Certified Financial Planner™ (CFP®) is the marquee designation/mark for the investment advisor/retirement planning industry. The CFP® board demands those given the mark adhere to their education, experience and fiduciary/ethical standards. On the CFP® Let’s Make a Plan/Find an Advisor website, the words “trusted advisor” and “fiduciary” are prominent. In fact, those in this field who don’t carry the mark do so at quite a disadvantage. I’m one of those, and I’ll explain why.
Strict regulatory and compliance oversight are essential in the financial services field. It’s rife with opportunity to take advantage of people – the industry is primarily about money, right? The Bernie Madoff, Vantage, Wells Fargo, Bradford Bleit, and other scandals were huge black marks for trust in the industry. Bleit admitted to using his CFP® designation to gain a false sense of trust in those he defrauded. One of Morgan Stanley’s top advisors kept his job despite his egregious behavior. There aren’t many lower forms of life than those who would take advantage of people who are struggling, and they deserve to pay a price for that.
The cost associated with belonging to various organizations is important to consider. I started my first company, Money Coach Group, Inc specifically to rescue folks who were on the brink of foreclosure, bankruptcy, repossessions, and other financial nightmares – often caused by or exacerbated by predators in the lending, credit repair, timeshare, or other areas of this industry. We had to keep our overhead razor thing to be inexpensive – those clients had no money. We did a lot for free, out of our driving primary mission of altruism, because those folks had often been victimized.
I moved into investment advising/financial planning with Emancipare, because although there are many great financial coaches/counselors, there are few in the planning/advisory area that are inexpensive and driven by altruism, rather than profit. As a person of a certain age who has lived and studied in this field my entire life, I took and easily passed the Series 65 exam and obtained my registration/license as an Investment Advisor Representative and opened Emancipare, my Registered Investment Advisory. I immediately began considering a CFP® designation.
As a person that has worn many hats in my life (scuba divemaster, writer, IT engineer, finance) I’ve seen that every industry has its associated designations and organizations that derive income by pushing those designations as social proof of one’s expertise. They make money by selling classes, annual renewals, advertising, conferences, merchandise, and other related endeavors. There are hundreds of designations in the personal finance space alone! This out-of-control “credentialism” is a cash cow for the organizations that provide them, and often get them away from their mission and more toward generating income for bloated compensation for board members, making them more income-driven and political in the process.
Don’t get me wrong. When done right, these are useful, especially for those who are young, without yet having extensive experience and legitimate social proof in terms of unbiased reviews/ratings/client testimonials. Even though I had all those things, when I started Money Coach Group, I got accredited by and joined the Association for Financial Counseling & Planning Education® (AFCPE®) as an Accredited Financial Counselor (AFC®). I vetted them and found their mission to be truly altruistic and their fees quite reasonable. I remain a member for that reason.
When I opened Emancipare, since the CFP® designation was such an overwhelming presence in the field, I explored it, and decided not to proceed. My reasons are as follows, broken out by the facets of membership benefits and other criteria.
Relevance. Obtaining CFP® would involve a great deal of time studying in areas that are not relevant to my mission at Emancipare. We are a low-cost investment advising/financial planning company that serves working people, not those in the ultra high net-worth sector. Our mantra is to keep investments simple – dollar cost averaging into just a few low-fee index fund ETFs that are correlated to the client’s risk tolerance, income needs, and time horizon. We don’t do options trading, alternatives, crypto, cash-value life insurance, annuities, or complex estate planning. The time and expense spent to develop expertise in those areas just to pass the CFP® exams would be wasted, and have an impact on our ability to serve our real clients and our rates.
Cost. Speaking of the above (our rates), the CFP® cost would add an ongoing burden for us financially, which as in any business, is passed on to the clients. You want me to pay a thousand dollars to take your test, and have to pass that on to my clients?? We don’t have a fancy office or expensive cars. We keep our costs razor-thin so we can charge rates working people can afford. CFP® fees are high, and ever-increasing, much to the chagrin of the community. There is a lack of transparency as to how their vast income is spent on salaries, bonuses, and marketing. Some board members aren’t and have never been CFP®s or financial advisors, meeting minutes aren’t made public, and they don’t have open elections for directors (Grillo).
Fiduciary. The CFP® board has an increasing emphasis, and, some would say, influence by the insurance industry. I feel that most insurance products such as deferred/variable/indexed annuities and whole life policies are overly complex, expensive, and a poor fit for the customers they are pushed on. Around 70% of CFP® members hold insurance licenses. Insurance products aren’t regulated by the SEC and advisors don’t have a fiduciary standard when selling those products (other than variable policies).
The same goes for the fee model that most advisors use to charge clients for management of their assets – the percentage of assets under management (%AUM) model. It’s deceptive in that the fees are often hidden inside or not even disclosed in the statements for the investment accounts they’re taken from, and most clients have no idea what they’re being charged. If they did, many would run.
I’m part of a growing new community of transparent, flat-fee, fee-only, truly fiduciary advisors who make our pricing clear and consistent to clients. We feel the %AUM model is not in the fiduciary best interest of our clients, it is against the fiduciary obligation we hold, because it charges some clients more just because they have more. In some complex cases, %AUM is a good fit, but those are a small niche of the client universe. The industry and regulatory/compliance organizations have allowed the terms fiduciary and fee-only to be obfuscated and blurred with designations like “suitable,” “best interest,” fee-based, and fee-offset. They confuse and lure clients who just want transparency and honesty. Much of that is on regulatory bodies like the SEC, FINRA, and Department of Labor, but the CFP® board should wield its power to do something, rather than go along. Transparency advocates such as Michael Kitces and Alan Moore, co-founders of the XY Planning Network for independent advisors, have filed suit against some of this activity.
Ethics. The CFP® board spends millions of dollars on marketing, but not enough on enforcement of its core mission of providing clients with “trusted advisors.” The CFP® marketing suggests its members are more ethical and trustworthy than non-members, and adhere to a higher standard than the regulatory agencies. But the CFP® board only asks that members “self-report” any misconduct, and of course, few if any do so. The CFP® board doesn’t check for misconduct (Zweig, Fuller). This was the subject of an expose in a 2018 Wall Street Journal article. There are still thousands of CFP® members with disclosures who show up on their CFP® profile as having no disclosures, and members are rarely disciplined by the organization (Grillo).
Education. To keep a CFP® designation, you must do continuing education. This is a good thing, and also a requirement to hold the AFC®. If you are a dedicated, passionate professional, it’s just something you do by nature. It’s hard to remain competitive and profitable without keeping up with the fast-moving changes in personal finance. It’s likely that the SEC will require those who hold investment advisor registration to fulfill a yearly education requirement, and I hope they do.
CFP® training and designation are great for newer, young advisors without a record of experience and delighted clients. Chris Mamula of caniretireyet.com has recently posted on the many benefits of obtaining the CFP® mark. This is a contentious topic, as witnessed by two feisty debates held by Sara Grillo (a leading financial advisor marketing consultant) on her blog/podcast.
Not having a CFP® designation hurts me in some ways. Many of the organizations that help clients find their best match in an advisor/planner require it, unfortunately. You can join some of them, but only as an ‘associate’ or some such, often without important member benefits that make the cost worthwhile. Wealthtender is one that does not discriminate in this way, so we’re happy to be a member.
As well, after doing this work for so long, and with the points made above, it just doesn’t seem like a good use of my money and time. I am already held to a very strict ethics, fiduciary, and knowledge standard by the AFCPE, SEC, FINRA, and the states that I’m registered in. More importantly, I’m held to that standard by my own personal code of ethics and conduct, which far outreach the regulatory ones. The client reviews at Money Coach Group and Emancipare speak to that, and it’s good enough for me. Now that the SEC’s testimonial rules have been relaxed, it should make for an easier barometer to gauge good from bad.
For those seeking financial advice/planning, my advice is to not make your decision or put too much emphasis on a bunch of letters after someone’s name. Do some research. Check their social media, Google/Yelp profiles and reviews, and most importantly meet with them, interview them, make sure you’re comfortable with who they are and what they offer. Ask these questions:
- Are you fee-only, flat-fee, fiduciary, and have transparent pricing on your website?
- Do you use the complicated, expensive percentage of assets fee structure for managing assets (AUM) that charge you more just because you have more?
- Do you sell any products, insurance or otherwise, or recommend investments that earn you a commission or any other kind of revenue?
- Does your inexpensive or free retirement/financial plan require me to be signed up for the above?
- Be careful of people that call themselves misleading names (counselor, coach, associate, etc) that aren’t real advisors. Many are insurance people trying to sell you very complex, expensive annuities, permanent/cash-value life insurance, and other products. A registered advisor will be required to provide you with their ADV form. Make sure to read it!
In closing, the scary thing for me is that the CFP® board seems to throw its weight around with an expressed desire to become the de facto and required agency for financial advisors and planners (Grillo). I hope the day never comes.
Camarda, Jeff (2019, September 23) Forbes. America’s Broken Financial Advisor Promise – What’s Wrong with the CFP Board & Why You’d Better Check Twice Before Trusting a Certified Financial Planner https://www.forbes.com/sites/jeffcamarda/2019/09/23/americas-broken-financial-advisor-promisewhats-wrong-with-the-cfp-board–why-youd-better-check-twice-before-trusting-a-certified-financial-planner
Flitter, Emily (2018, March 28) New York Times, Morgan Stanley Knew of a Star’s Alleged Abuse. He Still Works There. https://www.nytimes.com/2018/03/28/business/morgan-stanley-douglas-greenberg-financial-adviser.html
Grillo, Sara (2022, September 12) Should you cancel your CFP designation? (heated debate!) https://saragrillo.com/2022/09/12/cfp-designation/
Grillo, Sara (2022, September 26) Should the CFP Board police financial advisor “bad apples”? The debate continues! (Part Two) https://saragrillo.com/2022/09/26/cfp-board/
Zweig, Jason. (2022, November 4). Wall Street Journal. You Don’t Know What You Don’t Know About Your Financial Adviser https://www.wsj.com/articles/financial-advisor-disclosure-regulations-adv-11667576312
Zweig, Jason, and Fuller, Andrea. (2019, July 30). Wall Street Journal. Looking for a Financial Planner? The Go-To Website Often Omits Red Flags https://www.wsj.com/articles/looking-for-a-financial-planner-the-go-to-website-often-omits-red-flags-11564428708
Trone, Don. (2017, July 11). ThinkAdvisor. ‘Just Say No’ to CFP Board’s New Standards. https://www.thinkadvisor.com/2017/07/11/just-say-no-to-cfp-boards-new-standards/
Weisman, Robert. (2009, January 20.) Boston.com. An earlier Ponzi pain lingers. http://archive.boston.com/business/articles/2009/01/20/an_earlier_ponzi_pain_lingers/