Certified Financial Planner Board of Standards, Inc.
 
 
 
CERTIFIED FINANCIAL PLANNER™ Professional
 

Comments on Proposed Amendments to CFP Board's Experience Requirement

On April 5, 2012, CFP Board announced that its Board of Directors approved amendments to the Experience requirement for CFP® certification. The amendments, effective September 1, 2012, were adopted following thoughtful consideration of comments received during a 30-day public comment period. Read more about the amendments to the Experience requirement >

The individuals and organizations listed below responded to CFP Board’s request for comments by providing comments regarding the proposal between August 18 and September 17, 2011. The content of each comment is available for review below. CFP Board accepts no responsibility for the content of the comments.


Comments

Updated September 22, 2011


LAURIE ADAMS, CFP®, CLU, LUTCF

Date: August 18, 2011

Subject: Proposed Experience Revision

I respectfully disagree with the recommendation to split the experience requirement and shorten it to two years for individuals working directly with clients. If anything, we should lengthen it at the time we are executing a public awareness campaign about the value of our designees.

After 30 years of providing advice to clients and 20 concurrent years as a continuing education provider I am convinced that the complexity of financial planning services is not fully understood for several years. There is so much to learn beyond the information needed to pass the exams. (Let's not kid ourselves about the quality of learning that goes into that for many individuals; we know there are companies that make their living off of 'teaching to the test' so it is imperative that planners have sufficient opportunity to learn about context in the field.) And most of us know that some of our most valuable lessons came through mistakes – it is better that those occur before they are associated with the CFP® profession.

Yours truly,

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JOSPEH ALFONSO, CFP®, ChFC, EA, LTC

Date: August 18, 2011

Subject: Comment Regarding CFP Board Proposed Changes to Experience Requirement for Obtaining CFP® Certification

I endorse the Board's proposal to differentiate the number of years required to complete the experience requirement through personal delivery of financial planning services to clients (two years) from the years required to complete the experience requirement through supervision, direct support or teaching of financial planning services to clients (three years).

In conjunction with this change, however, I would recommend that the Board limit the length of experience credit it grants for participating in various educational programs (FPA Residency, practicum, internships) to 6 months in order to ensure candidates obtain a minimum amount of real-world experience in professional client engagements before becoming certificants. While I believe participating in clinical educational programs is valuable in preparing candidates to deliver financial planning services to clients, I believe there is no substitute for the experience gained in actual planning engagements where services are being delivered to a consumer for a fee.

Thank you for the opportunity to comment on this issue.

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MARK J. ALAIMO, CPA/PFS, CFP®

Date: September 2, 2011

Subject: Proposed Revisions to CFP Board's Experience Requirement

Thank you for the opportunity to comment on this proposed change. I strongly disagree with the proposed changes to the experience requirements to become a CFP® practitioner. I feel they are a dilution of the value of the CFP® mark and give me the impression the board is more concerned with growing the ranks of CFP® professionals at the expense of ensure those carrying the mark are qualified and experienced professionals worthy of the public's trust.

The CFP Board has spend significant time in presenting the mark as "the industry standard," and these changes move us closer to just another designation in the "alphabet soup" of financial designations. Further, the CFP Board's public awareness campaign is placing a strong emphasis on the experience of CFP® professionals…the board's actions speak louder than words!

Given the ever-increasing complexity of our industry, if anything I feel the experience requirements should be increased, not decreased. I strongly oppose these proposed changes, and urge the board to reconsider how these changes affect the current holders of the mark, and more so, how having less experienced individuals with the mark will affect the quality of financial planning services provided to the public.

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SANDY ANDERSON, CPA, CFP®

Date: September 7, 2011

I have reviewed the proposed revisions to the Experience requirement and agree with the changes.

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SHON P. ANDERSON, CFP®, CRPC®

Date: August 19, 2011

Subject: Experience Comment

I agree with all of the proposed changes, especially the internship/ residency affirmation…

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DAVID M. ARTHUR, CFP®

Date: August 19, 2011

Subject: CFP Board 3 Years Experience Proposal

You scare me with the fact that this proposal could even warrant any consideration. I usually don't get involved with these kind of discussions; however, a proposal of requiring 3 years of experience in the financial industry before one can get the CFP® designation is putting the cart before the horse. Would you allow a doctor to operate on you before he becomes certified? Would you hire an attorney before he passed the BAR? Why don't we send men into space as astronauts before training?

If any change is made, the CFP® designation should be required before one sets for the Securities series 6, 7, or Insurance exam. Of course, this is not reasonable in the real world either.

I've said enough; I hope my point is made.

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STEPHEN C. BAIRD, CFP®, CIMA®

Date: August 29, 2011

Subject: Comments on Work Experience

The general view outlined in the proposed revisions is positive – clarifying teaching versus personal delivery, tightening up the timeframes, etc. However I would recommend that the minimum experience in years remain at 3 years – with a maximum of 2 years from teaching. It is my opinion that 2 years is simply too short for someone to gain the necessary skills and experience commensurate with a certification.

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SHAWN BALLINGER, CFP®

Date: August 19, 2011

Subject: Experience Requirement Revisions

I briefly looked at the proposed changes and feel they are an improvement. I'm especially in favor of the tightening of the Qualifying Window from 10 to 5 years, the reduction of two years of Personal Delivery experience from three, and the elimination of the Current Experience.

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JAMES A. BARNASH, CFP®

Date: August 29, 2011

Subject: Amendment of the Experience Requirements for Certification.

I have reviewed the recommended amendments to the experience requirement for certification and find them to be reasonable and appropriate for the current marketplace. I find that the amendments should not put any unreasonable burden on an applicant and seem quite reasonable.

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BRAD BARTICK, CFP®

Date: August 18, 2011

Seems fair to me

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MARGARET BARTELT

Date: August 24, 2011

Subject: My Thoughts on the Proposed Changes to CFP® Experience Requirements

I just read the CFP Board of Standard's proposal to change the experience requirements. For the most part, I either agree or am indifferent to the proposed changes. The one I don't like is the narrowing of the window to get this experience to only 5 years around a passing CFP® exam.

Like many others respondents, I'm sure my comments are motivated largely by my own circumstances, but I do indeed think my circumstances could be shared by a good many other people. I made a career change into financial planning in my young 30s (just a few years ago) and at the same time, as many women of that age do, I started a family. So, I have been working part time (outside of maternity leave) since then, in an effort to balance motherhood and work. Getting 3 years of FT work equivalent into the next 5 years is doable, but it is going to be a stretch, as I plan to expand my family, too, requiring more time completely out of the work force, and then hopefully a continuation of a part-time work schedule.

I realize that working part-time is a choice I've made to honor both my family and my professional aspirations, but I feel as if my learning is no less for the extended time it's going to require to satisfy the experience requirement. Narrowing the time frame in which to get that experience would make things more difficult for the likes of me, who are getting continuous but not full-time experience because of a desire to balance family and work.

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MICAHEL BECK, CIPM, CFP®

Date: August 19, 2011

Subject: Proposed Amendments to Experience Requirement

Thanks for allowing me to comment on the proposed amendments to the experience requirement for the CFP® designation.

I disagree with the requirement for a verifier of employment and experience to be a CFP® professional. This will eliminate some possible candidates because they work for a smaller family office and there currently is not a CFP® professional on staff. I believe that a manager or director of the firm without the CFP® credential be allowed to verify the employment of the candidate and the participation in the financial planning process.

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A.T. "AL" BENELLI, CFP®

Date: August 18, 2011

Subject: Comment on Experience Requirement.

It would appear that this is a "dilution" of the experience requirement… coming at a time when the public appears to be most in need of trusted competency.

The new CFP Board advertising campaign seems to place great emphasis on the qualifications of a CFP® certificant. I feel this proposed change to the prerequisites for that most honored designation is an action in the opposite direction. I would respectfully remind all that "Actions speak louder than words".

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A. RAYMOND BENTON, CFP®, CRPC®, EA

Date: September 17, 2011

Subject: Proposed Amendments to Experience Requirements

I have reviewed the proposed amendments to the experience requirement. I congratulate the board on its efforts in this matter and am in agreement with the changes.

Good job!

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BRUCE BERNO, CFP®

Date: August 19, 2011

Subject: CFP® Certification Experience Requirements

I think the proposed changes to the Experience Requirements are sound and should be approved.

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JAKE BOND, CFP®

Date: August 28, 2011

Subject: Proposed Revisions to Experience Requirements

I review the proposed revisions to work experience and would like to suggest that you maintain a 3 year requirement for work experience for those providing personal delivery of financial planning services, as opposed to 2 years, as suggested in the most recent proposal.

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STEVE BRANTON, CFP®

Date: August 22, 2011

Subject: Reduction in Experience Requirement

I strongly disagree in the proposed revision to reduce the experience requirement.

Having recently completed the experience requirement in 2009 and now fully designated as a CFP® certificant, I am concerned about the dilution of the value of the CFP® credential. In the huge array of advisors available to any prospective investor or client, the CFP® credential serves as a powerful tool to filter out many other professionals, who are not ethically bound to put the needs of the client first.

Secondly, the reality is two years is a very short period of time in my experience, for a person, however resourceful or talented, to achieve the mastery necessary to truly hold themselves out as a professional financial planner. Having been in a full comprehensive planning role for nearly four years, I did not feel the competence or confidence to personally handle an entire plan until well into my third year of planning. Two years seems like the minimum threshold and frankly, as CFP® certificants we are not aiming for the minimum level of anything.

Finally, by continuing to hold the highest standards and requirements to become a CFP® certificant, we do countless benefit to our own profession. Folks know it is hard to become a CFP® certificant and therefore they value it. This instills a sense of confidence in us as planners and in clients who are beginning to value our niche among this profession. Watering down our credential seems a slippery slope, sort of like, how anybody willing to pay a fee and attend a class can sell life insurance or become a realtor. Our professional credential is not a stopping point on the way somewhere else or a part-time fall-back job. It is a career and the stringent experience requirement ensures that only the most seriously-minded advisors need apply.

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KIMBERLY BRIDGES, PHD, CFP®

Date: September 14, 2011

Subject: Comments on Proposed Changes to Work Experience Requirement

I have read the proposed changes, and would like to make the following comments:

  • I do not support the recommendation that the work experience requirement can be met through two years of experience in the delivery of financial planning services. I recommend that the existing three year requirement be maintained. I do not believe that easing up on the experience requirement will improve the status of the CFP® marks.
  • I do support the recommendation that a maximum of two years of full-time credit toward the three year work experience requirement be awarded for teaching in a CFP Board-registered program. I do not believe that anyone should be able to attain CFP® certification without actually working in the delivery of financial planning services with real clients (either through employment or pro bono experience). Furthermore, I believe that such teaching experience should only be awarded for teaching in a CFP Board-registered program. I do not believe that teaching finance classes in a non-registered program should suffice.
    • Exception: for newly forming Board-registered programs, I believe that up to one year teaching experience should be credited in the year leading up to registration. The reason for this is that colleges and universities who would like to start registered programs need to be able to attract newly minted PhDs to start the programs. Such new graduates may not have the CFP® designation, and would be reluctant to take a position with a non-registered program if their teaching experience would not count toward CFP® work experience. By allowing up to a year of experience to count, these professors would have an incentive to get their program up and running and registered with CFP Board.
  • I support the change in the qualifying window for gaining work experience from 10 years to 5 years.
  • In regards to Residency programs, I support crediting such programs for up to three months of experience, but do not believe that more than one residency program should be allowed as a substitute for real-life experience.
  • I support the change in attester verification to CFP® professionals in good standing only.

In summary, I believe that we need to uphold the highest standards for CFP® certification, and would not support any proposal that would make the work experience requirement easier to obtain. Because holders of the CFP® mark are expected to be able to provide comprehensive financial planning services without supervision, I believe the work experience requirement should involve more than one of the elements of the financial planning process. Since comprehensive planning involves more than performing a single function, work experience in a single area—such as investment analysis—should not be adequate to meet the requirement, regardless of the duration of experience. I also believe that we should not allow CE requirements to be met unless they cover a broad range of financial topics. Provisions should be in place that would prevent an individual with an area of specialty—such as insurance, investment management, or estate planning—from acquiring and maintaining the CFP® marks while gaining all experience and CE credits in their area of specialty. Other designations—such as CLU, CFA and AEP—are appropriate for specializations. Since the CFP® designation represents expertise in a broad scope of financial planning topics, work experience and CE credits should cover a broad scope to be acceptable.

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DAN CANDURA, CFP®

Date: September 15, 2011

Subject: Comments on Proposed Changes to Experience Requirements

I appreciate the opportunity to provide feedback on the proposed revisions to the experience requirements. I recognize that this matter was given thoughtful attention by the working group in collaboration with CFP Board staff.

I find there are parts of the proposal that I support and others that I suggest need further modification. I will start with the changes I like.

  • Restricting the attestation to CFP® professionals in good standing will help assure that candidates meet the actual requirements rather than the perceptions of someone less familiar with the requirements.
  • Making the requirement more stringent for those involved in support roles, supervision and teaching recognizes the supremacy of the personal delivery of advice. Consumers expect that an individual with certification has the requisite experience to serve their needs.
  • Acceptance of internships, practicums and residency programs offers an alternative approach for candidates to gain valuable experience under the supervision of an experienced professionals. The ability to fulfill up to six months of the experience requirement in this manner is reasonable.
  • Eliminating the currency requirement removes an unnecessary obstacle that created an additional burden for some
  • Limiting experience to five years before and after passing the exam provides sufficient time and assure consumers that the experience is reasonably recent.

    • These are the areas where I suggest modification in the proposal:

  • Reducing the experience requirement when fulfilled by personal delivery to two years does not serve the interests of consumers. It reduces the strength of the marks. This is especially true when combined with the possibility that six months of the requirement could be met through residencies, internships or practicums. A candidate with as little as 18 months experience in personal delivery of financial planning could meet the requirement. The requirement should remain as three years. It should not be reduced beyond the potential to use six months of the aforementioned peer review activities.
  • To recognize the essential difference between supervision, teaching and support services as qualifying experiences, I suggest that you either increase the requirement for this type of activity or allow 1/2 credit for these activities toward the experience requirement.
  • The current attestation process needs more structure to provide more benefit to the public. CFP® professionals should be required to complete a checklist of activities that verify that they have personal knowledge that the candidate meets the requirements and that they have observed the candidate perform the services described. The process could be similar to what applicants to graduate schools must complete in obtaining references. This could be done on-line as is done today at most universities. The candidate should be required to obtain more than one such reference.
  • The criteria for peer review activities should be more transparent to encourage more CFP Board registered programs, organizations and individuals to engage in this activity. The addition of a capstone course to the education requirement strengthened the preparation of candidates. The addition of innovative peer review experiences could do the same.

    • I congratulate the working group for their work evaluating the existing experience requirement. To continue as the preeminent certification for personal financial planning, the CFP® certification experience requirement should not be reduced or shortened.

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    ZACK CLARK

    Date: September 2, 2011

    Subject: Experience Requirement Change Proposal

    I am a 23 year-old paraplanner, working for a CFP® certificant, Stuart Coats and have been assisting on the delivery of plans on a supervised basis for the last several months now. When I heard about the proposal for the Experience requirement change, I must say I was quite pleased that the CFP Board is reconsidering this component of requirements for Certificants. It would be nice to benefit from such a rule change personally, but more importantly I think it would better align the requirement with the nature and progression of the industry. Society needs more planners who are held to higher standards of professionalism, ethics, and competence. By shortening the requirement for people delivering plans to clients and tightening the window for the experience, the Board would effectively increase both the competence of those holding the CFP® designation, AND the number of competent professionals able and willing to do the work that is demanded by the public. The actions of this proposal are certainly a step in the right direction!

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    VIRGINIA CLAY, CFA, CFP®

    Date: August 19, 2011

    Please tighten the qualifying window.

    I think 10 years is still wide -- someone could only spend 30% of their work life over that time period performing the related task. I would prefer 6 or 8 years. There should be a full time commitment to the profession.

    Please do not eliminate the currency requirement.
    Again, there should be evidence of full-time commitment to the profession.

    Internships, practicums the residencies should be PAID. Also, in many professions, these are defined and accredited. Some internships are not even well supervised and turn into clerical oriented work with minimal exposure to substantive learning. I oppose use of internships etc. if not paid and accredited and supervised by a third party like a University that is also appropriately accredited and allowing all the time in the internship etc. to be used for credit in their program.

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    VINCE CLINTON, MBA, CFP®, CLU

    Date: August 19, 2011

    Request for Comment: Proposed Revisions to CFP Board's Experience Requirement

    First of all, I would like to thank the group for their thought and deliberations on this subject.

    I had one comment that is not in support of one of the changes, and that is to limit the "attester" to a CFP® professional in good standing.

    I think that it is important to maintain our vision to the mission of providing services to the public that we all agree is underserved, with a credentialed program that really does stand for something positive. We currently allow CPAs and Attorneys to attest to services being provided, and I think that is a good thing for our program. To have the support of a CPA, or an Attorney evidences the cross-professional contacts that marks a successful CFP® professional candidate. I can understand the appeal of limiting this attestation, but like all decisions, it comes at the expense of what I would consider to be a greater good.

    I think that it is important for us to keep our eyes on our objectives, and not take on the characteristics of an inward-focused medieval guild.

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    ADAM F. CMEJLA

    Date: September 2, 2011

    Subject: Comments on Requirements

    While not a CFP® professional yet, it is a goal that I look at working to accomplishing in the next couple of years. I am excited about the possible changes which, I hope, will ultimately bring a level of prestige and exclusivity to the designation. I am also appreciative of the PR that is being implemented to bring more public awareness of the benefits of working with a CFP® professional. In today's day and age, with the complexities of personal finances, SEC and FINRA licenses along with in-house training are no longer sufficient to plan for clients. The knowledge that a CFP® professional brings is an asset to any client relationship and I hope the CFP Board continues to implement awareness measures to make the general public aware. I was especially surprised to see CFP Board sponsor an ESPN Sportscenter segment, though it would have been even better to see a follow up commercial to that plug!

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    STUART COATS, MBA, CFP®

    Date: September 2, 2011

    Subject: In Favor of Changing Experience Requirement

    As a CFP® certificant and fee-only planner who met the experience requirement over 7 years ago, I would like to go on record as being in favor of the proposed changes to the experience requirement for CFP® certification.

    In particular, I think the emphasis on the personal delivery of financial planning services over more indirect roles is a change that is long overdue. Two years served in a direct role under the supervision of a CFP® certificant is a reasonable level of experience prior to obtaining certification and it should cause more young people, not to mention career changers, to consider financial planning as a career. I think we would all agree that our profession desperately needs massive growth in the number of certificants.

    I also believe tightening up the 10 year prior experience window to 5 years appropriately reflects the tremendous amount of change that can occur in the financial planning landscape over what used to be a total 15 year window of experience crediting. It is hard to see a lot of relevance today from experience gathered more than a decade ago given the rate of change in the profession and it would be appropriate to narrow that 10 year window to a more relevant 5 years.

    After appropriate consideration, I hope the CFP Board will approve these revisions.

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    AUDRA COLLETT, CFP®

    Date: August 18, 2011

    Subject: Comments on Experience Revisions Proposed

    I just read the revisions and am in agreement with all of them but the first one. I believe that in order to satisfy the experience criteria to earn the CFP® designation, it still should be the three years full time work related to the financial planning process. The Board would still accept experience that involves the supervision, direct support, teaching, or personal delivery of all or part of the six part financial planning process to a client.

    This proposed change goes against your mission statement. The Board's mission is to benefit the public by granting the CFP® designation and upholding it as the recognized standard of excellence for competent and ethical personal financial planning. The CFP Board has established 5 core objectives that support its mission with one of them being competency. This objective is to establish and uphold the rigorous competency standards for CFP® certification. One of these standards is experience. In effect by reducing the experience requirement to 2 years, you are making it easier, or less rigorous, to obtain the designation and diluting the standards of excellence. I believe that the Board is damaging the reputation and prestige that the CFP® designation holds and has diminished the work of the previous Boards who have fought so hard for the prestigious reputation that the designation holds today. Why would the Board believe that it is better to have less experience? I challenge the motivation of this particular revision.

    I strongly urge the CFP Board to reconsider this revision.

    Thank you for your time and effort in this regard.

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    KAY CONHEADY, CFP®

    Date: September 6, 2011

    Subject: Don't Shorten the Experience Requirement!

    As a CFP® professional who understands firsthand how valuable each year is in the financial planning learning curve, my feedback to the proposed changes is that I don't think the 3 year requirement should be lowered to 2 for those who deliver financial planning services. 3 is the right amount.

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    ANTHONY D. CORONA, CFP®

    Date: August 19, 2011

    The harder to obtain and the stricter rules the better…

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    JANN DANIELS COULSON, CFP®

    Date: August 18, 2011

    Subject: Changes to the Experience Rule

    Since we are all good at math I think this is an adequate explanation. If not and I will develop a specific data set to demonstrate the problem.

    When I decided to begin work toward my CFP® certification ran into a potential problem. Although my situation work out, I would like someone to look at your system so it CLEARLY states when the "five years before and five years after" because I came very close to being the position (due to a stint as an at-home mom) where I was loosing a month of experience for every month I was working. Because of the gap I was making no headway.

    So please make it clear that a person gets credit for all experience within the prior 5 years as of the date of otherwise meetings non-fee payment requirements. Otherwise you may discourage a highly able and caring professional who regards family leave as important or has taken a break due to health issues or to test alternative vocational waters within or outside of the financial field.

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    GILLIAN E. CURRAN, CFP®

    Date: August 18, 2011

    Subject: Comments on Work Experience Requirement

    I would recommend adding part-time employment as an extenuating circumstance for the one-time, three-year extension of the work experience requirement. If a candidate is working part-time less than 16 hours per week in the personal delivery of financial planning services or less than 24 hours per week in supervision or direct support, then he or she will not be able to complete the requirement in time even if he or she works for 5 years. I think it would be reasonable to grant an extension in this case if the candidate has been working for 2 or 3 years but has not met the requirement as a result of his or her time being pro rated. I personally went into this field after having children because I needed a more flexible career and have always worked part-time. I have built a successful practice in spite of my time constraints and think it is important for the work experience requirement to be flexible enough to be achievable by those who work part-time.

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    MICAHEL A DARANY, CFP®, EA

    Date: August 19, 2011

    Subject: CFP Board Remarks

    Regarding the request for comments about qualifications, the 3 years in service has always been ideal, hell, I would make 5 years if I had my way that way they will learn their profession and have time to season three years is not quit long enough in my opinion.

    When I started there was no CFP® designation so we had to learn by doing and the only designation was the CLU before the CHfC was actually perfected as a designation. That was 1968. I took my CFP® certification courses starting in 1984 and received my designation in July of 1986. I have since become an Enrolled Agent that is a certification from the U.S. Department of Treasury in Tax matters it is a two day exam in all things tax unlike accounting which is more inventory accounting etc.

    Interestingly enough because I never went to college I am barred by my own colleagues from taking the Masters level of courses from the CFP® certification program. Broke my heart when I found out I had been rejected a number of years ago I even wrote the founding Father and he turned me down. I would suggest to you that decision was not right and if I had gotten in and passed and have been an upstanding and continued studying individual i.e. CE up to date etc, then I should have been provided the right. The business has been good to me for the most part this is one of those rough patches I never could appreciate. Your comments and consideration to go further in the education area and waive my four year undergraduate requirements would be very much appreciated. I even have the President of one America Largest Universities as a Client and he is the second University President I have had with two different schools; I have had the Chairman's of the Board of College Medical Schools; and Public Company Trust as clients. All my client's are highly educated they must know something the CFP Board Doesn't that I know what I am doing.

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    BRANDON DAY, CFP®

    Date: August 25, 2011

    Subject: Proposed Revisions

    1. Personal Delivery of Financial planning services; no I don't agree lowering from 3 to 2 years. It's too easy for somebody to stumble through their first couple years in the business utilizing family and friends. It's not until 3 years or more that you really become likely to stick with it. I don't want a bunch of wash outs holding the CFP® marks. The public should think of a CFP® certificate as not only ethical and balanced in their approach, but is likely in the business for several years to come. Someone dedicated to their craft. I would go the opposite direction and say 3 years plus peer review required.
    2. Qualifying Window: I agree, lower it from 10 years to 5 years. This business is constantly changing and evolving. 10 years is too much time to be not directly involved with the business.
    3. Attester: yes, only CFP® professionals in good standing should be in this position.

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    VIVIAN M. DERRICKSON, CFP®, CLU®

    Date: August 19, 2011

    Looks okay to me.

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    BRIAN L. DIETZ, CFP®, CFA

    Date: August 23, 2011

    Subject: Revised Experience Requirements

    I think these very reasonable changes will strengthen the relevance of the qualifications for CFP® certification.

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    JOHN DRAPER, CFP®

    Date: August 19, 2011

    Subject: Comments on Proposed Changes.

    I just wanted to give a quick comment on the proposed change from 3 years of practical financial planning to 2 years. Reading through this I guess the immediate thought was that we are lowering our standards. Even if that isn't exactly the goal, it is in essence what we are doing.

    I oppose lowering the standards when I feel so strongly this industry needs to keep raising the standards. If we don't raise them, then we will be under constant attack by politicians and other. They will keep putting restrictions on us, which invariably hurts clients in the long run.

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    ROBERT B. DUNN, CFP®

    Date: August 19, 2011

    Subject: Experience Requirement

    I am writing to make a brief comment on the proposed changes to the CFP® certification experience requirement.

    The marks have a level of value at the moment that give individuals comfort knowing that the professional they are working with has knowledge and experience. I have found that you can have different forms of learning that qualifies as experience for the board. I will say that the best experience is to work directly in a financial planning firm (not a money management firm) provides the greatest experience possible. The depth of conversations that take place among clients and other professionals during the current 3 year time frame helps grow the individual to a point where they can add value to a particular individuals planning situation. To lessen that would only lessen the value.

    The CFP® marks are continually under attack by other designations for superiority in relation to financial planning. If you are to reduce the time requirement to obtain the marks I think this will begin to reduce the strength the marks hold in the industry and the perception that the public has regarding the marks.

    Just a few words but I feel strongly that it is important for an individual to gain sufficient experience before they let loose on the general public. Do not reduce the time requirement for experience.

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    MARK ESSENFELD, CFP®

    Date: August 19, 2011

    Subject: Proposed Revisions

    I am in favor of all of the revisions as stated, except for the first. Though I agree with the idea of separating direct and indirect experience, I do not want to see that requirement lessened to 2 years for direct experience. I would prefer that the direct requirement remain at 3 years, and that the indirect requirement be lengthened to 4 or 5 years. Experience is a valuable asset in this very complex field, and I don't see that we are helping our profession by lessening the amount of experience required for certification.

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    RAMON FERNANDEZ, MBA, CPA, CFP®, CMA, CIA
    ASSISTANT PROFESSOR
    CFP® CERTIFICATION EDUCATION PROGRAM DIRECTOR

    Date: August 18, 2011

    Subject: Proposed Revisions to CFP Board's Experience Requirement

    If we are going to change the work experience requirement, it should be two years across the board. Why two years for delivery and three years for supervision/teaching/support? What is the rationale behind that? It sounds like a compromise, without much justification, between folks that wanted two years and those that wanted three years of work experience.

    If a financial planner is supervising other planners or teaching other planners, to me that is higher level work that should, if anything, be given preferential experience treatment. It should not equate to 2/3 of personal delivery experience.

    Make it two years across the board or leave it at three years across the board. This artificial creation of two experience tiers does not make sense to me.

    Thank you for allowing me to give you my comments.

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    MARK A. FISSEL, CFP®

    Date: August 24, 2011

    Subject: Proposed Revisions to CFP Board's Experience Requirement

    I am in receipt of the proposed changes relating to the Experience Requirement. Having just received the CFP® certification within the last month and waiting the prescribed three years for experience; it's disheartening, to say the least, that now the Board may consider decreasing that benchmark to 2 years for certain subsets of the population.

    I am very proud of the CFP® process and though at the time, I was irritated by the grueling process to become one of the elite few, I now appreciate the hurdles one must jump through. From my perspective, we should be raising the bar in future revisions rather than lowering it for new entrants. This is a highly coveted certification in the financial planning realm and even recognized by the general population as the most notable of accreditations. I fear we are "watering down" the certification which has been held in high esteem for so many years.

    As one of your newest members who plans to be a lifelong contributor and champion, I ask that you please reconsider lowering the water-mark for new entrants which could set a bad precedent in future revisions.

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    TINA FLORENCE, CFP®

    Date: September 7, 2011

    Subject: Proposed Experience Rule Change Comment

    I would like to comment specifically on the portion of the rule change relating to the "Attestor" for the experience requirement. If the intent is to only allow CFP® practitioners in good standing to certify for the experience requirement for the CFP® certification candidate, I would oppose that change. Requiring candidates to find a CFP® practitioner to work under to fill their experience requirement would create a host of unintended consequences. I believe it would have a chilling effect on the number of people pursuing the CFP® mark, especially if they are pursuing this as a change of career. Why go to all the trouble to complete the CFP® certification coursework and take the exam if there is no certainty you can find a CFP® professional "Attestor? What about the individual considering the CFP® mark as a further credential, but doesn't work at a firm with a CFP® practitioner? If they met all the other requirements would they then be barred from using the mark because a CFP® practitioner didn't supervise the experience? What if they live in a small community and there are no CFP® practitioners? What if there are CFP® practitioners, but none of them are hiring? And so on…

    I think a better approach would be to reward the candidate who trained with a CFP® practitioner by shortening the experience requirement. Maybe two years if you work with a CFP® practitioner, and three years if your training is with a non-CFP® professional advisor? That way there is a path for everyone, but an incentive and reward for CFP® professionals to mentor and train the next generation.

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    LACEY FONSECA, CFP®

    Date: August 18, 2011

    Subject: Revised Work Experience Guidelines

    I've reviewed the guidelines and support most – I'm not sure I'm 100% in favor of eliminating the current experience requirement. The industry is changing rapidly, and I think having some near reporting experience is important.

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    DAVID FUHRMAN, CFP®

    Date: August 22, 2011

    Subject: Opposed to Changing the Experience Requirement

    Since we/you are engaged in a campaign to increase public awareness of the CFP® certification and to promote the CFP® designation as the "gold" standard, a reduction in the Experience requirement seems counterproductive to the campaign objectives. While I support differentiating between "personal delivery of financial planning services" and the other qualifying activities, the direction should be to increase the time required for the "other qualifying activities" while holding the "personal delivery" requirement at 3 years.

    In my opinion, the CFP® certification standards are insufficiently rigorous. The CFP Board should seek to increase the value of the CFP® credential by making the exams more difficult and generally increasing the requirements. Your proposed modifications take us in the wrong direction!

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    J LOGAN FULLER, CFP®

    Date: August 18, 2011

    Subject: Proposed Revisions

    Regarding the Experience Standard, I do not agree that three years (without supervision) or two years (with supervision) is appropriate. If anything you should be increasing the Experience requirement to a minimum of four or five years with or with out supervision.

    In addition, the minimum passing scores need to be increased on the exam! Last time I checked the pass rate was over 50%?! Far too easy for the exam to be considered difficult and far too easy for the designation to carry any value within the industry. The whole point of this designation is to hold us to a higher standard and if the CFP Board lets just anyone pass the exam then it carries zero value. (Especially given the increase in dues)

    Those are my thoughts!

    Thanks

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    TODD C. GANOS, JD, CFP®

    Date: August 19, 2011

    Subject: Comments to Proposed Revisions to CFP Board's Experience Requirement

    I recommend that your proposed revision to your experience requirement for certification be a first step.

    Your proposals are sound. However, I would recommend limiting what counts as experience. In the past, CFP Board has been lax as to what would qualify as experience in comprehensive financial planning. Individuals who are property/casualty insurance agents, mortgage brokerage, etc. and who have never participated in the comprehensive financial planning process have become certificants. This would extend to many if not most stockbrokers who hold the designation. This has cheapened the designation. CFP Board should require clear and convincing evidence that an individual has experience in comprehensive financial planning.

    The second step CFP Board should take is to clean house with existing certificants. CFP Board should deny certification renewal to individuals who are not engaged in comprehensive financial planning. Individuals who are simply selling property/casualty insurance or who are selling mortgages do not engage in comprehensive financial planning and should not hold the designation. Many if not most stockbrokerage rarely perform comprehensive financial planning. Indeed, the canned financial plans that most stockbrokers sell to clients state that they are not providing comprehensive financial planning. As a part of its certification renewal, CFP Board should devise some method to inquire as to what an individual is actually doing in each of the elements of the comprehensive financial planning process.

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    COLIN GEIGER, MA, CFP®

    Date: August 19, 2011

    Subject: Revision of Work Experience for CFP® Certification

    I think the revisions being proposed for work experience are sound except I would question the removal of the condition that 6 months of experience be immediately preceding the application for acceptance of work experience. It would seem that the retention of the 6-month condition will ensure the Board is certifying candidates who are "in the business" and presumably current on the practice of financial planning.

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    MATTHEW D. GELFAND, Ph.D., CFA, CFP®

    Date: August 20, 2011

    Subject: Comment on Experience Requirements for CFP® Certification Candidates

    The work of the CFP Board on reviewing and amending the experience requirement in fulfillment of qualifying for the CFP® certification is to be commended. I send this comment in support of most, but not all of the recommended changes. To wit: (1) tightening the qualifying window for experience to five years before and after successful completion of the CFP® exam: (2) eliminating the currency requirement that some experience be completed within six months of reporting; and (3) affirming CFP Board's support of internships, practicums and Residency Program opportunities as a valuable method of gaining financial planning experience are all sensible changes that have the effect of ensuring that work experience is both more current and based on up-to-date professional standards and practices.

    However, I am strongly opposed to reducing the experience requirement from the current three years to the two years you suggest for those who garner experience through personal delivery of financial planning services to clients. First, as a matter of protecting the integrity of the CFP® certification, I strongly believe the requirement should be kept at three years to conform with the requirements of existing CFP® certificants. Second, as a matter of substance, two years is hardly enough time to learn and absorb the practical, real-world details and nuances of financial planning applied to actual clients who are entrusting their life savings and family welfare to our professional colleagues. I would argue that three years is barely enough time, but three years is a standard length of time for many other professional credentials, of which I am most familiar with the CFA designation, which also requires three years of relevant work experience.

    Consider, by way of example, a candidate who had completed exams any time between 1990 and 1999. Such a candidate, for example, would never have experienced a recession or a bear market, would never have experienced the normal volatility with which we have been living since 2007 and arguably since 2000. Going forward, if markets revert to the mean, new candidates completing exams in, say, 2014 or 2015, again, might never have worked through a recession or bear market, or oppositely might only have worked through a recovery period and bear markets that (one can hope) will not be representative of more positive experiences going forward. While three years of experience would not ensure experiencing a full business or market cycle, shortening the work experience requirement would only make this problem worse, not better.

    I strongly recommend that you retain the three-year work experience requirement for newly aspiring CFP® certificants.

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    MICHAEL GRANNIS, CFP®

    Date: August 19, 2011

    Subject: Work Experience Requirement

    I'll make this quick and simple. I believe the experience requirement should be AT LEAST 3 years personal delivery, if not 4 or 5 years. Without this background experience the CFP® certification becomes more of a hoop to jump through then actually benefiting the planner and his/her clients. I also feel that direct support should require 5 years experience.

    Please do not dilute the standards of the CFP® certification to increase revenue flows from newly qualified planners. Making the CFP® certification easier to obtain seems to be the goal of this proposed revision, which I do not believe is in the best interest of current CFP® professionals.

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    ARTIE GREEN, CFP®, MBA

    Date: August 19, 2011

    My comments on the experience requirement changes:

    Changes such as 5 years instead of 10 years are quantifiable and can be unambiguously applied.

    However, once you create a two-tier system where "Personal Delivery" counts for more experience than "Non Personal Delivery," you run a large risk of (1) diluting the brand (becoming a CFP is no longer so rigorous) and (2) generating lots of extra communications and possible ill will between CFP Board staff and CFP® candidates unless the definition of "Personal Delivery" can be made pretty lucidly clear.

    For example, Planners A, B, C, & D all work for an RIA owned by Planner X, a CFP® professional.

    Planner A spends 2 hours preparing a retirement spreadsheet for a client, then 1 hour reviewing it with the client as part of discussing alternatives & making recommendations.

    Planner B spends 2 hours preparing a retirement spreadsheet for a client, then 1 hour reviewing it with the client together with Planner X as part of discussing alternatives & making recommendations.

    Planner C spends 2 hours preparing a retirement spreadsheet for a client, then gives it to Planner X who spends 1 hour reviewing it with the client as part of discussing alternatives & making recommendations.

    Planner D (a contractor to the company) spends 10 hours developing the retirement spreadsheet that the other planners above used.

    How many hours of "Personal Delivery" does each of the planners above qualify for?

    A: 3?
    B: 3?
    C: 0? 2?
    D: 0? 10?

    And what happens if someone accumulates both Personal Delivery time and Non Personal Delivery time. How is each hour treated? For example, suppose an IAR (who passed the test) works 6 hours a day doing client work, 2 hours a day doing marketing for her company, and 3 hours a week teaching investing at a local community college. How many hours a week does that count for and how many weeks will it take for her to qualify for CFP® certification candidacy?

    Bottom line: I do not recommend creating a two tier experience system without significantly improving the definition and the measurement system for both Personal Delivery and Non Personal Delivery.

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    MIKE GREENE, CFP®

    Date: August 29, 2011

    Subject: Comments on CFP Board Work Experience Requirement

    Overall I really like the clarifications. I believe they will be well received by practicing planners. My comments below apply to corporate office support personnel who wish to gain the mark.

    I would ask that CFP Board more closely define what is meant by: "Candidate must be directly responsible for information that is provided to the planner and/or client and have reasonable accountability for the client." Depending on how this is interpreted by a CFP Board analyst I will likely stop having Ameriprise corporate employees go through the program as it appears that this means actually work client cases only versus the variety of support we provide including designing software, providing training, telephone support, etc.

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    DONALD L. HAISMAN, CFP®

    Date: August 18, 2011

    Subject: proposed revisions to the Experience requirement for CFP® certification

    CFP Board,
    I have been practicing full-time as a CFP® Practitioner since 1967.

    I have reviewed the revised experience requirements for CFP® certification and completely concur with the changes.

    Job well done.

    I have no additional changes to propose.

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    STEVEN HART

    Date: September 6, 2011

    Subject: Proposed Revisions to CFP Board's Experience Requirement

    I graduated with my Bachelors degree in May of this year when I was 20 years old and took the CFP® Exam in July

    I would like to see the Experience requirement allow people to gain the required experience past the 5 year window. I only have about 8 months of part time experience going into the exam which means that I need almost all 3 years experience within the 5 years following the exam. I would like to have the flexibility to work in an unrelated job but still in finance having the possibility of having to retake test just because I did not have prior experience. I have a rare case of this being so young and as a side note I would like to know what the youngest is that anyone has ever passed the exam is.

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    C. THEODORE HICKS II, CFP®

    Date: August 22, 2011

    I'm not sure how I'm supposed to make comments on the proposed changes ... but I don't think we should go from 3 years down to 2 years. I do think we should add the proposed professional supervision requirement or peer review.

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    ERIC D. HIRSCH, CFP®, AWMA®

    Date: August 20, 2011

    Subject: Comments on Proposed Changes to Certification Requirements

    I believe that the focus of the board should be to make the CFP® certification attainment and maintenance requirements more stringent. Over the past months the board has created, what is in my opinion, a powerful and valuable marketing campaign that will help CFP® professionals convey their value to prospective and current clients. This has increased the value and allure of the CFP® designation. Unfortunately, I don't believe that a relaxing of the rules for entry into designation will have a similar impact. With the sheer number of CFP® professionals the value of the designation is becoming diluted. I urge the board to make the barrier to entry and maintenance a higher one so as to maintain the supreme value of the designation.

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    JOSIE HOFFMAN, CFP®, CSNA, CRPC®

    Date: August 19, 2011

    Subject: Comments on Proposed Changes to Work Experience

    This would be a great change! It would make the goal of becoming a CFP® professional more aligned with the goals of the organization. If an applicant has not had recent experience, they have not seen all the recent changes in practice, only on paper.

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    BRIAN HOUTS

    Date: September 20, 2011

    Subject: Clarification of Proposed CFP Board Experience Changes

    I would like to comment on the issue of "grandfathering" and how it would apply to the new regulations.

    Would existing CFP® certification students/testing applicants (say in 2012) be wrapped up under the new experience rule requirement, or continue with the three year requirement?

    In my case, a two year client-facing requirement would actually expedite my experience process, however I can see that it could slow the process for someone in a supervisory or teaching role who would then have to provide new experience levels to qualify.

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    CHRISTOPHER A HOWARD, CPA, CFP®

    Date: August 19, 2011

    Subject: Comments on Proposed Changes

    Our industry is constantly changing so I agree with tightening the window.

    IMO:

    Keep the experience requirement at 3 years.

    As someone who is relatively new to the CFP® certification I think it is wrong to water down the CFP® designation by letting someone with only 2 years of internship experience use the designation. If we're going to market that our credential is the best in the industry how can turn around & make it easier to attain? If this is about growth in membership it is not the right way to go about it. The AICPA has grown membership & has actually tightened the standards to receive the CPA designation over the last decade.

    There must be a better way - thanks for your consideration!

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    BRENT HUNSBERGER

    Date: September 17, 2011

    Subject: Comments on Proposed Revisions to CFP Board's Experience Requirement

    I'm a candidate for CFP® certification from the Certified Financial Planner Board of Standards. I've been a business journalist for 10 years at The Oregonian. I restarted the newspaper's personal financial column in November 2008 (www.oregonlive.com/finance) and won the Society of Professional Journalists award last year for Best Business Column in the five-state Pacific Northwest region.

    Also last year, I earned an executive certificate in financial planning from the University of Portland and passed the July 2010 CFP® exam. This spring, I became a state-registered Investment Adviser Representative for New Outlook Financial, a fee-only planning firm in Portland. I work there part time, personally delivering planning services to clients.
    I applaud the board for reviewing its experience requirement. However, the proposal fails to tackle inconsistencies in its certification process, one of which hits home personally for me.

    According to Keven Keller, chief executive, and Michele Warholic, managing director of examinations, education and talent, the organization will not consider work as a personal finance columnist and financial journalist as qualified experience for CFP® certification. At least three other financial journalists have been told the same thing. I plan to contest this interpretation as it applies to my specific circumstances when I submit my Work Experience Reporting Form.

    I'd like to make the working group and board staff aware of how financial journalists follow five of the six elements of the planning process:

    1. Establishing and Defining the Relationship with the Client: Journalists do this just about each time they conduct an interview. They define portions of a conversation are on or off the record. They set parameters for what information from an interview will be published. They describe the nature of their publication and the goal of their inquiries. This is what the board says planners should do with their clients. Moreover, personal finance columnists such as myself explain to readers "issues and concepts related to personal financial planning process," another part of this element.
    2. Gathering Client Data Including Goals: Financial journalists do this with individuals and corporations. They gather information on broad economic trends. They analyze Morningstar reports and corporate balance sheets. They research the pluses and minuses of financial products. When profiling individuals, they ask questions about their investments, income, asset values and debts. They verify this information with original documents – account statements, public land records, financial disclosures (For an example, see http://bit.ly/qhBkXF). Most importantly, they listen. They ask subjects what they dream of doing in the future and how their current situation reflects those dreams. Financial planners do the same thing as they serve their clients.
    3. Analyzing and Evaluating the Client's Current Financial Status: Journalists analyze financial statements, cash-flow needs, balance sheets, debt loads, risk management practices, investment performance and tax situations of both corporations and individuals. They do this using the same information available to financial planners.
    4. Developing and Presenting Financial Planning Recommendations and/or Alternatives: Journalists regularly present the findings of their research to readers in written reports. They offer specific recommendations and solutions to issues facing individuals, companies, voters and elected decision makers. It's part of a journalists' public service. My three-part series on asset allocation, for instance, gave very specific diversification strategies readers could use based on their own risk tolerance. Read the series at http://bit.ly/gOumQ5 and http://bit.ly/esJgsa and http://bit.ly/gN9Ihh.
    5. Monitoring the Financial Planning Recommendations: Journalists follow all sorts of economic and financial trends. I do this especially if I've recommended them to readers in any way. Here's an example of how I followed steps of the financial planning process, including monitoring, while reporting on behalf of investors throughout Oregon. In late 2008, a key bond fund in the Oregon College Savings Plan lost nearly 40 percent of its value. I broke the story, investigated the state's slow response, explained the risky derivative bets to readers and made recommendations to safeguard the plan in the future (See http://bit.ly/nbxFAr and http://bit.ly/mYG3lp). The state eventually changed plan managers and implemented safeguards highlighted in my stories. Then, earlier this year, while continuing to monitor the new plan, I was the first to notice an annual loss in its conservative money-market fund (See http://bit.ly/qqYUYL), something not even the plan's independent consultant had brought to its board's attention. My story triggered the plan's manager TIAA-CREF to waive its management fees not only in Oregon but in three other states, saving participants thousands of dollars (See http://bit.ly/lzpXEB).

    In addition, I believe journalists' experience equals and in some cases exceeds that of CFP® practitioners in the following areas:

    Continuing education: Journalists stay on top of changes in laws affecting taxes, retirement plans, health insurance and estate planning to keep readers informed. They do this by turning to the same sources CFP® practitioners do.

    Accountability: Journalists are as accountable to readers as financial planners are to their individual clients – in some respects, more so. A personal finance column is open to repeated scrutiny by thousands of readers, including CFP® practitioners. Readers comb them for mistakes and report them to editors for prompt and public correction. Online, our writing is immediately open to critique and debate (See http://bit.ly/9NTdIZ). A planner, by contrast, is accountable to an individual client and periodic visits from regulators. They communicate largely in private. Readers can scrutinize a journalist's written recommendations over time for their accuracy, reliability and soundness more easily than a new client can scrutinize a financial planner's past performance.

    If what I've described above does not resemble personal delivery of planning services, it certainly resembles providing direct support to the financial planner or clients. Such work qualifies under the board's experience requirement.

    Personal finance journalism also is akin to teaching planning (another approved type of experience) to those who can't afford a CFP® practitioner but need the help as much as anyone. The financial literacy of this country's youth and their parents is inadequate. Yet many CFP® practitioners require minimum net worths or initial investments that exclude those who need their guidance the most. The CFP® mark would be well served if it was held by writers who educate themselves about the financial planning process and, in turn, educate the public about the benefits of planning as well and the intricacies of financial concepts and strategies.

    As I said earlier, I am working part-time with a fee-only planning firm New Outlook Financial to accumulate qualified work experience by personally delivering planning to clients. However, the way the current experience requirement is interpreted, I face working 20 hours a week for six years while working my full-time job in journalism to meet the board's requirement of 6,000 hours of planning work. I would also need, under the proposed rules, a three-year extension for "extenuating circumstances." Would my circumstances as described warrant such an extension? Even if it did, this is a tall order and could discourage someone who's otherwise highly qualified and motivated from joining the field.

    Finally, I'm puzzled as to why, then, the board has approved the work of mortgage brokers and stock brokers as qualified experience. I'm told by staff that one reason journalism doesn't qualify as CFP® experience is that the board wants to see candidates with responsibility for an individual's finances over time. I agree wholeheartedly with that virtue. But the work of brokers rarely is comprehensive in nature or focused on the long term. The financial crisis we endured arose in part because mortgage brokers held no fiduciary duty to borrowers and had no regard for their clients' finances over time. How can the board, then, accept such experience while simultaneously rejecting that of a journalist held publicly and professionally accountable for his work who strives to educate consumers? I cannot see, either, how the proposed amendments to the experience standards address this inconsistency. The board needs to address the problem either in the language of the standard itself or in the manner in which its staff applies the standard to CFP® certification candidates.

    I understand the need for planners to gain real-world experience. I don't understand the board's inconsistent interpretation of what experience is. The board faces the unenviable task of upholding the integrity of the CFP® mark while encouraging more able, eager and ethical entrants to join its ranks. It's undermining that mission, however, by qualifying mortgage brokers and those peddling financial-product salespersons while rejecting even partial credit for writers trying to educate and directly support readers. It's also missing an opportunity to tie the mark to a visible, concerted effort to improve Americans' financial literacy. At minimum, journalists provide both direct support and education in that effort. We can all benefit from that.

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    MARVIN R. HUTTMAN, CFP®, CPA, MST

    Date: August 19, 2011

    It used to be that a CPA could sit for the exam without prior financial planning experience. I`m not in favor of that being done away with.

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    CLEOPHAS ISHMAEL, CFP®

    Date: September 16, 2011

    Subject: Three Year Requirement

    I support the three year pre -training for CFP® certification applicants in order for them to gain that fundamental knowledge in planning.

    I presume that applicants would feel more competent in pursuing the CFP® designation after three years in the field.

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    MARK E JOHNSON, CFP®, ChFC®, FIC

    Date: August 18, 2011

    Subject: Comments

    I have trouble understanding why we would reduce work experience to just 3 years. In practice, most "advisors" are just short of dangerous their first two years on the job. Most advisors only become truly good at what they do after close to 10 years. There is no substitute for the school of hard knocks and time on the job. The 5 year standard seemed to strike a happy medium. Why change?

    Likewise with the qualifying window. Today's world is changing so rapidly that someone out of the field for 3 years is essentially starting over. The recommended 5 year window is better than 10 years, but I think falls short. I would recommend 3 years. To those of us already certified, the CE requirement, professional association membership, never-ending reading, and continuous work in the field keeps us up to date.

    I plead ignorance on the residency program, but I shudder to think we would allow CFP qualification to someone with only months in a residency program. If this comment is ill-founded, I apologize, but I'm sure you understand the intention.

    Thanks for the opportunity to comment.

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    CLIFFORD JURDI, CFP®

    Date: August 19, 2011

    Subject: Proposed Revisions to CFP Board's Experience Requirement

    Having taught CFP® Certification curricula at Boston University as well as Northeastern University's MST program, I believe a flat 3 year experience requirement should be completed.

    Those in the financial services business need a great deal of supervision and training particularly early on.

    I see the need for this even when working with experienced financial services employees. The CFP® Certification curriculum is about teaching individuals a method of looking at the client in a more client centered relationship (client and plan led) than what is offered in the financial services industry (sales and product led).

    It takes a disciplined, structured methodology to achieve a well designed financial plan. Obviously, there is flexibility based on a client's goals and needs.

    However, I believe that there is much too much at stake. We're talking about a client's lifetime financial health, particularly those who have distribution needs. I would encourage the board to consider a 3 year experiential factor for both those who deliver personal financial services to clients as well as those achieving the requirement through supervision, direct support or teaching of financial planning services.

    I appreciate the opportunity to be heard.

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    RICHARD BROOKS KANE, CFP®

    Date: August 19, 2011

    The experience requirement should be scrapped. Length of tenure is no guarantor of any higher degree of competence or capacity. It is a needless imposition on new entrants, and the requirement has doubtless kept many promising entrants from considering the profession. It is a not so subtle form of seniority and has no place whatever in a dynamic professional milieu.

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    R. TIMOTHY KELLY, CPA, CFP®, ChFC

    Date: August 18, 2011

    Subject: Proposed Changes to the CFP Board Experience Requirements

    I read the proposed changes to the CFP Board Experience Requirements in the 8/18/2011 email. I believe these changes are reasonable and help simplify the otherwise complex process that exists today.

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    MICHAEL S. KERTES, CFP®

    Date: August 19, 2011

    Subject: Proposed Revisions

    I am 100% in favor the of proposed changes.

    I am currently a CFA Level II candidate and the CFA Institute has similar experience requirements for obtaining the CFA Charter, even after passing all exams.

    We should be looking to raise the standards of the CFP® designation and this proposal does that.

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    MICHAEL KITCES, MSFS, MTAX, CFP®, CLU, CGFC, RHU, REBC, CASL

    Date: September 18, 2011

    Subject: Comments on Proposed Changes to Experience Requirement

    I am writing to express comments regarding the proposed changes to the experience requirement for the CFP® certification. While I am generally supportive of the CFP Board's efforts to refine and advance the experience requirement of the certification, the changes proposed to present a number of important concerns.

    First and foremost, while I generally agree that it is valuable to make a distinction between the experience of doing financial planning, versus the experience of supporting, supervising, or teaching financial planning, the changes to the rules as proposed create several issues and concerns. First and foremost is that, simply put, I do not believe that 2 years of personal delivery of financial planning services is sufficient to develop the experience necessary to become a reasonable expert in the delivery of financial planning, such that granting the marks would be merited. In practice – especially for those who start into financial planning immediately with clients, with no prior job positions – the first year is often a very chaotic one, complicating by simply trying to learn the basics of actually delivering the craft, and more importantly by learning to develop relationships with prospective clients to even potentially deliver services in the first place. It is experience working with dozens and dozens of young planners through the NexGen group, I have witnessed that it is not uncommon for a brand new start-up planner to actually deliver fewer than half a dozen full comprehensive financial plans in the first year. Such little client volume is simply not sufficient to allow a planner to completely develop all of the remaining skillsets needed to effectively deliver financial planning in the second year of practice. Simply put, 2 years of personal delivery of planning is too short; the existing 3 year requirement is more appropriate. It is also notable that there appears to be both an industry and public perception that changing the current requirement from 3 years down to 2 years also represents an adverse "lessening" of the credible standard that the CFP Board has worked so hard to establish.

    On the other hand, I do think it's reasonable to make the distinction current proposed, between experience with the actual delivery of planning, and those who support, supervise, or teach financial planning. However, if the experience requirement for doing financial planning remains at 3 years, then the requirement to support, supervise, or teach, would then be extended to 4 years, to maintain the proposed differentiation in the current proposal.

    If this distinction is maintained, though, it is also necessary to clarify how to evaluate the experience requirement for those who have a blend of experience in the different categories. For instance, if someone follows the "typical" financial planning progression, and provides support for 1.5 years, followed by "doing" financial planning for another 1 year, where does this leave the candidate? Even under the current rules, the individual has fewer than 3 years of total planning, but more than 2 years, which is at least partially composed of the personal delivery of financial planning? But what actually completes the experience requirement? The 2 years of blended experience? Or 3 full years? Does this effectively mean that an individual who does at least 1 year of supporting, supervising, or teaching financial planning, automatically must complete 3 years anyway, because it will take 2 more years just to be doing 2 years of financial planning delivery? What if the planner does 1.9 years of personal delivery, followed by 1 year of support? Is the planner still not eligible to complete the experience requirement? Does that mean the planner should have remained offering "personal delivery" of financial planning for one more month, to reach the 2-year mark? Even if there wasn't actually a new comprehensive financial plan created or delivered in that time period?

    I also found the implications of the proposed changes highly concerning with respect to the career track that it implies for financial planning. The typical candidate, upon completion of the CFP® certification exam, typically seeks the "shortest" path to complete the experience requirement and obtain his/her marks. Under the current proposal, this will encourage prospective candidates to complete internships, practicums, and residency programs, as those provide accelerated experience credit (which is good). However, candidates would also implicitly be discouraged from taking a job in an established financial planning firm in any role that merely "supports" financial planning but is not responsible for actual delivery – because a support job extends the experience requirement from 2 years to 3. Ironically, this means a planner who might obtain a quality support job, earning experience constructing potentially dozens of financial plans, in a quality supervised and supported environment, will instead be encouraged to "hang their own shingle" and instead spend the time trying to grow a business and develop clients from scratch, doing what is typically an incredibly small number of actual financial plans in the initial year. In the end, this means that an individual who is "doing" planning might receive the marks after 2 years, despite creating and delivering no more than 10-20 comprehensive financial plans (in an environment that may have little mentor support, supervision, or any guidance regarding refinement and quality, except to whatever vague minimum is necessary to support an attester's signature), while an individual in a support role who creates 50+ comprehensive financial plans over the same time period, and potentially has at least some interaction supporting the personal delivery of the plan as well, is deemed to require another year of experience. Notably, most established planning firms themselves are so cognizant that brand new planners with no other experience are "not ready" to work directly with clients, that the natural career path in larger independent firms is already to spend a period of 1-2 years supporting financial planning before having a material amount of direct client interaction and personal delivery of planning. In the established history of virtually every profession, "apprenticeship" is a natural path to mastery of a craft, from tradesmen to the residency program of medicine, and the associate accountant or associate lawyer positions in the professions of accounting and law; I would urge the CFP Board to establish an experience requirement that encourages individuals to take on support roles as a part of their professional development, and rewards them for such a path (as the current proposals do for internships, practicums, and residency) as many existing and establish firms already do in common practice, rather than implying that the best way to professional status after schooling and a limited amount of the aforementioned programs is to hang one's own shingle in a mostly unsupervised and unsupported environment to learn their craft from scratch on live patients/clients. Because in reality, given the reluctance of many firms to allow young new planners to work directly with clients until they have established some additional experience simply supporting financial planning (as an "apprentice"), planners who wish to complete the experience requirement in only 2 years will be naturally driven away from the most supportive mentoring firms (that don't allow new prospective planners to personally deliver financial planning to clients in year 1), or will help firms who unleash unprepared prospective planners directly on clients to have a hiring advantage over those firms who wish to provide a slower – albeit more supported – development path that forces another year of experience to earn the marks. Perhaps this means a further distinction should be made between the value of supporting the delivery of financial planning – a natural career path for apprenticeship in all professions for a millennia – as opposed to the supervision (ostensibly, in a regulatory or management capacity?) or teaching financial planning.

    On a final note, I would point out that note only do I support the CFP Board's proposal to reduce the qualifying window from 10 years prior to a successful exam date down to only 5 years, but I hope this will continue further down a path of shortening the qualifying window for experience prior to the completion of the CFP® exam. In no other established profession does experience an individual gains before they are even fully educated as a professional count; surely, we would find no credibility in a doctor who spent 3 years doing internships in a hospital, who THEN went to medical school, got a medical degree, and claimed that he was ready to be a practicing doctor due to the experience he got as an uneducated intern prior to his actual medical studies. While I realize that in the current environment, there are in fact individuals who have established significant financial planning experience before completing the exam, due to the existing career paths in financial planning and the availability of other educational programs, I would hope that over time this qualifying window of prior experience would continue to narrow. Ultimately, only experience that was earned during the educational process, or after the educational process, should actually count as qualifying experience for the CFP® certification – again, the goal simply being to mimic any other profession, which appropriately realizes that experience obtained before an individual has actually been trained in his/her craft and received the appropriate education cannot genuinely be a full level of professional-certifying experience.

    Beyond the comments expressed here, I am in full support of the remaining proposed changes to the CFP® certification experience requirement, including the current experience adjustment associated with the qualifying window, the restriction on teaching experience in a registered program, and the updated attester requirements.

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    MICHAEL KNIGHT, CFP®

    Date: August 23, 2011

    Subject: Proposed Changes

    I support the recommended revisions to CFP Board's Experience requirement.

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    BARRY KORB, CFP®

    Date: August 27, 2011

    Subject: Comments on Proposed Revisions to the Experience Requirement

    Thank you for your efforts to review the experience requirements.

    I applaud the suggested changes to two years for a practitioner who is practicing full time in a manner consistent with the CFP board requirements for a fiduciary CFP® professional!

    •    It should be made clear that experience (time) devoted to sales related activities subject to a suitability and not a fiduciary standard does not count. I.e., experience would have to be prorated between the two roles with only the fiduciary experience counting.
    •   In this regard I would suggest that the ten hour exam test for an understanding of CFP Board rules I this arena and or that the application include a test for such knowledge.

    I have always been concerned about the experience requirements based on direct support and supervision.

    •   I question whether an individual who does no more than collect client intake forms is gaining a full or adequate breath of desired experience. I view this as a serious loophole that harms the credibility goal being sought by having an experience requirement. Would one count a doctor's assistance's or receptionist's experience as qualifying experience in the place of an inter or residency program? Similarly for paralegals. Note this comment is not meant to disparage such individuals or their professionalism. It is meant to distinguish the limits and bounds of their experience and profession.
    •   Similarly, supervisors may in reality be gaining no appropriate experience. Would an MBA supervising a doctor or lawyer really be getting qualifying experience as a doctor or lawyer? A supervisor in a shop primarily adhering to the suitability standard as opposed to the fiduciary standard, may in fact have a built in conflict of interest that hurts their ability to truly gain desired experience even if their focus/function truly goes beyond supervision and management (which often is not the case).

    I hope these comments help. I would be happy to discuss them with you.

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    JERRY F. KRALIK, CFP®

    Date: August 19, 2011

    Subject: Comment response: Experience Requirement, Disciplinary Rules

    I'm entirely for the action to move forward on both changes.

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    DANIEL M. LATHAM, CFP®, CRPS®

    Date: August 19, 2011

    Subject: Work Experience Requirement

    I think that reducing the years of work experience requirement from 3 to 2 years would diminish the stature of the CFP® designation. The CFP® designation should continue to be granted only to those individuals who have demonstrated a commitment to financial planning. 2 years of work experience could be nothing more than transitory, and at some firms in the industry 2 years represents the training period. To allow trainees to obtain the most distinguished designation in the financial planning community would reduce its significance.

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    ERIK R. LAUG, CFP®, CRPC

    Date: August 19, 2011

    Subject: Proposed Amendments to Experience Requirement

    I support tightening the experience requirements, but suggest these requirements be completed prior to receiving the designation.

    More importantly, if we look to other professions similar to ours, specifically tax and legal, the public holds them in a higher professional standing due to the educational requirements demanded before they can even pursue their professional status as an attorney and/or CPA. In fact, I believe CPAs now must earn the equivalent of a Masters before they can sit for the CPA exam.

    In summary I agreed with tightening the experience requirements, but I encourage the CFP Board to consider more stringent educational requirements. Education is as important, if not more, than work experience.

    Thank you for your efforts.

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    EDWARD G. LEEDOM, CFP®

    Date: August 19, 2011

    Subject: CFP Board Experience Requirements Comments

    As an active holder of the CFP® mark, I support the effort to enhance the experience requirements to attain the mark. However, there is a class of people who have obtained the certification that would be precluded from attaining the certification going forward, should the new guidelines be adopted.

    Individuals who work in the financial services industry, but are not actively engaged in financial planning with clients, could not hold the mark if I read the proposed guidelines correctly. Having held the mark since 1994, I have not been involved in financial planning directly. In my work with RIA's, intermediary firms, retirement plans, and endowments and foundations regarding their investments, I have found the concepts involved in the CFP® certification program to be very helpful in allowing me to add value in a variety of client interactions. The CFP® mark also serves as a differentiating tool and enables me to speak with my client base, including RIA's, financial planners, and broker/dealer reps as a peer. Having the mark myself also establishes a certain level of credibility with individuals who hold the mark and are directly involved in financial planning.

    In my 22 years in the business, I have had numerous clients say that they like to work with CFP® professionals in the investment product sales process, as it shows that the salesperson cares enough about the RIA or financial planner to take the time to attain the certification and enables the salesperson to potentially help the RIA or planner with their own client conversations by providing information or background for the planner's asset management discussions with their clients.

    Furthermore, it would strengthen the credibility of the mark if there were some sort of education requirement prior to attaining the mark. Requiring an undergraduate degree would help to raise the professionalism within the financial planning industry and also demonstrate a level of commitment to the financial planning process. The CFA mark requires that certain educational standards are met; aligning the CFP® mark with the CFA education standards would definitely raise the credibility of the CFP® mark and elevate the financial planning process to a new level of professionalism.

    Please feel free to contact me if you would like to discuss this issue, or if you have any questions regarding my comments above.

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    HAL LEONARD, MBA, FIC, CFP®

    Date: August 18, 2011

    Subject: CFP Board Work Experience Requirement.

    CFP Board
    Concur with the proposed changes. One must be actively engaged in the planning process not just teaching or supervising someone doing it.

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    WILLIAM G. LOVENTHAL III, CFP®, CLU, ChFc, AEP

    Date: August 18, 2011

    Subject: Experience Requirement

    I would keep the 3 yr req; the rest of the changes I'm ok with.

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    JEREMY J. LOWE, CFP®

    Date: August 19, 2011

    I think that the experience requirement should remain at three years across the board.

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    HILARY MARTIN, MBA, CFP®

    Date: August 18, 2011

    Subject: Comments on Potential Changes to CFP Board Experience Requirement

    I am writing to comment on the proposed changes to the CFP Experience Requirement. I am a CFP® certificant. My feedback is the following: I don't support the proposed changes.

    First, what problem is the Board trying to solve by making the experience requirement more stringent? What are the harms or failures of the current system? Nothing about this is described in the document I received. Why solve a problem that doesn't exist?

    Second, it is a well-known phenomenon that professional groups with minimum standards tend to drift toward more and more stringent standards—increasing barriers to entry. It is an unjustified form of avoiding competition—namely, "Once I'm I the group, increase the standards to get into the group to decrease my own competition." The academic and testing portion of passing the CFP® exam is tough enough. I don't think the experience standards need to be changed.

    I am happy to comment further, but I don't want to write you a novel, not knowing what weight my comments carry or who, if anyone, will read them. If it's a simple yes/no vote, I vote "No".

    Thank you kindly,

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    SEAN M. MCCANN, CFP®, MSFS

    Date: August 19, 2011

    Subject: Proposed Experience Changes

    My impression of the proposed changes are that lowering the work requirement to two years, albeit in the direct delivery of financial planning services, will open up qualification to people who haven't truly reached the level of maturity in our field that we require to properly be in an authority position. In essence, you are allowing entry to people that haven't "put in their time". It is widely known in our industry that there is a three year demarcation line after which the chances of success becomes probable.

    By allowing people that haven't proven themselves to call themselves an expert simply makes no sense, and dilutes the prestige the CFP® certification carries in the work force. I don't mind narrowing the definition to financial planning delivery, but 2 years is too short. Rather you should be considering raising the experience to 4 or 5 years. If you are looking to increase your lobby, consider a junior status. Don't lessen our status in the process.

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    DONN R MERRILL, CFP®

    Date: August 22, 2011

    I oppose the proposed changed to the experience requirement as it shortens the experience requirement from 3 years to 2.

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    DAN MOISAND, CFP®

    Date: September 8, 2011

    Subject: Experience Requirements

    Kudos to CFP Board for asking for feedback. I will encourage my peers to share their opinions.

    On the bullet points from your request:

    "Differentiating the number of years required to complete the experience requirement through personal delivery of financial planning services to clients (two years) from the years required to complete the experience requirement through supervision, direct support or teaching of financial planning services to clients (three years)."

    While it seems reasonable to me that the experience of working directly with clients is possibly more "valuable" than the other activities listed, I would have preferred that the requirement remain 3 years for personal delivery and the others require more years if CFP Board were to differentiate.

    "Tightening the qualifying window for experience to five years before and after successful completion of the CFP® exam"

    This is sensible. Ten years is too a long time.

    "Given the proposed tightening of the qualifying window, eliminating the currency requirement that some experience be completed within six months of reporting work experience"

    I'm not sure I am doing the math correctly but it looks like combining this with the tightening and two year requirement above would mean that someone could take 3 years off and not have to reestablish experience if they had been personally delivering financial planning services. That strikes me as a significant change from the current 6 months.

    "Affirming CFP Board's support of internships, practicums and Residency Program opportunities as a valuable method of gaining financial planning experience"

    Having personally witnessed FPA Residency, it would be a travesty not to affirm support for that program.

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    MICHAEL SEAN MOLLOY, CFP®

    Date: August 19, 2011

    I think the direct financial planning services requirement needs to change to 5 years of experience and for the supervison, teaching, direct support to 8 years.

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    R. ALAN MOORE, CRC®

    Date: August 23, 2011

    Subject: CFP Board's Experience Requirement

    I personally do not support the proposed changes. I do not believe they will effect very many planners, and actually promotes working in a commission based field over fee-only because you are more likely to work directly with clients in a commission based firm early in your career. Overall, I don't see the purpose for changing the current requirements. I believe they should be made more difficult, not less.

    For example, requiring an internship/number of direct client contact hours (much like therapy certification) would be my preference. Another option would be to require a degree in financial planning (much like accounting in most states) in order to ensure a deeper understanding of financial planning.

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    BOBBIE DOW MUNROE, CFP®

    Date: August 24, 2011

    Subject: CFP® Certification Changes

    In general I am fine with the changes with one exception. It seems that the academics/professors only get to use their teaching experience as two years of the 3 year requirement. This means they would have to pick up the extra year in practical experience. I think this is improbable if not impossible. I suggest that you WANT program professors to have the designation as their students will be more likely to pursue that designation. I ask that you reconsider this change.

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    LAWRENCE O. MYERS, CFP®

    Date: August 18, 2011

    Subject: Experience Requirement

    I agree with the proposed change to the Experience requirement. I think it will continue to strengthen the value of the certification process.

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    MICAHEL E. NEAL, CFP®, CLU, ChFC

    Date: August 19, 2011

    Subject: Changes in Experience Qualifiers

    I would oppose any easing of qualifying standards. It seems counter intuitive to have just held an advertising campaign touting the value of the services and advice offered through holders of the designation and then lighten up on the qualifying standards. Three years of experience of delivering advice is a small hurdle to cross for an individual looking to make a career out of planning. There could be little advantage to the public to reduce that number to two years.

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    MARK A NEHRA, CFP®

    Date: August 19, 2011

    Subject: Proposed Changes to Experience Requirement

    I object to lowering the experience requirement to 2 years. At this time when the CFP Board is looking to reinforce the significance and integrity of being a CFP® Certificant, anything which may be viewed as diluting the standards may be perceived as detracting from the standards. Speaking as one who recently was certified and completed the experience requirement. I believed 2 years would have been insufficient experience.

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    JOHN W. NOEY, CFP®

    Date: August 18, 2011

    My only comments would be to further restrict those who can use the marks.
    1.    5 Year Advisor experience requirement
    a.    When evaluating the retention levels of advisors in the industry those who make the cut for the long run will have more than 5 years of experience.
    b.    In addition, require minimum FINRA licensing requirements of series 66 (6/65) as a minimum requirement for using the marks. The standards the board issues are parallel to the fiduciary standard.
    2.    Eliminate the ability of support staff, educators, etc. who are not practicing advisors from using the mark.
    a.    To retain the fee revenue create a separate mark for each of these "other" type category.
    b.    Examples of distinction of marks
    i.    Educators in Board Certified Programs CFPE®
    ii.    Support Staff CFPS®

    Should you require additional details on these thoughts feel free to contact me.

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    JASON M. PALMER, CPA, CFP®

    Date: August 18, 2011

    Subject: Experience Requirement Comment

    A three year experience requirement is unwarranted. Even Certified Public Accountancy, a far more complex license, only requires a maximum of two years of experience and even less in the case of an advanced degree. The actual process of financial planning is just not that complex. NOTE: I am not referring to other functions, which have other registration, licensing, and experience requirements of which a Financial Planner may engage. (My number one problem with the CFP® mark in general is that it is predominantly held by people that sell product and it is used to add a level of legitimacy to their sales process instead of being a truly independent plan for the benefit of the client.)

    The experience requirement should be waived in its' entirety if the registrant already holds any other licensed credential such as CPA, RIA, SEC Licenses, or Insurance Licenses. These other professions have experience and education requirements that far exceed and encompass many of the CFP® professional's functions.

    The experience requirement, as presently implemented, favors the institutionalization of the Financial Planning process to Banks, Brokerage Houses, and Insurance Agents. It would appear to make it practically impossible for an independent person to become a CFP® professional unless they were willing to work for a company that sells product. Many independent financial planners cannot afford additional staff in the present economy.

    For a person that has absolutely no other business or financial services background, an experience requirement is potentially warranted but it should be reduced to six months or less.

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    JENNIFER PATTEN, CFP®, cltc

    Date: August 19, 2011

    Subject: Work Experience

    I am in agreement with the proposed changes. Thank you for taking the time to review that portion of the policy in more detail.

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    MARK PHILLIPS, MBA, CFP®, AIF®

    Date: August 18, 2011

    Thank you for requesting feedback on this issue.

    I would offer both general perspective and specific recommendations in this area of work experience:

    General perspective:

    To increase the value of an item (as we might think of the mark and the right to use it) with no exact replacement alternative (which I believe the mark enjoys) one would not propose to reduce its cost. One of the costs to bear in obtaining the mark is that of committed work experience. The proposed revisions will not "raise the bar" but will in fact lower the bar by allowing those with 2 (not the current 3) years of delivery of financial planning services to clients to meet the required experience. So it would be that I could have worked from September 15, 2006 to September 14, 2008 and today be an applicant for the mark with the requisite experience. I would have been able to leave the profession for the last three years of most valuable learning experience and now be considered for the mark.

    The issues we as planners are being asked to help our clients address are growing ever more complex, not simpler. A significant amount of the knowledge needed can only come through experience and the critical experience is that gained by working directly clients doing comprehensive financial planning.

    As an item (again the mark) that we as practitioners hold we would all like it to rise in value, but not so much so that it becomes "over priced" and thus irrelevant. If the work experience "cost" is too high few if any will apply (having reached 10 years as a planner in the industry I wonder if I would now choose to endure the other academic requirements to earn the mark if I did not already hold it). There is an optimal point of cost for the mark and while I do not propose to know it I would suggest that we engineer the cost (and this element of the cost) such that we prevent a significant of new applicants.

    This, I will admit, is a social issue as, I believe, having more qualified CFP® professionals in practice would likely prove a boon to society overall, however not so if they are not amply experiences and qualified.

    Questions that I would hope were all addressed as they seem critical to

    • What is the target for new CFP® practitioners to be "minted" each year?
    • How many CFP® practitioners are ceasing to practice each year?
    • What is the replacement rate threshold needed for new CFP® practitioners?
    • How many more than replacement rate would be desirable each year?
    • Will this increase be best met by lowering of the costs (aka standards)? This is to try to understand the "price" elasticity of the mark.
    • Would a lowering of the costs eventually degrade the mark?
    • Would a cost increase in the mark actually increase the coveted nature of the mark and thus increase demand for it?
    • Would an increase in cost taking effect in 1-2 years drive those who were considering obtaining it to act sooner, and still not discourage later applicants?

    The best way, I have witnessed, to encourage "purchase" of an item is to show it is of value now and will increase in cost in the future.

    I believe that the value of the mark will diminish and there will not be any measurable increase in practicing CFP® professionals in 10 years with the adoption of the proposed WE changes.

    Specific Recommendations:

    • Continue to require 3 years of delivery of financial planning services to clients or alternatively 5 years of supervision, direct support or teaching of financial planning services to clients.
    • Announce the rule change more than one full year in advance of it taking effect.
    • Develop higher tiers of accreditation to the mark (such as the CFA designation has) that will further acknowledge experience, and expertise

    Final thought: Harvard has not seen a dramatic rise in applicants over the past few decades because it became easier to get in or cheaper to pay for.

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    WAYNE M. PICHON, CFP®

    Date: August 19, 2011

    Subject: Revisions

    As a 23 year practitioner I agree with the changes. Our team currently has four CFP® professionals and two more will soon be added. The current process is cumbersome and archaic. We hope the new is less burdensome.

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    GREGORY M. PINTER, CFP®

    Date: September 6, 2011

    Subject: Comments on Proposed Revisions to CFP Board Experience Requirement

    I've recently reviewed the proposed revisions to the CFP Board experience requirement. I'm generally in favor of most of the proposed changes, however, I would take issue with changing the allowable attester from any professional with acceptable designations / licenses to only a CFP® professional.

    My opinion is based on my personal experience in going through the certification process last summer. I work in a small office that currently does not have any other CFP® professionals. Therefore, I used our senior advisor as my attester. He is a CLU, ChFC and has 40 years of experience in the financial planning business. In my opinion he is more qualified to attest to my abilities than many existing CFP® certificants. While I do know a handful of other CFP® professionals, I have not worked with any of them closely and therefore under the proposed change I would have had to pursue a relationship or ask a favor of someone who has no idea what I am or am not capable of. That does not make a lot of sense to me. Therefore, I do not see any real positive that would come from this change, and potentially some negatives in a situation like mine. My vote is to keep the attester provision as it currently is.

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    KENNETH L. PIPKIN, CFP®

    Date: August 19, 2011

    Subject: Proposed Revisions to CFP Board's Experience Requirement

    I think it is a good idea to shorten the qualifying time, however, rather than the 10 year (5 and 5) proposal, it seems to me that an 8 year window (3 and 5) would be better.

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    KELLY RACH, CFP®

    Date: August 22, 2011

    Subject: Experience Requirement Change Feedback

    I like everything proposed except for the switch to 2 years of personal delivery. Everyone else has had to complete 3 years, why loosen up the requirements now? As someone who passed the test right out of college and had to wait three years, I don't think it should be changed. However, like I said, everything else is reasonable and only improving the standards and requirements to which we are held.

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    J. ROBERT REYNOLDS, CFP®

    Date: August 19, 2011

    Subject: Change in CFP® Certification Work Experience

    I concur in the changes recommended regarding the work experience required to obtain the CFP® designation.

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    JOHN C. RICH, CFP®

    Date: August 18, 2011

    Subject: Experience Requirements

    I have read and understand the recommendations of the CFP Board Committee in regard to the new proposed Experience Requirements. I concur with the Committees recommendations as they appear well thought-out and sound.

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    JAMES M. ROBINSON, CFP®

    Date: August 19, 2011

    The changes look good and should further the credibility of the "MARK" and programs. Please be sure the internships and practicums opportunities are real and not attempts at cheap or free labor or ploys to sell insurance and annuity products.

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    PENELOPE CAROL ROEDER, CFP®

    Date: August 19, 2011

    Bad idea. CFA is 5 and if we want to be taken seriously, THAT should be our point of reference.

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    FRANK J. RUFFING, CFP®

    Date: August 18, 2011

    Subject: Experience Requirement Change

    Lopping a third of the required prior experience will make it easier for the Board to gain new registrants, though the change may cheapen the credential.

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    KYLE S. SCOTT, CFP®

    Date: August 19, 2011

    Subject: 3 Years Experience is Too Little for CFP® Certification Yet Alone 2 Years

    I am wholeheartedly against lowering the experience requirement to 2 years from 3 for those offering financial planning services to clients. All this will do is dilute the strength of the CFP® mark. I would recommend going the opposite direction and requiring 5 years of experience in the field and/or 5 years experience offering financial planning services to clients.

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    ALAN B. SEGAL, CFP®, CIMA®

    Date: August 19, 2011

    Subject: Experience Requirement

    My feedback is to agree with all the revisions under consideration, with one modification. I think the experience requirement for client-facing service should remain at 3 years. I could argue it should be longer for supervisors, support and teachers, but won't.

    My rationale is merely to point out that which most of us with any length of tenure already knows: it takes a good 5 years of experience for an advisor to really develop into a sound, well-rounded, competent advisor.

    Since the objective of the designation is to help the public identify the more trained and (hopefully) competent advisors, I think shortening it to 2 years is counter-productive. Final point: most advisors spend the majority of their time in the first 1-2 years of their careers on marketing.

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    SHASHIN G. SHAH, CFA, CFP®

    Date: August 22, 2011

    My name is Shashin Shah and I have been a CFP® professional since 2002. I taught for the Kaplan CFP® Certification Review for 6 years and am currently a Subject Matter Expert for IMCA.

    While I agree with the bulk of the changes, there are a few that I would recommend reconsidering in my opinion:

    • Attester- I believe the attester should remain a CFP® Professional. In order to maintain community in the profession, it may avoid some potentially unscrupulous advisors from seeking the designation. Furthermore, I believe the attestation should be prior to the candidate taking the exam, much like Medical or Law School.
    • I also believe current experience should be a factor. We should invite planner in who wish to practice and not to have "letters behind their name" as an option to enhance resumes.

    Definition of Work Experience:

    • The definition of a client is debatable. I believe there should be a distinction between a paying "client" and a probono client. BD's will not differentiate the two.

    Thanks for your hard work and we appreciate the diligence of all involved to better our profession.

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    JENNIFER SMILJANICH, CFP®

    Date: August 19, 2011

    Subject: Comments on Revisions to Experience Requirement

    I agree that tightening the qualifying window for experience to a 10 year window from a 15 year window is appropriate. However, I disagree with eliminating the currency requirement. It seems to me that someone who is trying to meet certificant standards should either be currently practicing or intending to currently practice in the field.

    I disagree with reducing the number of years required to complete the experience requirement to two if personally delivering planning services. In practice, and based on my own experience, I believe that three years is a reasonable time for someone to gain some proficiency in the field. Likewise, in other discipline areas, such as engineering, a three year experience requirement is the standard for achieving similar professional designations.

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    CRAIG SMITH, CFP®, ChFC®

    Date: August 24, 2011

    Subject: Proposed Experience Requirement Changes

    To be clear: I am in favor of retaining the current three-year requirement for all CFP® practitioners.

    If the Board moves to the 2 year standard you no longer distinguish yourself from the also-ran designations (including ChFC, which I also hold)

    If the Board moves to the 2-year standard AND allows for internships, practicums and the like to qualify as "experience" you will have young (22, 23 year old) "wet behind the ears" individuals with one year (or less) of true, independent work experience. That is a disservice to the existing CFP® practitioners AND more importantly a disservice to the public. This comment is from a 31-year old with four years of hands on client experience who still feels like there is so much more to learn to fully support my clients' needs.

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    WHIT STEGALL

    Date: September 14, 2011

    Subject: Experience Requirements Comment

    Increasing barriers to entry to an individual's greater education and service to the public could NOT be better for the public in general.

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    DAVID F. STREGE, CFP®, CFA®

    Date: August 26, 2011

    Subject: Comments on Change of Proposed Experience Requirements

    The proposed changes for the experience requirements for a professional to have the right to use and display the CFP® marks seem appropriate to make sure the public is properly served with appropriate financial recommendations. The change of having teaching only counting up to 2 of the required 3 years seems to make sense, but there is no directly expressed rationale for this change. I agree that all CFP® professionals should have some direct working knowledge of how to develop financial recommendations for individuals. If a teacher wants to use the CFP® marks then they teach financial planning topics for at least 2 years and must either through self-employment, pro-bono or employment get the other required year of experience. You will likely get some push back on that being difficult to fulfill. So I would recommend that the working groups' rationale for this be expanded.

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    CAROL J. SUTTER, CFP®, ChFC

    Date: August 24, 2011

    Support for New CFP Board's Experience Requirement

    I would just like to comment that I like how the new proposal reads and fully support it as written.

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    SCOTT SWANSON, CFP®

    Date: August 19, 2011

    I have proposed in the past to the ICFP and the FPA that it should be an obligation of our profession to help develop, distribute and maintain educational programs that advance the public's knowledge of the principals of Financial Planning. To this end teachers, qualified to teach Financial Planning principals, should become a member of the professional "Financial Planning Community." If this concept is ever accepted by our profession it will be necessary to develop "experience requirements" for teachers.

    Background

    When I was a member of the ICFP Board and a Director on the Board for Harris County Extension, I introduced the Extension Service to the College of Financial Planning in the 80's to promote Financial Planning education in High Schools. Through the efforts of Dr. Bill Anthes this concept was advanced. Financial planning curriculum was developed by the College and later NEFE and then distributed to high schools through the Extension Service. This effort has been expanded through the efforts of Brent Neiser and NEFE. I believe it is time to consider certifying teachers to educate the public in the principals of Financial Planning and make them a part of the profession.

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    CAROLYYN TOMIN, CFP®

    Date: August 26, 2011

    Comments on Proposed Work Experience Changes

    The changes you are proposing are very well considered and fair to both candidates and the public, and are an improvement over the current work experience requirements. Although the length of full time work has been shortened, the new 2 year experience requirement is appropriate and sufficient, and should not adversely affect the public's ability to receive competent advice and planning from new CFP® practitioners.

    I believe that the quality of education has improved due to the new capstone course requirement, and that the certification exam is now placing stronger emphasis on the integration and application of financial planning, so that a 2 year work experience requirement in conjunction with these other improved and strengthened certification requirements makes perfect sense at this time.

    There is still one part of the proposed definition that has not been changed, and frankly, has never made any sense to me.

    Definition of Work Experience

    CFP Board's work experience requirement is defined as the personal delivery, supervision, direct support or teaching of all or part of the personal financial planning process to a client.

    This implies that teaching is acceptable when teaching "to a client" when you mean teaching to students in a registered program, as you have clarified elsewhere in the proposal. This could be re-written to say:

    CFP Board's work experience requirement is defined as the personal delivery, supervision or direct support of all or part of the personal financial planning process to a client, and/or the teaching of financial planning subjects in a registered program.

    My thanks to all the committee members who have put together this solid proposal, and thank you for considering my comments.

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    SCOTT A. TRAMMELL, CFP®

    Date: August 19, 2011

    I believe that reducing the experience requirement for "personal delivery of financial planning services" is a mistake. Even with "CFP® professional supervision or peer review required," 2 years is NOT enough time for a new advisor to gain enough experience to be able to use the "gold standard" designation of our industry. I believe that this would be an ill-advised move for the CFP Board and would cheapen the CFP® designation. I encourage the Board to leave the current 3-year requirement for this category in place.

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    HARRY S TRUMAN, CFP®, AEP®, CLU

    Date: September 7, 2011

    Subjecy: Amdedment to Experience Requirement

    I would suggest holding the line to three years for practitioners. It would appear to be lessening rather than strengthening the CFP® certification standards and, if we are to be held to a higher standard than the unlicensed "financial advisors", our standards should be maintained at a higher standard for our CFP® professionals. The desire is obviously to gain more licensees yet there is a delicate balance between maintaining high standards of conduct and easing of eligibility for entry to use the mark. Just my opinion.

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    CARLENE TUCKER, CFP®, FICF

    Date: August 19, 2011

    Subject: Proposed Experience Requirement Changes

    I do not think that shortening the requirement to two years for practicing applicants is a good idea. Three years is a relatively short time to learn a business as complex as this one.

    I do not think that three years of "teaching only" experience is adequate. There is a good argument to be made that at least some amount of experience in actual practice should be required. Teaching is very different than doing; the information is often provided to those teaching and the same material may be taught for three years in a row. In practice an individual has to be able to find the needed information on their own and stay up to date with a constantly changing environment. Those who are teaching only should probably require 5 years experience. A combination of teaching and actual practice, with at least one full year of practice should be the bare minimum.

    I do agree with tightening the window to 5 years before and after. This business requires that one's knowledge be current. The rules and planning environment are very different today than 10 years ago. Experience that is that far back is probably not very useful today if the individual has been removed from this field for that long.

    If all the experience were within 5 years I think that 6 months within 18 months or 2 years would be acceptable.

    Internships, residency programs, etc. are certainly valuable but the need for actual hands on planning responsibility is essential to preserving the integrity of the designation.

    I can understand the need to broaden the membership but doing so by lowering the experience requirement is a bad idea in my opinion. Successfully educating the public of the need to seek out a certified planner will increase the demand for designees. When the demand comes from the client community the membership growth will be there.

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    MARVIN W. TUTTLE, JR., CAE
    EXECUTIVE DIRECTOR/CEO, FINACIAL PLANNING ASSCOCIATION

    Date: September 19, 2011

    Subject: FPA comment

    The Financial Planning Association® ("FPA") is pleased to submit its comments to proposed Revisions to CFP Board's Experience Requirement (the "Proposal"). We fully support the basic premise of the Proposal: to align the CFP Board's Experience requirement more closely with the current and expanding professional practice of personal financial planning. However, in the absence of explanations as to the particular reasons for the changes in the Proposal, our ability to comment on whether the changes effectively accomplish your goals, or not, is limited. Nonetheless, we would like to raise some specific issues and questions.

    The first issue is the reduction in the experience requirement for certification. The CFP Board proposes to reduce the experience requirement for full-time personal delivery of services from three years to two years. We believe that the three year experience requirement is a reasonable and appropriate standard for planners to gain practical experience. A robust experience requirement is important: the last decade has taught many lessons that could not be learned in a classroom or from a book. In addition, it separates the CFP® certification from other certifications. If we understood the reasoning for the reduction we might be able to support the change, but without the reason we do not know if we can support the change.

    We understand the challenge faced by self-employed planners who need to obtain experience. However, we are concerned about the ability of a non-supervising CFP® certificant to attest to the planner's work. As a non-supervisor, the CFP® certificant may not be able to attest to the quality of the planner's work. Yet if they are only attesting to the quantity of work, this creates a perverse incentive to become a self-employed planner to avoid oversight of the quality of your work. It is also not clear what the effect of this would be on a planner who works for an accounting or other firm without CFP® certificants available to supervise the planner. Can they have an outside CFP® certificant attest to their work even if they are not technically self-employed? If not, what is the reason that they should be treated differently from a self employed person?

    We ask for clarity in the amount of teaching that can be used to satisfy the experience requirement. In the paragraph, "Required amount of experience", it states that three years of teaching is enough to satisfy the experience requirement. Yet in the "Types of Experience" section, this is limited to two years. Members of FPA's academic community are concerned that the CFP Board may be limiting the amount of teaching that can be used to satisfy the experience requirement through three years of teaching. They point out that most full-time faculty do not have the time to have a practice on the side and most practitioners do not have the time or skills required to do research. Again, without an explanation for the reason for the change, it is unclear why two years are acceptable for the three year requirement but not three years. Our members fear that this change will reduce the research and teaching in CFP Board related topics that continue to be necessary to the profession.

    In summary, FPA strongly commends CFP Board for looking at the certification process and we appreciate the opportunity to comment on the proposal. However, we would like to better understand the reasons for the changes and then comment further before the CFP Board makes the rule final. On behalf of FPA, we would be pleased to respond to any questions or comments that you may have.

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    RALPH UJANO, JR., CPA, MS, CFP®

    Date: August 18, 2011

    Subject: New Work Experience Requirements

    I appreciate the direction, especially the requirement that it be done under the purview of a CFP® professional. Given the serious nature of our role I still believe the three years required experience is vital as well.

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    EVOR C. VATTUONE, CFP®

    Date: August 19, 2011

    Subject: Work Experience Requirements

    I feel that the proposal is agreeable and that the "direct experience" (client interfacing and planning/analysis/recommendation, etc.), should count more heavily towards "experience" than associated activities such as teaching or being in para-planner type of position. As an owner of a practice, I really felt more comfortable and confident in delivering truly great advice to clients after 2-3 years of experience. I believe it's really the comprehensive nature of the planning experience with real people and situations that is the best teacher…not just one segment of a plan or doing associated work.

    The one thing I'm not sure about is the amount of time. I think it should be 3 years of "direct" experience and 4 years of associated experience. If supervised, I think it should count towards the 3-year requirement as long as the candidate was involved in ALL aspects of the financial plan and not just certain segments.

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    JOHN H. WELLFARE, CFP®

    Date: August 19, 2011

    Subject: Experience Requirements

    I am in favor of two things in the proposal: One is the wording about "delivery of financial planning services to clients" vs. the older, rather nebulous requirements. Second is the reduction of time of performing these actions to two years.

    A beginning CFP® professional is like any neophyte in a profession: He's got the tickets but he's still confined to the cheap seats. In other words, his knowledge, perception, foresight, understanding, techniques and creative professionalism will take years to develop. If I was not still learning in this business I would give it up. We are all a Work-In-Progress in the profession. I have long felt that 3 years was a bit unreasonable before full certification is granted and the marks allowed to be used. If someone has been under direct supervision by other CFP® professionals in providing financial services to clients, and the person has been deemed as competent in that area, two years should be an adequate experience level. And within that 24 month period he also has to complete the CE requirements, so like all of us, he or she is still growing.

    It's a good change.

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    ELIZABETH L. VERTERANO, CFP®, CRPC®

    Date: August 18, 2011

    Subject: CFP® Certification Changes

    I support the changes you have suggested.

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    MICHAEL WEISS

    Date: September 19, 2011

    Subject: Work Experience Requirement

    I would like to take the CFP® exam but I have concerns about not meeting the current or proposed work experience requirements. My recent experience as an investment analyst was not client facing. I would not meet the rule regarding six months experience out of the prior 12 months. I believe I have three years of acceptable experience. Within the past 10 years, I worked as a portfolio manager for Evergreen Investments for roughly three years and then managed money as an independent investment advisor for another three years. At Evergreen, there was a trust advisor in between me and clients. However, I was not the primary relationship manager. I am also a CFA charterholder.

    Under the proposed changes for work experience, I would benefit from the elimination of the 6 month rule but reducing the prior experience window to 5 years would make it impossible for me to get the designation immediately. To be honest, I don't want to devote the time and cost to studying, if I can't get the designation.

    Do you have any thoughts on this?

    I would like to make one more point. In my opinion, the current structure does not welcome anyone who is not currently working or anyone who is considering a career change. I am sure you must know that in this economic environment, getting a position such as a financial planner would be very difficult for many people who do not have the CFP® designation.

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    ERIC J. WHITE, CFP®

    Date: August 19, 2011

    Subject: Work Experience Feedback

    CFP Board's currently accepts work experience that involves the supervision, direct support, teaching or personal delivery of all or part of the six-step personal financial planning process to a client.

    CFP Board,
    The above sentence was in the description of allowable work experience for individuals to qualify for CFP® designation. I am not sure what the correct path should be but I believe the focus should not be on how many designations can we give out in a year but more along the lines that the individuals who do obtain these credentials have actual hands on experience in planning with individuals. I do not believe the category of "direct support" would make me comfortable if I were in the general investing public that just because someone was in a direct support field that they are then competent to guide a client through the entire process of financial planning and give qualified advice without having actual advisory experience. I think there should be some requirement that a person have an actual advisory role with clients (not teaching) to be certified.

    As an analogy if you were going to have heart surgery would you chose your surgeon based on actual experience or someone who has a certification but who has only been in a direct support role or teaching for the last ten years. I know who I would choose. So as a CFP® professional and having been advising clients for over 15 years I am more concerned with the quality of work done by CFP® professionals than the overall number of the pool that holds this designation. These comments are my opinion only and do not reflect any opinion of my firm/company.

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    KENNETH YOUNG

    Date: September 9, 2011

    Subject: I Vote to Lessen the Req's

    I say look to CPAs and attorneys for general guidance on this matter. Depending on the state, both typically require no work experience to be certified/licensed; though some states require one year work experience.

    Remember, current CFP® professionals who make their living as such want as few CFP® professionals as possible to minimize competition. Those who seek the degree want the req's loosened. For those on the CFP Board, probably the best course of action is a "balance" of the two interests.

    The biggest criticism by CFP® professionals of loosening the requirements is that a newbie lacks the experience to do everything well. That's true. In the accounting profession, everyone knows a newly minted, 22 yr old CPA doesn't know everything. But within a year or two, he'll know enough. Should he be called a "CPA candidate" for 2-3 years? Well, not doing so has not hurt the designation one bit.

    Clients won't turn everything over to a 22-yr old CPA. Nor should they. Clients also won't turn everything over to a 22-yr old CFP. Nor should they.

    Certifications aren't magic; they are merely an indicator of education and work ethic. Experience comes with time. If you continue to set the bar higher than both the CPA and attorney licenses, the number of CFP® professionals will continue declining dramatically as those who qualified back when it only required a simple exam retire and are not replaced by new ones under the current, super strict standards.

    I considered pursuing a CFP® certification to move more into financial planning. But the work requirements changed my mind. I know a substantial number of CPAs and attorneys who've made a similar decision. Along these lines, I also don't think your brand would be weakened by allowing a waiver of the work requirement for "licensed" attorneys and CPAs. On the contrary, the added visibility would likely strengthen the CFP® certification brand and insure its ongoing relevance.

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