial planning like nonqualified executive benefit plans, wealth management, life insurance products, etc. Perhaps the requirement could apply to those who work in the general financial planning process as a part of their regular practice. Please consider my comments.

Thank you for your efforts.

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WILLIAM O'LEARY, CFP®

Date: August 4, 2009

Yes, I agree that this would be a nice addition to the overall program. We want to be sure that candidates for CFP certification truly understand the concept of financial planning for individuals and families, and this would assist in reaching that objective.

Thank you for your efforts.

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STEVE OVERTON, CFP®

Date: August 3, 2009

I support the CFP Board's plans to install a financial plan requirement. I wish it had been required when I received my certification.

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KENNETH M. PALLACH

Date: August 4, 2009

I think this would be a very constructive addition to the curriculum.

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THOMAS J. PANOS, CFP®, ChFC

Date: August 5, 2009

Yes I am all for this.

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KEVIN PAULSEN

Date: August 3, 2009

I believe the Proposed Financial Plan Development Course Requirement is a great idea! It indeed helps the prospective certificant take a step from study to practical application.

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DAVID S. PEARSON, CFP®, CLU, ChFC

Date: August 4, 2009

I absolutely support the proposal to include a Financial Plan Development Course as a prerequisite for exam eligibility.

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TOM PEMBERTON, CFA, CFP®

Date: August 3, 2009

I teach in three different university CFP programs. Each of them has a case study module but only one program requires the student to actually produce a financial plan. The Duke University Executive CFP program divides the class into groups of 3 or 4 individuals. Each group is assigned two case studies and must develop a financial plan, present it to the class, answer questions about the plan from the curriculum and from their classmates. The students grade for the module is based on their written and oral presentation of the plan and the questions they are asked.

I teach the Duke case study module and have found it to be an extremely effective way to bring the entire program together. I strongly endorse a requirement similar to the Duke format.

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TODD PERRY, CFP®

Date: August 4, 2009

This would be a plus for the program. Being a recent CFP® professional, I wish I would have had more preparation in my classes doing comprehensive financial plans. It’s easy to study the different areas separately but learning to integrate the topics is a different story. I also think presenting the plans would be good practice to get students familiar with delivering complicated material in a clear, concise manner within a prospect/client scenario.

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GREG PHELPS, CFP®, CLU, AAMS

Date: August 3, 2009

I'm in favor of the proposed changes as it further increases the standards in our industry in these challenging economic times when the CFP designation needs to really "shine" as the superior designation in the field.

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CHRISTI S. POWELL, CFP®

Date: August 4, 2009

Thank you for the opportunity to comment on a Financial Plan Development Course. As a relatively new CFP (less than 5 years) with no prior experience in the financial services field I found the work environment quite confusing and deliberately opaque. My mentor was secretive with the templates used to build the verbage used in plans. When I left to start my own business there was no sharing or help. The addition of a course such as you describe would help the new practitioner hit the ground running and have tools essential to the fiduciary relationship.

It seems so incongruous to speak of fiduciary responsibility in an industry that seems to thrive on competition for clients. My former profession (healthcare) might serve as a role model in caring for clients. Perhaps the compensation structure is all wrong, even in my chosen fee only manner.

Best of luck in designing the course.

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STEPHEN C. POWER, CFP®

Date: August 4, 2009

I support the move to add a Financial Plan Development Course to the CFP Board's education standards.

Throughout my 34 year career in financial services, I have been involved in delivering financial literacy and education via a large number of different platforms. For six years at the University of Texas San Antonio, I taught a "Capstone" case study course that followed the courses of study for those seeking to earn the certified financial planner designation.

More recently, I have become involved in teaching financial literacy to high school students via the NEFE High School Financial Planning Program (HSFPP). Here in San Antonio, at the end of the semester's HSFPP lessons, participating students are given a case study about a hypothetical family in financial distress. Schools compete against each other to come up with viable solutions. We call our program "Junior Duel in Old San Antonio". The case study helps students "pull it all together".

In both of the classroom environments I cite above, it's gratifying to observe students who understand the challenges of financial planning and who effectively present their recommendations. A course in financial plan development will strengthen the Board's education standards, and it will result in providing the general public with CFP certificants more capable of delivering appropriate solutions.

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KENNETH W. PRICE, CFP®, CHFC®, CLU®, DIRECTOR, UNIVERSITY OF TEXAS AT AUSTIN FINANCIAL PLANNING CERTIFICATE PROGRAM

Date: September 30, 2009

We are pleased to see that there will be a requirement for a Financial Plan Development Course in the near future. We have required one in the University of Texas Financial Planning Certificate Program in order for the students to receive a certificate of completion of our program although it’s not required for them to sit for the board examination. We’ve had great success with the class entitled Strategies and Case Studies and will begin our 13th session of leading it this coming January.

There are a few suggestions we would make to your proposed framework.

We recommend that the students be allowed to write and present the financial plans in groups or teams.

  • This allows the students to benefit from one another’s backgrounds as there are students who have an insurance background, an investment background, an accounting or tax background, and still others who are career switchers and therefore no exposure to the field.
  • This will inevitably cause the students to write and present plans that are more comprehensive as opposed to skewed more to their area of expertise.
  • It forces students to adequately become more proficient in the areas of the financial plan that they are not as comfortable in.

We recommend that the minimum of 45 contact hours read as a minimum of 30 contact hours.

  • This shortened contact hours reflect the fact that the students would already be spending more than 90 hours outside of class for this course. During this course in our program the students spend at least 90 hours outside of class time analyzing other cases as examples, preparing their own cases within small groups, writing the financial plan, and then actually preparing to present the plan as if they were doing it in front of a client.
  • It allows for the programs to be a little more flexible to account for various class sizes.

We suggest that the assessment have a component for other grading factors.

  • Having an allowance for assignments and quizzes allows the instructor(s) to make sure the students are on the right track in instructor-led cases or item sets before they tackle one comprehensive case of their own.
  • This would allow the instructors to assess and give immediate feedback to students on whether or not they are properly assimilating all the required disciplines necessary prior to preparing a financial plan.

Again, we appreciate the value of this course as requirement as we have already seen it beneficial for our students the last 12 sessions that we offered it. We just recommend that the students be allowed to write and present the financial plans in groups or teams, that the minimum of 45 contact hours read as a minimum of 30 contact hours, and that the assessment have a component for other grading factors.

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CHARLES A. PUTNEY, CFP®, EA

Date: August 4, 2009

The proposed Financial Plan Development course is a good idea and should be part of the CFP curricula. Real world scenario planning is the difference between an academic abstraction and a plan that clients can relate to and use as a road map for their future.

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Debra M. Quade, CFP®, CRPC®

Date: September 29, 2009

I am in favor of including the Proposed Financial Planning Development Course. CFP® certificants have varied backgrounds and while many may never be a face to face client meeting, I think it is imperative they understand how to approach a client via a case study. It also provides relevance that our recommendations will have impact on client’s lives and their families and that the designation is valued by the public for this primary reason. I personally know someone who passed all of the CFP® coursework but felt ill-prepared to sit for the exam because she did not feel comfortable with developing a financial plan from data. I think many people would benefit from this course but do have concerns about how to handle the obvious subjectivity. I think it the certificants would benefit from viewing strong role play-best practices and this should be integrated into all the various programs consistently (perhaps by video). Overall, believe this is the seminal part of CFP® and should be a necessity.

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DANIEL RAY, CFP®

Date: August 3, 2009

I favor this. For many years I have found it strange that this was not part of the curriculum and part of the requirement. The financial plan is what demonstrates the integrated / wholistic aspect of the CFP, yet the course work “unbundles” the realms of knowledge, i.e. retirement planning vs. insurance vs. investments vs. estate planning. So, where does the course work integrate these things? And, it has always frustrated me that the course teaches highly specialized info on ERISA plan rules, but doesn’t teach basic things like how to calculate whether a client has, or likely will have enough to retire.

So, I support this as a step in the right direction.

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BILL RENO

Date: August 5, 2009

What a novel idea. A financial planning curriculum that actually includes a Financial Plan Development Course; what will we think of next?

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DR. PAUL RIVERA, CURRENT CFP BOARD PROGRAM INSTRUCTOR AT FAIRFIELD, SACRED HEART AND PACE UNIVERSITIES

Date: September 20, 2009

I am happy to learn that the subject is under consideration,,,as a CFP instructor for over 30 years, the ability to prepare and articulate a complete and comprehensive Personal Financial Plan, encompassing the major CFP competencies (Insurance/Risk MGT, Tax, Investments, Retirement/Ee Benefits, Estate Planning, etc)...should be a key task and skill of the CFP practitioner. In that regard the Case that I previously wrote for the CFP exam as well as test items that I prepared in earlier years, were intended to reflect the corresponding overall skill set that would be reflected in the proposed course.

I would recommend, if not yet considered, that the CFP Board develop a more specific set of standards for the evaluation of the oral portion of the end of course test....such would include:

  1. A Standard check list that would be used by all educational programs to assess the oral portion of the test....such a check list would help to establish some level of objectivity in the oral evaluation by ensuring that specific criteria, as determined by the CFP Board, be appropriately treated.
  2. A basic Personal Financial Plan Outline, developed by the Board, that the presenter would follow in the development and presentation of their plan.....

As a Member of the Curriculum Development Committee for The Albertus Magnus College's MBA program, I co-developed both the College's Business Plan Thesis outline as well as the oral evaluation criteria check list,,,,and both served as excellent tools for evaluating the oral presentation of MBA candidates.

In addition, a colleague at Fairfield University, where we both are CFP program instructors has been developing a course with similar objectives.

Please do not hesitate to contact me should you want to explore these ideas further.

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THOMAS S. ROGERS, CFP®

Date: August 5, 2009

This sounds like a good idea to me.

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LINDA C. RUTLEDGE, CRPC, CFP®

Date: August 3, 2009

I love the idea of requiring the candidate to create a financial plan. I think this would prevent those who don't do financial planning to use the CFP mark if they just wanted the designation for show. I don't think it would prevent those who currently have the designation who are not currently in a planning role to use the CFP designation.

So, I support this as a step in the right direction.

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JAMES S. RYAN, J.D., CFP®, AIF®

Date: August 10, 2009

I commend the Board on its goal of better qualifying new Certificants. I am curious as to whether we could provide two paths to the end goal? With that being said, my suggestion would be to possibly segregate applicants into two groups; one group who intends to practice independently and the other group who will be practicing in concert with or in the employ of a CFP designee(s). So unless the individual seeking to attain CFP certification is going to practice on their own, I would suggest the same number of contact hours be documented by a practicing financial planner overseeing the work of the applicant. Upon successfully completing that number of hours, the applicant would submit their financial plan, prepared solely by them, to the Board for review. Those individuals working independently would be required to complete the Financial Plan Development Course through the normal program.

In the end, we all would prefer individuals in our profession to be as well prepared to provide quality, comprehensive planning advice to their clients, as early in their career as possible. However, day to day working experience in a supervised environment may provide the same quality outcome as a course.

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LORRAINE R. SALVO, CFP®

Date: August 6, 2009

I agree with this proposal as this knowledge is key to being a successful planner. It should be CFP Board’s responsibility to ensure that all certificants are knowledgeable in this area, given the variation in training and mentoring programs available at our respective employers and the possibility that we do not receive formal training in this important area after becoming Certified Financial Planners™.

Will a training program be created as an optional course/set of courses for those who are already certified?

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DUSTIN SANDLIN, CFP®, AAMS

Date: August 3, 2009

As a former student of the PFP program at Texas Tech University, I am in support of a educational requirement designed to provide practical application of Financial Planning course work. I appreciate it's requirement at TTU.

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STEVE SANT, CFP®

Date: August 4, 2009

I am opposed to the proposal to add a Financial Plan Development Course to the current CFP® certification process.

It seemed like a good idea at first glance. After all, I’ve worked with many new CFP® practitioners that, although properly credentialed, had no idea how to implement all of that knowledge. I even remember doing my first comprehensive financial plan in 1993. I felt both knowledgeable and ignorant at the same time.

Then I remembered that part of the curriculum prior to moving to the 100% multiple-guess format was implementation of the plan. In fact, my recollection was that 50% of my grade was determined by how I recommended implementing the concepts I had just learned. Although I have a very successful comprehensive planning firm today, those financial plan development courses didn’t actually help me in real life. What did help was a good mentor once the basic knowledge was in place.

Converting back to a program that did not meet its intended objectives seems more like a step backward than a step forward.

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TRACY SCHAFF

Date: September 27, 2009

I am in support of the proposed framework for the Financial Plan Development Course requirement especially for those who are either entering the field or rhave ecently entered the field. Looking back my at experience, the core curriculum did a great job of teaching me all the important aspects of financialy planning, but never attempted to put it all together into one financial plan. I had no idea what a plan looked like until I first started working in the field, which was after I completed the core curriculum.

I do not however, feel that it is unnecessary to impose this requirement on those that are experienced (3+ years in the field). These are professionals that already know the financial plan development process or don't find it applicable. Thus, I feel they should be waived from this requirement. All others, or anyone with less than 3 years of experience from the date they finish the core curriculum should have to complete this requirement, in my opinion.

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RAY SCHENK

Date: August 3, 2009

Based on the CFP Board's Request for Comments on Proposed Financial Plan Development Course Requirement, I am writing in support of the proposed course requirement. Additionally, I think continuing education courses offered to current CFP Practitioners in the area(s) of developing financial plans would be an excellent tool to help all Practitioners to provide more comprehensive, thorough, and well developed financial plans to their clients. I have been a FINRA/NASD Registered Representative for many years, and have been a CFP Practitioner since early 2002. Over the years, I have seen many well crafted financial plans, as well as many that were vague, lacked substance, or were poorly written. While financial plans can vary based on the needs of clients, a standardized plan development course(s) and/or CE, would help all of us to create more valuable plans for our clients. Thank you for your time and consideration.

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CARROLL SCHERER, DIRECTOR OF PROFESSIONAL PROGRAMS, SUSANNE M. GLASSCOCK SCHOOL OF CONTINUING STUDIES, RICE UNIVERSITY

Date: September 9, 2009

Having offered a Case Studies course in its classroom-based curriculum for several years, Rice University is supportive of the concept of requiring CFP candidates to complete a Financial Plan Development course. After hearing the presentations at this year’s CFP Directors’ Conference and considering Rice University’s experience offering this type of course, we respectfully submit the following recommendations regarding the proposed course requirement:

1. The Financial Plan Development course and completion of a financial plan should be a requirement for licensing, not for taking the CFP Exam. In addition, we recommend that CFP candidates be required to pass the CFP Exam before taking a course that requires completion of a financial plan. We are favorably inclined toward having this requirement satisfied through a university course, but recommend the requirement be satisfied after candidates take the CFP Exam for a number of reasons.

  1. Taking an extended Financial Plan Development course that requires a great deal of concentration and presenting a financial plan before the CFP exam is not ideal, because candidates will be distracted from studying for the exam itself.
  2. Many education programs end shortly before the date of the CFP exam, leaving only 4-6 weeks to complete an exam review and take the CFP Exam. Adding time to the education program to complete an additional course before the exam might preclude taking an exam review course or taking the exam on time, which would be detrimental to pass rates.
  3. CFP candidates prove they have mastered the financial planning body of knowledge by passing the CFP Exam; therefore, passing the exam should be a requirement for taking a Financial Plan Development course that requires completion and presentation of a financial plan. In addition, those who fail the CFP Exam and never retake it should be weeded out from those who are more serious about their financial planning careers, before they complete the Financial Plan requirement.

2. If the Financial Plan Development course is made a pre-exam educational requirement, CFP Board should allow universities the flexibility to create a separate course outside of their current educational program or to opt out entirely from offering the course. This approach would solve many problems for universities who have obstacles beyond their control such as accreditation and budget restrictions. With this approach a university could opt to offer the course through another arm of the university, or let their students satisfy the requirement by attending another university’s course via the internet or an intensive format in a nearby city. This approach should add value to CFP candidates as they would complete the Financial Plan Development course requirement with a university that has the appropriate resources to deliver a quality course.

3. CFP Board should depend on the expertise of the educational providers to determine the best length of the course, given the format of their program (degree, certificate, accelerated, etc.). Rice University has offered a Case Studies course in its accelerated classroom-based program for several years and has found that 25 hours is sufficient to meet the proposed requirement that each student participate in creating a financial plan and make an individual presentation (for 20-25 students). Class size will have an impact on the appropriate length of the course, as the amount of time allotted to presentations will vary; therefore, universities should be allowed to adjust the class length as appropriate. Furthermore, during the CFP Directors’ Conference, a representative from a degree-granting program said that they don’t spend the entire 45 hours of their Case Studies course creating and presenting a financial plan – she said that the financial plan could easily be taught in much less time.

4. CFP Board should allow flexibility for the financial plan document to be created as either an individual or team project and should allow the presentation length to be determined by the universities. This will help programs with large classes and/or accelerated formats to deliver the program in a reasonable length of time.

5. CFP Board should allow universities to determine the method of delivery of the presentation. Various formats, including live or recorded presentations, in-class or online, should be allowed to satisfy the presentation requirement.

In summary, while Rice University supports the intent of the proposed Financial Plan Development course requiring a financial plan and presentation, we request reconsideration of the timing of the requirement in the certification process, as well as flexibility in developing and implementing the course. Kathy Hartin and Joe Gillice, Rice’s academic directors, or I would be happy to participate in further discussions about this important issue.

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MARK C. SCHNEIDER, CLU, CFP®

Date: August 4, 2009

In general I am opposed to any addition educational requirements. Having only recently taken the exam, I find it impossible to conceive that an individual could pass the exam and not be able to prepare and present a proper financial plan.

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Joyce Schnur, MBA, CFP®, Vice President, Kaplan Schweser

Date: September 30 2009

As a provider of several board registered education programs including self study, virtual and traditional classrooms, we have a unique view as to the issues of implementation of this requirement and we can appreciate the council’s work to provide consistency in the curriculum. I personally am a CFP® certificant who practiced for over 20 years and certainly agree with the need for CFP certificants to be able to deliver comprehensive planning to their clients. However, the disadvantages to the profession, I believe, outweigh the advantages from this noble initiative. While there are clear problems with the course as it has been originally presented, which include increased cost and expected decrease in CFP candidates, there is certainly a way to include cases in such a way as to avoid these problems.

The presentation portion of this requirement is problematic to distance learning programs which currently send the majority of candidates to the Board for examination. It was suggested by the education panel at the recent program directors conference that the presentation portion could be done via Skype or by sending in a 15 minute video tape. There is a significant inherent cost to these requirements not only to the education providers to build up technology and instructor costs, but to the candidates as well to acquire the necessary webcam, video recorder etc to comply with these requirements. The additional cost could drive qualified practioners away from pursuing certification and would limit the potential for additional certificants. This does not insure the public’s best interest. Based on discussions we have had with challenge type candidates, we would expect fewer of these other professionals to take the exam.

It was suggested during the conference that the ability to present a written plan should be reviewed when a candidate submits his or her experience to the Board. Perhaps the candidate should receive a recommendation by another CFP certificant to attest to his or her abilities. The advantage to this approach is that it is less likely to negatively impact the number of candidates pursuing the CFP credential.

We would also like to address the written plan requirement as it currently has been explained. The ability to spot, address and implement a client’s comprehensive financial planning needs is a critical component of being a CFP professional. The education component of CFP Board’s requirement should be to educate the potential candidates on the issues necessary to provide comprehensive planning. The education courses can provide guidance to the students by introducing case discussion into the curriculum. This can be accomplished by reviewing and testing the candidates on several case studies throughout their education courses. Again, the assessment during the education program should focus on cases, not on writing a comprehensive plan from scratch. The creation of a comprehensive plan could be a much different experience given the current position of a candidate. For example, a current practioner could simply utilize the software utilized by his or her current employer while a career changer would not have access to the same tools, thereby creating an undo burden to write a plan. The review of a comprehensive plan should not be done until a candidate has completed the examination and is submitting his or her experience to the Board.

There are two other specifics of the proposal that we would like to address. The first issue is the 45 hour of class time requirement. There was significant discussion at the program directors conference that the hour requirement is just too high. We provide a capstone case course in conjunction with several of our university programs that is 28 hours at the end of the curriculum. The students spend numerous hours outside of class time preparing their cases. The additional classroom time would not be overly beneficial to the students. The second issue is the desire for challenge candidates to complete this requirement as well. Program directors of traditional classroom may not have the ability to add challenge candidates to their classrooms. It may be too costly to administer and matriculate students. Many programs use adjunct faculty and the review of the comprehensive plans would be labor intensive thereby increasing the costs. Some also feel that the chemistry of the cohort may be upset to add in additional students at the end of the education program. Certainly, undergraduate institutions would not have the ability to do this. Distance learners organizations may be the only way for challenge candidates to fulfill this requirement. This issue surrounding the delivery of the requirement for distance learning providers has already been discussed above. It was suggested that challenge candidates who are current practioners could “challenge” out of this requirement as well by submitting a written plan to the Board directly, again this could be done upon completion of the examination when they submit their experience. As currently proposed this would be another barrier to entry for some very qualified practioners to become CFP certificants.

In conclusion, while this is a lofty goal, there are real issues that must be considered before forcing this upon the programs. This would be different if obtaining the CFP designation was a requirement of working as a financial planner. Unfortunately, that is not currently the case. I’m sure that everyone in the profession would like to see that.

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BILL SCHRETTER

Date: August 5, 2009

Although I disagree with any "hours standard" associated with the requirement, I do think that the demonstrated ability of being able to interview clients, develop a plan, document a plan, and present a plan are critical components of our profession. A new CFP candidate should have some experience in delivering that type of presentation. I consider it a "capstone" element of a complete CFP development program.

Besides my career experience, the ChFC preparation had a financial plan development module associated with it that I had to complete. As a profession, the more we encourage financial planning skills development, the more we will be able to change the overall financial industry from a transaction mindset to a more holistic planning profession. I want the public to trust that when they see the CFP acronym, they know they are working with a professional that has demonstrated an expertise with client interviews/fact finders, plan development, formal documentation, and presentation of a financial plan. A plan created and presented by a person who takes their fiduciary obligation seriously. It does not help the profession or the client to have an advisor who is knowledgeable, but not skilled enough to present a plan.

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EDWIN SCHROETER, CFP®

Date: August 4, 2009

Excellent to require grooming in financial plan compilation and design.

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PATRICIA SCHULTZ, CTFA, CFP®

Date: August 4, 2009

I feel this is a most appropriate requirement. In fact, as a CFP I would be interested in taking this course. Please keep me informed as to the inclusion of this requirement and the opportunity to participate.

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JUDITH L. SEID, CFP®

Date: August 3, 2009

I agree with the new proposal for a fin plan development course...this is of course a vital role the planner will be playing in someone's life

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MARCUS SEITER, CFP®

Date: August 4, 2009

I think this is a much needed requirement.

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HOWARD A. SENESCU, CFP®

Date: August 4, 2009

My suggestion is to incorporate the financial plan development material into the current course curriculum taken by most certificants. I would not make it a separate requirement as this would add to the costs involved.

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PETER SHANAHAN

Date: August 4, 2009

I am in favor of a Financial Plan Development Course Requirement.

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RICK K. SHAPIRO, CFP®

Date: August 3, 2009

I believe, after cursory reading of the proposal, that this is a beneficial idea for both CFP candidates and the public at large.

Including such a requirement will serve to provide the candidate with practical/hands-on experience which can only benefit him or herself and his future clients.

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DAMIAN SHAW, CFP®, M.A.O.M.

Date: August 4, 2009

This appears to be very practical in nature. I am very much for it.

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ELLEN R. SIEGEL, CFP®, ChFC, CLU

Date: August 4, 2009

I am in full support of this addition to the CFP® curriculum. Question: would the student be required to use a computerized planning system (Profiles, eMoney, MoneyTree, etc.)? I do see where assessing and evaluating the plan could be a source of contention. Who would be the evaluators?

I would be happy to assist in this project, if you need volunteers.

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WILLIAM A. SIMS, CFP®

Date: August 17, 2009

Inclusion of a Financial Plan Development Course requirement for CFP® certification is absolutely essential, and I believe, the missing element from the current course of study. The final course requirement for my MBA, and for most MBA programs across the country, is Strategy & Policy. Utilizing comprehensive case method, Strategy & Policy ties together all elements from core requirements in a very real world and applicable approach. In fact, you may consider calling the course Financial Plan Strategy & Development. Good work.

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JOHN A. SIPPLE, CFP®

Date: August 5, 2009

Just wanted to pass on that I would be in favor of adding the proposed Financial Plan Development Course requirement.

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TIM SOMMERS, CFP®

Date: August 4, 2009

Part of me feels that any requirement which increases the professional abilities of CFPs is a good thing, however, in this case the addition of this requirement strikes me a superfluous. Interested parties who undertake the educational requirements for CFP already cover the topic well from an informational point of view.

In reality, the financial plans developed by CFPs are already highly standardized and stylistically similar. Guidelines in this area are what is needed, not a three credit course on formats. Most plans cover almost identical points regardless of where you obtain them. So, I am against the new requirement.

I would fully support requirements laid out by the Board for the standardization of financial plans similar to the "plan of care" standards in medicine.

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JIM STARTZELL

Date: August 7, 2009

I think any financial plan should have a checklist at the end for the planner to go back and ask these questions (for example):

  • Does the plan meet the risk comfort level of the clients?
  • Is it diversified properly?
  • Does the plan match the client goals?
  • Was their age taken into consideration?
  • Does the plan consider transfer of assets upon death?
  • Were taxes minimized (income and estate)?
  • Could all of the investment objectives be met with lower cost to client?
  • Is there enough liquidity available?
  • Will income needs be planned for?

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PHILIP J. STATZ, CFP®, RFC

Date: August 3, 2009

First, I am amazed that the board thinks as a practicing business owner we might have time to spend just reviewing some course - it really shocks me.

Further, I have no idea what or who precipitates the idea of adding another hurdle to becoming a CFP as a good thing. Does that speak to the current system being broken? Lately it seems like these ideas start somehere and get all the way to fruition without any other feedback until you are about ready to launch, sort of seeing if your wife to be is interested in marrying you when you are at the alter.

Thus aside from a time factor itself, it again is very difficult to assess the validity of this new agendas purpose and if amongst all other options this is somehow the best.

I wonder if this somehow even lends itself to the fiducicary elements we all have been painstakenly discussing in the past year - seems a bit of a departure.

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RICHARD G STEINBRUCK, CFP®

Date: August 20, 2009

My initial reaction is that it is a bad idea. We need a better system AFTER a person is certified, not adding requirements to become a CFP®. I have a MS Ed degree and this financial plan development course sounds like educators thinking they can get better teachers if they teach how to do better lesson plans.

In the Tampa chapter, a couple of times each year there is a CE class that offers a case analysis, usually for 2 or 3 hours, in which the participants work together to analyze and put together a financial plan. It is an enjoyable and meaningful class because the diverse opinions and approaches of practicing planners are heard and evaluated.

If indeed the CFP® certification curriculum is deficient and needs a specific "How To Write A Plan" component, I would rather see it broken up and included in each of the existing courses and then built upon until the course work is completed. I think adding a separate 3 hour course is excessive, if for no other reason but that it is an academic exercise before the person is in the real world. People entering our profession need a practical, real plan developed with real situations, not one that might have been good three years ago before it got into a textbook.

A GOOD IDEA would be a mentoring program that would work with either students or new certificants. New certificants would earn CE credits in the first two years of their practice that focus on writing a financial plan with the assistance of an experienced CFP®. The medical profession has an internship program. Teachers have to get 'student teaching' credit. Pastors have 'vicarage.' A properly designed mentoring program would give CE credits to the new certificant and either CE credits or other recognition for the mentor.

PS. How many of those favoring the the addition of the course would be happy if they learned that because they were in favor of it, they would be required to also take the course for certificant renewal? I certainly would not want a 3-hour college course added to my renewal requirements. However, I would enjoy plan development CE courses where I could have discourse with other CFP®s, if those courses were applied against my renewal requirements.

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DAVID G. STREGE, CFP®, CFA®

Date: August 3, 2009

I agree with adopting the proposed Financial Plan Development course as a prerequisite for all individuals wishing to take the certification exam effective 1-1-2012. This added educational element will serve to better ensure candidates are able to meld the broad range of topics learned into an accurate and clearly presented (written and verbal) Financial Plan. The ability to effectively apply learned concepts is every bit as important as textbook knowledge and is integral to the advisor/client relationship. This additional requirement will help new CFP® certificants to be better prepared to actually prepare and present financial plans to the public. As long as the registered programs can handle this additional requirement it is a great idea.

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PAUL J. SULLIVAN, CFP®

Date: August 4, 2009

Absolutely. This is a major part of our work and the value we offer to clients. I wish my education required it.

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JERRY D. SUTHERLAND

Date: August 7, 2009

I believe to be a CFP one should have a Bachelors Degree, with at least 6 hours in Accounting, 12 hours in Economics, 6 hours in Finance, 6 hours in Math, 3 hours in Taxes and 3 hour in Statistics.

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JOHN L. TALLENT

Date: August 4, 2009

I am in favor of having the course as a requirement. We had such a course as our capstone at Rice University’s CFP program. Many of my classmates found it enormously beneficial in having to integrate all of the areas of study we had endured into a single document. For Rice, as I recall, it was a requirement to be able to “pass” the entire program and proceed to pursue the CFP designation.

As to the time requirement discussed in your posting, I am unclear where the 45 hours would be spent. I can say I spent more than 45 hours in the preparation of my plan for final submission. We received our case early in the CFP program. I referred to it often as I went through estate, insurance, etc. Hope this helps.

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JOHN E. TATTERSALL, CFP®

Date: August 10, 2009

I agree. They should take a course.

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DON TAYLOR, PHD, CFA, CFP®, ChFC, CASL

Date: August 25, 2009

My initial reaction in hearing of the proposed change in the curriculum was that the Education Committee was recommending that the education providers take on a responsibility that would be more properly vetted by the people attesting to the candidate’s professional experience. I’ve reconsidered that position because it truly is difficult to justify that the development of a comprehensive plan not be one of the learning outcomes in the education component. My modified stance is one where the Certified Financial Planner Board of Standards, Inc. allows a measure of flexibility in how the education providers accomplish this goal and not require a separate 45 contact hour course to be taken by all candidates for the CFP® certificate.

While I support the idea that a candidate for the CFP® certificate complete a comprehensive financial plan, and be assessed on the oral and written delivery of that plan as part of the education component required of all certificants; I think that the proposal goes too far in mandating how the requirement must be met by means of a 45 contact hour course. There’s just too much variability in course delivery between degree and certificate programs, online and classroom delivery, to make one size fit all for this requirement. Letting the education programs have a measure of flexibility in how they would achieve the new requirement would be a welcome change to the proposal.

In an ideal curriculum design the other five courses would not be taught in silos and the candidate would learn how the topic areas interrelate as they take the courses covering the 89 topics. That would lessen the need for a full semester course in development of the financial plan.

I’m also concerned that the requirement to build a comprehensive plan minimizes the role that tax professionals and attorneys would play when a certificant is out in the real world writing plans for clients. This interplay amongst professional also makes it difficult to properly teach a Financial Plan Development Course, and evaluating the learning outcome, short of team teaching the material and having the student’s plan evaluated by a group of professionals. Should a coach, or communications professor evaluate the oral component, while the written is evaluated by professionals in the different disciplines?

Professional challenges should also be considered as a way for a candidate to be assessed for this education requirement. Not a free pass, like some professions now enjoy with the other education components, but a professional assessment of an example, or a portfolio, of the candidate’s professional work.

As with most things in life, the devil is in the details. There’s not enough detail, or flexibility in delivery of the requirement, for me to look favorably on the proposal as written.

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LESLI TERRELL-PAYNE, M.ED., DIRECTOR OF THE CFP BOARD-REGISTERED PROGRAM & ASSISTANT DIRECTOR OF CERTIFICATE PROGRAMS, UNIVERSITY OF GEORGIA

Date: September 4, 2009

As I mentioned at the conference recently, I do not feel that the Financial Planning Development course is appropriate at the program level. While I can certainly appreciate the pedagogy behind it, I believe it would be best handled by the Board—after successful completion of the Exam. Working with students first-hand, I can assure you that those that complete an educational program, like ours, then sit for the Exam and do not pass, are extremely upset. I often have to do “damage-control” in order to prevent the possibility of them not recommending our program to colleagues and/or friends—even though they consistently tell me that it’s the Exam, not us. At any rate, can you imagine if they’re made to complete this lengthy additional requirement only to not pass the Exam? It will just double their exasperation!

As for the ability for programs to deliver this requirement, it will add significantly to the cost of a program, not to mention drastically change the time frame on which the curriculum is built. Students already go through 13 months of classes (for our program anyway) plus a capstone plus a live review, which typically includes up to 200 hours worth of pre- and post-study….and adding an additional 45-hour requirement is simply too much to absorb for these busy professionals, most of whom have families with young children.

I would seriously recommend that the Board not adopt this new requirement for non-credit certificate programs such as ours. Thank you for your time.

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J. HOLLAND TOLES, PH.D., CFA, TEXAS STATE UNIVERSITY - SAN MARCOS

Date: August 25, 2009

On a side note, just let you know, we'll be sending comments soon on the new 3 hour course requirement but I'll go ahead and give you some now. We had a finance faculty meeting today and the general consensus was that (1) the new requirement would likely cause us to end our existing registered program with the Spring semester of 2011 due to our likely lack of ability or willingness to devote more resources or space in our curriculum (which has recently been reduced due to other university constraints) to comply with the new requirement. (2) If we tried to implement the new requirement it would pose a sequencing problem. Our students take the current 5 course sequence during their final two semesters (after satisfying rather substantial prerequisites). To have a true capstone integrative course it would require that the students have taken the bulk of the courses prior to their last semester which would be difficult for us to arrange given other constraints in our curriculum. (3) In any case if we are to comply we would request more time to plan the necessary changes to our curriculum. One simple constraint is the need for any new courses (particularly if they require new resources) to be approved by the Texas Higher Education Coordinating Board. The time therefore for a new course proposal to become actually implemented takes about two years from initiation (Dept, College, University, State Board). (4) Further we would need to plan for the possibility of needing to hire additional faculty--a prospect that does not seem to receive support given that fewer than 20 students are completing the program each year (and as far as we know only about 2 of our students per year actually sit for the examination). In addition, there is duplication in our area due to the new program offered through UT continuing ed, and the program offered at UTSA and the online program offered through Rice continuing ed. (6)This new requirement being still in the discussion stage with an expected implementation in Jan. 2012 seems very unreasonable to us from the AACSB business school perspective. Programs offered through divisions of continuing ed do not face the same constraints that we do and therefore will be able to comply more readily. The courses do not have be approved by the State coordinating board and hiring adjuncts doesn't get them in trouble with AACSB. The full-fledged degree programs (and most certificate programs) probably already offer a "capstone" course so implementation will be a breeze. I suspect you'll find some resistance from some of the other business schools who host 15 hour programs. (7) There is a view among our faculty (most of whom have no interest in teaching personal financial planning) that CFP Board, through its changing topic list, exerts too much unilateral control over our curriculum as it is, and this recent unilateral requirement for which we are not sure we have ever received "official" notification (other than links buried inside emails) that is to be implemented as of Jan. 2010 only adds insult upon injury in that regard.

It is my hope the CFP Board can find a way to implement this new requirement without imposing it upon the existing education programs. Perhaps it can be an additional requirement that could be either fulfilled by a registered program, or by a certficate earned from a licensed CE provider who provides the specialized comprehensive financial plan requirement. Therefore a separate requirement (a 5th E, so to speak) that can be fulfilled in a number of ways. If so we would likely continue to operate our program in its existing configuration.

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JAMES A TOLLEFSON, CFP®, FICF

Date: September 4, 2009

I believe the current method of testing is more than adequate to test the knowledge and implementation skills of a candidate.

The addition of a new requirement, if that is what is proposed, sounds to be costly and time consuming. Consider, that given the same set of real world facts, there is a likelihood of more than one appropriate plan. It sounds as if subjectivity could triumph over objectivity.

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CHRISTIAN TREITLER

Date: August 3, 2009

I think that developing a comprehensive financial plan is at the core of the services a financial planner performs for a client. Therefore, it makes a lot of sense that a Financial Plan Development Course becomes part of the curriculum.

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DARLENE TUCKER, CFP®, FICF

Date: August 3, 2009

I would be in support of the new requirement of the plan development education.

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MICHAEL SAVAS TUMER, CFP®

Date: August 3, 2009

I completely agree on such a requirement. One semester/quarter or 3 credit hours is a reasonable time frame to develop some financial planning skills especially if the time is utilized to simulate real-life situations.

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TANYA TUSSING

Date: August 4, 2009

I believe the Financial Plan Development Course has originally part of the program. However, whether this course is very similar to the original course content or not, I think it is a good idea to add this requirement for new CFP candidates.

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ROB TYPER, CFP®

Date: August 4, 2009

Including this course is a wonderful and necessary addition. I feel my input could be valuable considering that I have done over twenty financial plans. In my view, the key is to make the plan(s) as realistic as possible, and it is better to have candidates complete several plans as opposed to just one. My thoughts:

  1. Will this course be made available to existing CFP®’s?
  2. Candidates should do two plans:
    3. a) One for a younger couple; with children who will need to have college funded; need a budget; need insurance analysis; need disability insurance; basic estate planning; portfolio designed for growth; one parent recently changed jobs, perhaps the other parent is likely to lose theirs; and they have a lot of credit card debt and/or home equity loan debt.
    b) The other is a couple either close to retirement, i.e. ten years or less; need long term care insurance; require more estate planning; in need a of full retirement income plan, i.e. they qualify for Social Security but do not have defined benefit plans; lastly, an approach to help clients with the mental transition to retirement e.g. how are they going to fill their time?
  3. Provide resources for financial planning software.

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CASEY VAN ZUTPHEN, CFP®

Date: August 3, 2009

I wish I had some experience creating and presenting a financial plan before joining a planning firm. The FPA residency program should also be required for CFP designation.

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MALAY VASAVDA, CFP®, MBA

Date: August 7, 2009

I wanted to comment on the proposed requirement to include putting together a financial plan in order to obtain CFP certification. I believe this is a very valuable requirement and it will do nothing but raise the standard of a CFP to that which is expected by consumers. Consumers look at the “Certified FINANCIAL PLANNER” designation and assume that the advisor has extensive knowledge of putting together a FINANCIAL PLAN. Too often, I have seen advisors who have CFPs focus too much on products and sales and the “plan” is simply an afterthought meant to enhance sales of the product they already have in mind. I believe if this is included in the education as a requirement, it will open many future advisors’ minds to truly understand the importance of putting together a financial plan and how it is something that will benefit both advisors and clients in the long run. If someone is never required to put together a true comprehensive financial plan, he/she will not have much incentive to learn on their own if planning is considered an afterthought in their practice. NAPFA requires its applicants to complete a comprehensive plan and submit it to other advisors for review before gaining admission. This is a vital step in our education and will make us true “PLANNERS”.

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SCOTT VINCINI

Date: August 6, 2009

I am supportive of the new education requirement. I think we should continue to have a rigorous standard that requires professionalism in dealing with the client. Despite the fiduciary nature of our profession, I am sure that some certificants do not practice all they have learned. Taking them through a process that emphasizes the due diligence needed for a client engagement would help support the fiduciary standard.

My two cents on another topic: The two year ethics requirement should be changed. I very much support an ethic component, but I would like to see something above a repeat of the same material every two years. I would recommend an online course that is similar to what registered reps must do that can support the standards and practices but also emphasize ethics based on current events such as the Madoff controversy or money laundering. I believe it would be more useful if we had a course that integrated ethics with the current issues of the day.

I think the Board is doing a tremendous job.

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EDDIE E. VINEYARD, CLU, ChFC

Date: August 5, 2009

It sounds like an outstanding idea. How would this affect people who are qualified to take the exam on a challenge basis? I also think making the course available for current certificate holders to take for CE credits would be a good idea.

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MARY VOLL

Date: October 1, 2009

I completed the certificate program for financial planning at UT Austin in September 2008. The program included a “Capstone” final course much like what CFP Board is contemplating. I believe that it was an important element in the program and should be included in the educational course requirements for CFP® candidacy.

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STEVE WAAS, CFP®

Date: August 5, 2009

As I worked my way through the CFP program I was quite surprised to find that, while the education and especially the examination requirements were thorough, there was no real requirement that I prepare a comprehensive financial plan. I find this oversight very difficult to justify. Explaining this to non-CFP’s is particularly challenging.

Correcting a somewhat embarrassing oversight in these requirements would be one advantage of implementing the proposal.

However, I think that a much more important advantage is that it would stimulate discussion and research on this important part of the Planner’s job. This would accelerate the evolution of generally accepted standards and best practices – which are critical elements of all professions.

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THOMAS E. WAGNER, CFP®

Date: August 3, 2009

I am writing you in strong support of a Financial Planning cource requirement as outlined in your recent public notice.

I believe the adoption of a formal class requirement in this area would benefit the development of the financial planning profession and the CFP mark.

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OLIVIA XIAOYU WANG, PH.D., , CFP®

Date: August 6, 2009

This is in response to your request for comments on proposed financial plan development course requirement. After working as a wealth management advisor and director of estate planning for Fidelity Investment for a combined total of over 11 years and then changed career to be a development officer with closely related skills, I personally do see the necessity of such a course for CFP practitioners.

However it is the timing of such a course that I have some reservations about.

For people who have not worked in the capacity as a wealth management professional, but simply finished the other required courses, the course may not offer as much value without the real life experience. Even with my existing experience at the time (2-3 years), I was more or less delivering plans on paper, nicely presented and well package. Yes, they looked nice, as my professors told me. It did not feel real to me.

It was only about 2 more years after I have obtained CFP designation and had more than 100 plans completed that I started to feel confident in my capability to address real life issues and problems, and implement and monitor the plans I made. And it is only then I felt the need to (re)learn the craft of making and delivering a plan.

Again in short, I do feel the necessity for this course. I question the timing slightly. But would like to suggest having it combined with a intership program where students and new practitioners build solid ground to help people with real life needs.

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MIKE WASSERMAN

Date: August 3, 2009

I would imagine I've had my CFP license longer than most anyone still active -- as it's been more than 25 years. I'm #003939. I am also the Mayor of my town and a Registered Tax Preparer.

If you feel it appropriate to add an additional course to attain CFP certification, I'm fine with that, as any individual considering certification would know the rules ahead of time.

The reason I'm writing you is to make sure you are not considering adding any more requirements (courses, continuing ed, etc.) to maintain one's license.

That's all I had to say, thanks for listening.

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JAMES F. WATKINS, JR., CFP®

Date: August 3, 2009

It certainly seems good to have someone with a CFP able to prepare a comprehensive financial plan. I don’t know that the 3 credit hours or 45 equivalent is a good metric to measure learning. I assume a course would be added to the College of Financial Planning Correspondence Program. Is it projected that this addition will assist a greater number of test applicants pass?

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LARRY WEBER, WEALTH MANAGEMENT ADVISOR, CFP®

Date: August 4, 2009

Amendment looks like overkill. I would vote against it. It is far more important for CFP®’s to understand the implications of the issues at hand rather than designing. Unless it is someone with the competence level of a Ken Zahn, you probably do not want them creating a plan.

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LARRY P. WEATHERFORD, CFP®, CLU, CASL

Date: August 3, 2009

This sounds like a good idea to me

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THOMAS E. WEISENFELS, CFP®, CRPC®, CFM, CSNA

Date: August 4, 2009

I support the addition of the financial plan based module and application for CFP® certification by the Board. This is why this designation is actually sought, though I see quite a number of financial industry folks purporting that they support financial planning; yet, have never done a financial plan nor know how to develop one or implement it. I have seen this case especially with the insurance industry that proposes ridiculous amounts of life insurance or insurance as investment/savings vehicle and using “planning” to support this. People that earn the CFP® mark should be able to do basic planning, know the procedure, and be able to implement it. I support the proposal.

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JOHN H. WELLFARE, CFP®

Date: August 3, 2009

Very briefly, I feel this would be an excellent addition to the curriculum and to the overall professional standards of preparation.

I would like to comment, for what it is worth, that when I took the Practicum in Personal Financial Planning through the University of California Extension in 2003, we were required to create a complete financial plan for real individuals, addressing all the areas included in the Practice Standards. It was a challenging but highly valuable part of the entire course.

I had always assumed having such a requirement in a personal financial planning curriculum was standard. Apparently I was incorrect.

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JOHN WHEELER, CPA, CFP®, MBA

Date: August 4, 2009

I agree with the new curriculum requirement. The ability to verbalize concepts and recommendations to clients is at least as important as having the knowledge itself.

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SUSAN D. WIER

Date: August 4, 2009

I agree that the proposed course would be a good addition to the course work. That’s where the knowledge is applied.

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TYE WILLIAMS

Date: August 3, 2009

I am for it.

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TOBIN WILLS

Date: August 3, 2009

I agree that adding a Financial Plan Development Course is a good idea.

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WALT WOERHEIDE, Ph.D., CFP®, VP OF ACACEMICS & DEAN, FRANK ENGLE CHAIR OF ECONOMIC SECURITY, THE AMERICAN COLLEGE

Date: October 1, 2009

Comments on Live Presentations

Many of the people posting comments herein are simply indicating the proposal to require an oral and written presentation of a comprehensive case that is also part of a comprehensive case course is a good idea. Indeed, it is awkward to argue against this proposal as such an argument could easily be interpreted as being against the belief that capable financial planners should have this skill. Nonetheless, there are several good and valid reasons to object to this proposal. There are actually multiple components to the proposal: one is to have a comprehensive case course in all CFP educational programs, a second is to have a written and oral presentation as part of this case, a third is to require that students successfully complete this course before sitting for the exam. I am neutral on the first component, but strongly oppose the second and third.

First, this proposal will clearly have no effect on some of the people who will be sitting for the CFP exam. This is because they are obtaining their education either through a degree program which has such a course and requirement, or they may be enrolled in a certificate program which requires a capstone course. People challenging the exam would also apparently be exempted.

Second, there are many wonderful ideas that can be suggested as ways to improve the quality of financial planners. I would like to suggest that financial planners who have a J.D., are an Enrolled Agent, and have an MBA with a concentration in finance, along with a CFP® designation would be much better qualified than those having just the designation. However, I clearly do not offer this idea as a proposed requirement because it should be apparent to all that there would be few, if any, people obtaining the CFP® designation if such requirements were added. Simply stated, the cost of such requirements would far exceed the benefits. But the point is this, as we consider each idea to improve the quality of people obtaining their CFP® designations, we need to be mindful of what are the costs and what are the benefits. Some of the worst rules are rules that carry significant costs and do NOT address any problem that actually exists. In this particular case, I should note that there is no study or other comprehensive analysis that indicates that the lack of an oral and written presentation requirement is resulting in fewer people being adequately qualified to be financial planners. There is only anecdotal evidence offered by a few practitioners who say, “gee, when I hire a new planner, I would like it if they already had strong presentation skills and were fully experienced in developing a solution to a comprehensive case.” Such anecdotal evidence does not mean that the vast majority of planners who are earning the CFP® designation are not fully capable under the current rules of doing a good job in preparing a comprehensive solution to a complex case and presenting that case. If such a study were undertaken using a sound research methodology and the results indicated that a significant number of CFP® candidates lacked this skill and that a comprehensive case course with required presentations would solve this problem, then there would be a good argument with proceeding to add this requirement. Having a bunch of people go to a website to say, “This sounds like a good idea,” is not adequate documentation. Remember, what this proposal will do, as several of the people posting documentation have noted, is add to the cost of obtaining the CFP® designation in terms of the time, effort, and dollar expense to acquire the designation. So we know there are costs to this proposal, but do we have the facts to prove that there are benefits that will outweigh these costs?

As a supplement to this point, CFP Board takes great pride in noting that this designation is NOCA-accredited. This accreditation rests, in part, on the fact that every five years there is a job analysis, and the education and examination are based on the Study Points that are derived in this job analysis. If the requirement for a paper and oral presentation are a necessary component to being a CFP® certificant, then I have to ask why this has not been a requirement going back to when the designation was first established? The fact that this requirement does not originate with the job analysis certainly calls into question whether or not it is truly mandatory to establishing the qualifications of a capable financial planner.

I would also challenge the proposal on the related grounds that the vast majority of people sitting for the CFP examination are doing so to improve their skills and qualifications within their CURRENT job. I suspect that it is primarily students coming out of degree programs who lack the experience in preparing and presenting comprehensive cases, and it is these students who are already being subjected to this requirement. If CFP Board were to research whether students taking the exam were in fact looking to enter the field of financial planning or were already established in the field of financial planning, and the results indicated a significant number were looking to enter the field and had no prior experience, then there would be a plausible argument for introducing this requirement.

I should note that no one today actually develops comprehensive financial plans from scratch. Everyone uses software. To require a student to solve a comprehensive case in a course would likely mean that each program will have to acquire appropriate software and provide it to students. Now, there are three programs that collectively educate about 50 percent of the people sitting for the exam. If these three providers all adopt the same software, then not only are they in effect endorsing this product, but after a period of time, there is a good chance this one product would become the dominant software for the industry. In addition, it is not clear to me that if a student learns to prepare a comprehensive case with one software product, and then goes to work in a firm that uses a completely different software package, that said student will not in fact need to be retrained.

As an academic administrator who has managed both online programs and programs at traditional universities, I can assure you that mandating a syllabus and pedagogy will not guarantee that all students receive a similar experience. Some teachers grade with a light hand and find all presentations acceptable, and others grade with heavy hands, even flunking some students. With coursework in the CFP programs, the quality of the product can ultimately be measured by success on the CFP examination. I do appreciate the fact that the Education requirement and the Examination requirement are two different components of the 4 E’s. However, my point is only that the Examination requirement serves as a validation of the Education requirement. Unless there is some way of validating the quality of the comprehensive case course in each program, then the lack of uniformity in quality will certainly defeat the objective of this requirement.

If CFP Board is adamant in pursuing the presentation requirement, then there is certainly one way to assure uniformity in the evaluation of the ability to provide written and oral presentations of comprehensive cases, and that would be for CFP Board itself to take responsibility for the evaluation of the paper and the presentation. Thus, CFP Board would control evaluation of both the examination component of the process, and the case component.

A large percentage of people taking the CFP exam do so on a distance basis. Grading a paper in a distance delivered course is not a problem, but grading an oral presentation certainly is. Few students are computer geeks able to deliver an oral presentation over the Internet. Asking a student to go to the campus of a distance program is unreasonable. This is not a simple problem to solve. Some of the CFP educational providers run huge programs. Several providers could have as many as 1,000 to 1,500 students taking this course each year. Whether such a program has one person grading 1,500 presentations or 300 people each grading 5 presentations, the mechanics of the process are problematical at best. At the Program Director’s conference, someone suggested getting local practitioners to grade these presentations. Hiring and overseeing 300 instructors for one course would itself be a full-time job. There would be truly uneven quality of evaluation, and the first time such an instructor failed to grade a presentation or paper in a timely and professional manner, the program coordinator would have a very unhappy customer, with good reason. My point is, this proposal for a paper and oral presentation are easily done in live programs, and clearly penalize distance programs. If the goal of CFP Board is to put distance programs at a competitive disadvantage, then this proposal is one step in that direction.

There is much to commend the position that it makes more sense to have the presentation requirement be part of the experience. That is, not only must a CFP® candidate identify his or her experience requirement, but he or she must also certify that this experience includes both a written and oral presentation of a comprehensive case.

Finally, I would like to remind everyone that there are degree programs and certificate programs. Several years ago, CFP Board co-sponsored with the Academy of Financial Services a task force to create proposed syllabi for a degree program. Although the two organizations had hoped to ask the same task force to create proposed syllabi for certificate programs, that never materialized. Nonetheless, it was clear in everyone’s thinking that the requirements for a certificate program would be LESS than those for a degree program. I suspect that the requirement for a comprehensive case presentation would not have been included in the recommendations for a certificate program. Simply put, I would expect the graduates of a degree program to be much better qualified and trained for financial planning than the graduates of a certificate program. So the fundament question is, what are the appropriate differences in these two types of programs. I believe that one such difference should be the requirement of a written and oral presentation of a comprehensive case.

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EDWARD R. WOLFE, PROFESSOR OF FINANCE, WESTERN KENTUCKY UNIVERSITY

Date: October 1, 2009

As a long time former director of one of the oldest registered financial planning programs in the country, I would like to comment on the proposed new case course.

My concern is that you not require this of students who are simply enrolled in our programs. As you surely know, most students never take the exam. This is something, it seems to me, that the Board ought to study and try to find out why this is the case. Even certificate programs have this experience, and one would think that folks enrolled in a certificate program are serious about wanting to complete the whole process. Alas, that's a topic for another day.

In terms of our program, in any given year we probably graduate 25-30 students who are eligible to sit for the exam. Most do not take the exam, and therein lies the rub. This course that you're proposing is very labor intensive. It simply makes more sense to make it a requirement AFTER someone passes the exam. In that situation, we could do it as an independent study and be much more intensive in our instruction. In Arlington, this suggestion was made and supported by many of the participants.

In talking to one of the committee members (actually the chair of the committee), I was not encouraged by his reaction to my suggesting the above. I distinctly got the impression that the fix was in, and you are going to simply require that this course be added to all the programs.

I hope that I am wrong about that.

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WILL WOODARD, CFP®

Date: August 5, 2009

I am against the proposed financial plan requirement for CFP certification.

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KATE YOHO

Date: August 6, 2009

As every financial planning situation is different, I do not find that your proposal to add this requirement is necessary nor would it help aspiring financial planners better or more comprehensively serve their clients.

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GARY L. ZAUGG, CFP®, ChFC®, CASL®, CDFA

Date: August 4, 2009

GREAT IDEA!

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