Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
On August 17, 2012, CFP Board issued a request for comments (PDF, 73KB) on proposed changes to the Continuing Education requirement for
CFP® certification. The deadline for submitting comments on these proposals was September 30, 2012.
The individuals and organizations listed below responded to CFP Board's request for comments by providing comments regarding proposed
changes to the Continuing Education requirements between August 17 and September 30, 2012. The content of each comment is available for
review below. CFP Board accepts no responsibility for the content of the comments.
Name
Jeff White, CFP
Subject
®
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Comment
I find these changes abhorrent.
1. Most course work is WAY behind the times and what i need to learn I must learn on my own - and THEN take
additional CE to meet these requirements. To waste additional time on this requirement seems absurd to me.
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2. Many good CFP [professionals] focus on one area - to limit their CE to no more than 50% seems particularly
unhelpful.
Aaron Oberlin, CFP
®
®
Proposed CFP
[Certification] Requirement
Changes
Increasing CE credits to 40 from 30 and raising Ethics to 4 credits are misguided ideas. I find CE as required hours
going over things I already know. CE on actual new information would be more like 6/yr – every year. Ethics is basic
and learned in one session. Taking it over and over for years is aggravating. Sit thru one the guy at Royal does and tell
me you are looking forward to another 2 of that in two more years. After basic training it is integrity of the individual
which will not likely be changed by an added 2 hrs requirement.
Probono credit makes a lot of sense and supports communities. Requiring only those “supervised CE sponsor” would
render the concept of credit meaningless to many (or most?) as not having one available. I have taught Dave Ramsey
classes and done other probono counseling that should certainly qualify regardless of a CE sponsor.
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There needs to be a lot more work, or at least more effectiveness, on CFP [mark] brand awareness, not more CE
requirements. How does that get rolled into the thinking here?
Aaron Gutierrez, CFP
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Adam P Rivituso, CFP
®
CE Changes
I think it's fine the way it is. I am a member who is not in the planning field currently and the raised fees and changes to
CE will make it hard to keep up. I value my designation; maybe have a lesser CE and fee requirement for those of us
not in the industry but who want to maintain their mark.
CE
I would totally oppose these changes. You raised our dues to 325 dollars per year. Give our everyday commitment to
the process, I believe more is learned in actual practice and new standards. Certainly CE is for the better of the cause
but this would become a detractor for those that are pursuing or thinking of pursuing. In addition many of us pursue
other designations or education throughout our careers. Feel free to contact me with any questions.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Adam B. Obrecht, CFP
®
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Laurie Adams, CFP ,
CLU, LUTCF
Page 2 of 379
Comment
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CE Requirements
1.
I would prefer to not have the CFP [certification] move to a plan where there are topical requirements or caps.
Our state insurance has started to do this and the first renewal year this doesn’t seem to be much of a challenge but
future renewal periods have started to cause problems. Verifying that all CE vendors are reporting my CE hours
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correctly each time continues to put additional burden on the CFP Professional.
2.
Going to 4 hours of ethics seems appropriate but how does this match to other professions. I know in my state
that I am required to do 3 hours of Insurance Ethics CE which has caused issues with CE vendors offering 2 hours for
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CFP [certification] but then having to do an additional hour class for the Insurance people.
Comment of proposed regs
As a former CE instructor and life long student I applaud the effort to increase education expectations for CFP
professionals. However, I do believe the 50% Cap in a single topic area is unnecessary and potentially onerous for
record keeping.
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We should pursue education because the topic is of interest to our practice and our clients rather than to fill a quota.
We’re all adults, capable of recognizing the need to stay abreast of trends, techniques and legislation. Personal
responsibility is implied at our level of expertise and a direct reflection of the fiduciary standard we uphold.
V. Thomas Adams,
®
CFP
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Adrian Albidress, CFP ,
MBA
NO ADDITIONAL
CONTINUING ED!!!
MOST OF US IN THE ADVISORY BUSINESS ARE UP TO OUR EYE BALLS IN CE REQUIREMENTS.
COMPANY MANDATED, STATE INSURANCE MANDATES, CIMA CE REQUIREMENTS. NO MORE.
NO ADDITIONAL ETHICS REQUIREMENTS. I’M ALREADY REQUIRED BY FIRM AND INSURANCE TO TAKE
ETHICS EVERY YEAR.
STOP ALREADY!!
Continuing Ed - do not
agree
I would like to comment that the increasing of continuing ed requirements will do nothing except increase the fees
required to contunue being registered.
Those of us to pursue this career and have taken the courses and completed exams are students of the business by our
nature. We are all licensed in securities, insurance, or others in CPA work which have many additional hours of CE.
There is study required every week to keep up with the marketplace and take care of our clients. If we are going to
require more CE then the extra hours should be able to be satisfied by proof of industry training, seminar attendance,
etc. not by burdening those of us who are working hard every week with additional costs and time away from our
families.
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Aida G. Visakay, CFP ,
CEO
CE credit comment
In my opinion, I think that 30 credits every 2 years is more than enough. I feel that between all the credits that we in the
industry have to get we spend a LOT of time making sure we get them. We do need to work and earn a living
Albert J. Benneian,
®
CFP
Proposed CE Changes
This set of proposals is unduly burdensome. We are busy professionals and have more than enough responsibility on
our plates as it is without increasing the already rigorous CE requirement. It seems the members of the CFP Board’s
Council on Education might have a bit too much time on their hands to have come up with a proposal like this. This is
akin to the outrageous imposed regulatory excesses we keep hearing about coming from the government. Please back
off and let us do our jobs!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Cynthia Meyer,
®
CFP , ChFC
Subject
Comments on proposed
rule changes
Page 3 of 379
Comment
Thank you for undertaking the work updating the continuing education requirements.
While I generally agree with the changes, which in many ways encourage a more comprehensive approach to CE, I was
flabbergasted to read that you are considering eliminating credits for obtaining other professional designations!
Many financial designations require significantly more study time than the proposed "40 hour" requirement, and offer a
financial planning practitioner the opportunity to considerably improve their skills. Passing a section of the CPA, or a
level of the CFA requires hundreds of hours of study and thousands of practice questions to master difficult material.
Someone who holds a CFP designation benefits significantly from expanding their knowledge this way, and their clients
receive the ultimate advantage.
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As someone who has held the CFP [certification] designation since 2000, and has earned additional designations [such
as the ChFC] I certainly agree that the skill set required is increasingly complex. That's why it's so important to
constantly improve our skills through continued learning.
I recently passed the CFA Level 2 exam, which was extremely difficult and required about 500 hours of preparation over
nine months. The program is certainly helping my investment skills, as well as deepening my overall financial
knowledge. What would be the rational behind denying CE credit for a similar course in the future?
There are many designations that may not require such a large time commitment but certainly require more than 40
hours. Certification in philanthropic giving or small business appraisal, for example, could help planners who work with
those types of clients better serve them.
I encourage you to reconsider. Eliminating CE credit for worthwhile professional designations is a disincentive to the
spirit of your intended reform and counterproductive.
Chad Loveland,
CFPⓇ, CLU
30 hours is plenty!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Charles H. Ballou, CFP
®
CE Requirements
Page 4 of 379
Comment
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I have been a CFP [professional] since 1984 and find myself slowing down at the age 67. What I find is that there are
always new things to learn which is good because it keeps the mind young and engaged – I wish I can say the same for
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one’s body. With over 25 years of taking courses for the CFP [certification], FINRA and state insurance I have come to
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find much of the content redundant and somewhat a waste of time - I did not have this view as a young CFP
[professional] because the body of knowledge seemed almost overwhelming.
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I believe it may be time to give older CFP [professionals] a break on the CEU requirements – At the age of 67 and 42
years in the financial services business, If I do not understand the concepts of ethics I never will. I also find it ironic that
some of the regulatory groups who requires the courses in ethics do not seem to have the same requirements for
continuing education – from some of the things they say and do it is apparent that the need for continuing education is
there. –
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I am really proud that all three of my children are CFP [professionals] and that hat I started a fee based business in
1984 that serves as an family business for middle class families. While I do not plan to fully retire I also do not plan of
working 40-60 hours per week. I do believe that some type of consideration should be made for those “senior” citizen
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CFP [professionals] – we still have a lot of knowledge and experience to share, but our time and energy is not what it
once was
Thank you in advance for your consideration
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Alan J. Griffes, CFP ,
CTFA ChFC
I AGREE WITH EVERYTHING BOB CLARK, ADVISORONE SAYS. THAT IS RARE SINCE I AM A CONFIRMED
CONTRAIRIAN.
http://www.advisorone.com/2012/08/22/re-education-will-more-ce-hours-make-cfps-better-p?t=life-planningltc&utm_source=dailywire82212&utm_medium=enewsletter&utm_campaign=dailywire
I have been a financial planner since the early 1980s and was founding officer of the local chapters of IAFP and CFP
Board. For the last 15 years it seems that the CE that counts is not very interesting or helpful for my clients. The
hundreds of hours of nonqualified education that I do, does help me do my job better, but does not count for credit.
I don’t believe that more requirements help. Ethics education is useless in every industry, but practice management
could help make it relevant and useful for many.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Alex J. VonderHaar,
®
MA, CFP
Page 5 of 379
Comment
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I hope that someday the CFP mark is recognized by the legal and regulatory environment. Until that happens, my
concern relate mostly to 2 areas - the 50% cap rule and no credit for other licenses (is that for all CE coursework or just
attaining the license ?)
Like many of your other certificants, I have several CE requirements to maintain simultaneously - securities, insurance,
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CPA, CFP [certification]. I hope to emphasize those courses that count for multiple designations. The alternative
would be to spend more than a week each year on maintaining designations in addition to the training I receive that
earns no CE credit.
If employment status eventually becomes jeopardized due to excessive revenue-producing time being shifted to
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certification maintenance, some certificants could be forced to drop designations not required by law (CFP [mark]) in
favor of keeping licenses and designations required by broker-dealers.
Given that, I am OK with increasing to 40 hours per biennium provided that our freedom to choose topics and doublecount coursework across multiple CE jursidictions would not be infringed upon. It may help to make it easier to get
courses & meetings approved for CE credit.
Alexandra Armstrong,
®
CFP
think all the proposals are good, particularly the one giving credit for pro bono work! Thanks for including them among
your changes.
I am sure some will have objections to some of these proposed changes but as you comment our profession requires
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keeping up with fast changing information and I think [CFP professionals] needs to be required to meet a higher
standard.
Alistair Kelly, CFP
®
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If your goal is to reduce the number of current and potential CFP Practitioners then by all means keep going. It is
readily apparent to even the most naive CFP- [professionals] that the folks at "The Board" have a lot of time on their
hands and have no concept of the time spent on resolving actual issues our clients face. One of my business owners
said it best - "Business owners now have to satisfy an 'increasingly hungry for power' government before then even
consider satisfying their clients' needs". This proposal prompted me to remember that comment from such an astute
businessman. "The Board" is, of course, the government in this analogy. I am certain that "The Board" can rationalize
any proposal put forth as being in the clients' best interest but I guess if they didn't then they would have to rationalize
their own very existence.
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I still feel like a 2nd class professional because we are NOT CFP [professionals]. We are CFP "Certificants". Sounds
pretty professional to me.
You asked for input. I just gave mine. I say thumbs down. 'The Board" is, and has been, misguided.
I renew in September and I will pay the "Public Awareness" fee because I have no choice. I challenge "The Board" to
quantify it's positive influence on me and my practice when I live in such a small town.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Chris Amon, FSA,
®
®
CFP , ChFC, CRPC
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Page 6 of 379
Comment
I like almost all of the recommendations - however I do feel that CE should be granted for additional designation
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licenses. I've found that the ChFC or CPRC have a lot of over-lap with in material with a CFP [certification].
Also, I would like to see an extension what would include for CE. Seminars/annual meetings/group study are great ways
to get CE.
Lastly, having on-line CE available is a practical necessity. With busy schedules, FAMILY TIME, work time, etc..
sometimes the only choice is to take a night class.
John J. Anderson, CFP
Andrew J. Head, CFP
®
®
Please do not raise CE hours.
CE Changes
I am in favor of all of the proposed changes with the exception of allowing CE credit for Pro-Bono work. I understand the
desire to increase pro bono work for the public benefit, but is it truly beneficial when an individual is choosing to do pro
bono work because of the CE credit? In other words, either he or she wants to serve the public in a truly pro bono
fashion, or they do not. If the tipping point is that they receive CE for the service, then I would rather they stayed home!
This also means that for those of us already doing this type of service, we would have to do less CE, if the required
hours were to stay at 30. Even with the increase to 40 hours, those doing pro bono work get a pass for 4 of those new
hours.
Andrew Massaro, CFP
®
Please don't!
40 hours is too burdensome.
I’m an established practitioner. At this point, the designation doesn’t make a difference in my practice. If the hours are
increased, I will most likely drop my designation at the next renewal.
Andrew T. Graybar,
®
®
®
CFP , CLU , CRPC ,
®
MBA, ChFC
Angie Secolo, CFP
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Anthony C. Pesce,
®
CFP , CLU, ChFC,
CLTC
more CE hours
No, thanks.
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I get the impression that the paid staff and the academics (non CFP [professionals])
don't realize how much training goes on, constantly, and how much
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reading CFP [professionals] do, regularly, for licensing purposes.
30 hours of CE is enough, in view of the above.
Keep the 30 hour CE
I think 30 hours is sufficient.
Proposed revisions.
Please consider and remember that not long ago (in the last 2 years) the board changed the number of credit one
earned when taking an American college class.
which in reality added taking more classes credits to reach the required
number of hours. I can't understand why that was done - when you
actually learn something from an American college class VS. these on-line one credit deals.??
But what do I know???
My only question is are these changes necessary and justified or just politics?
Also, I also did not realize that the fee is now every year VS. every 2 years!!
What was the reason for 100% increase??
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 7 of 379
Comment
Anthony V.
®
Mancuso,CFP
Changes to CE
requirements
The changes to the number of hours both in general and for Ethics I believe is unwarranted. It is already difficult enough
to accumulate the hours given the fact many of us also have to meet requirements for various other licenses and
certifications. I feel the change would be costly as well as difficult to meet. The other changes that are proposed I
believe may be beneficial.
Arthur R. Werner, CIC,
®
CFP , PWCA
New CE requirments
I fell that the current requirements are more than sufficient and increasing the requirement will cause economic
hardship.
Comments on proposed
CE changes
Thanks for the opportunity to provide input. Here are my comments:
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Artie Green, CFP , MBA
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.- OK
Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period. 1 hour CE credit per 4 hours pro bono service. - Good idea but I'd suggest at least 2 hours CE per 4 pro
bono, if only to encourage more pro bono activities.
Increasing the Ethics CE requirement from 2 hours to 4 hours.- OK but only if you provide multiple avenues for planners
to get the additional training. Cost needs to be moderate and availability needs to be broad.
Expanding the professional activities that qualify for CE credit - OK
Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours.
I see some issues with this:
1. What if a planner specializes in only one area (e.g. investments or education)?
2. Are there enough offerings in enought different topical areas available in the marketplace today?
3. Can a particular seminar qualify for multiple categories? If so, would the planner have a choice in how he/she
categorizes it?
Eliminating CE credit for completing professional licenses and designation examinations. - OK
Jack Augenblick, CFP
®
New Continuing Ed
Requirements
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My name is Jack Augenblick, CFP , who became a CERTIFIED FINANCIAL PLANNER™ practitioner effective
2/24/2012. I have not yet met the current continuing ed requirements, although I certainly plan to do so within the
allowed time frame.
The proposed new C/E requirements sound rigorous and beneficial. My first question is, what is the estimated cost to
these new requirements? My second question is, what will be the avenues available to complete the new requirements?
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Patrick B. Aydt, CFP ,
®
CRPC
CE Certification Changes
Sirs: Our practices require so much CE and Government regulated education programs that this is an unjustified
burden. It looks like non practicing & practicing educators are making up the rules. They hand themselves credit for
doing their jobs. Instead of increasing the requirements and giving exemptions to certain classes of certificants just
make the 30 hours required thru testing which the Board of Standards makes up and administers with no exceptions for
teaching etc.. Everyone is treated the same and maybe these individuals looking for a loophole will not be so eager to
increase the cost and time burden of CE requirements.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Debra J. Baker, CFP
Subject
®
Comments
Page 8 of 379
Comment
I am in disagreement with the recent proposals to the CE requirements.
I do firmly believe the current standards are absolutely adequate as they stand. In my 26 years in financial services I am
in tune with achieving my CE credit, as are the advisors I work with. As advisors, we also participate is usually several
meetings weekly that in addition to the classes we take for CE, also provide to us the education needed to keep up with
changes and knowledge in the industry. In addition to this is the continuing ed for our firm requirements and insurance,
LTC licences; I firmly believe I am completing a level of CE that allows me to serve my clients well.
Personally, I was disappointed recently and would like to comment. I have completed my renewal recently, and earilier
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in the year had taken a 3 hour” live ethics” class through a CFP [certification] provider Broker Education & Training
(FLA) & was confident I had now completed my ethics requirement. I found out in trying to complete my application for
recertification, that my ethics course was not accepted. There are only a “select” few courses that were acceptable. I
did not see any of the requirement information on the website. When I called to check, a representative walked me
through a fairly complicated series of steps which I could not find on my own to locate where the “acceptable” courses
were located.
David Freed, President
Beacon Hill Financial
Educators
Comments on Proposed
Changes
1. Increase Total CE hours to 40:
We recommend that the Board consider including the time it takes to complete an exam for a self-study course be
counted in the CE-hour calculation for the course. A well-constructed exam should be more than just a confirmation that
the course content was studied – it should serve to reinforce the comprehension of the material. The time spent in
completing an exam is part of the learning experience, and therefore should be counted toward the CE-hour total.
Due to the ten-question per credit-hour-requirement for self-study exams, a significant amount of time is devoted to
taking the exam for a course, such that the actual number of hours devoted to fulfilling the overall CE requirement, if
done through self-study, is significantly higher than the proposed 40 hours.
To illustrate, the proposed increase to 40 CE hours translates to an aggregate number of exam questions of 420 (10 x
38 CE hours plus 40 questions on the CFP Board Ethics course). Using the formula for calculating the CE hours for
exams used by the National Association of State Boards of Accountancy (1.86 times the # of exam questions, divided by
50), this translates to 15.6 CE hours, bringing the actual CE hours devoted to the overall CE requirement (using selfstudy courses) to 55.6.
2. Increase Ethics CE Requirement:
This needs some clarification. Is the “CFP Board-produced Ethics program” provided by the CFP Board directly to
certificants? Will it be available in both self-study and live formats?
How is the above different from “pre-approved programs on CFP Board’s Standards of Professional Conduct?”
3. 50% Cap Rule For CE in Any One Subject Area:
The transition to the 50% cap rule (if enacted) should include a grace period for individuals, who have already
purchased self-study courses with 21 or more CE hours, to complete those courses and be able to report the full CE
credit, even though it will be in excess of the 50% cap (we suggest one year after enactment of the rule).
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Paul L. Bechly, CFA,
®
CFP
Revisions to CFP Baord's
CE requirement
Page 9 of 379
Comment
I think that the upgrades are exceptionally well thought, and entirely appropriate for the profession.
Consider caution regarding the mandatory CFP Board-produced Ethics program (2hours) as this component should be
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offered at no additional expense to the CFP [professional] licensee. If the CFP Board charged for this component, it
could be considered self-serving which would present an ethical conflict of interest.
Holly Bell-Proshkin,
®
CFP
Benjamin Baum, CFP
®
Please keep it simple
Your rationale for increasing CE hours, etc… is the same rationale I will give for not doing so.
"Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations."
You are correct. Our profession requires constant continuing ed, learning on a day-to-day basis and therefore, we do
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not have the extra time to add to that load maintaining the CFP [certification] designation. Making processes complex
and difficult doesn't make them better.
CFP ce requirements
The current requirement of 30 hours every 2 years is more than enough to maintain awareness of new rules, laws and
techniques needed to lead and assist in proper and complete Financial Planning.
40 hours every 2 years would begin to invade the assistance and time we can spend with clients and potential clients
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that need our input. It can also lead to fewer CFP [professionals], putting a strain on existing practicing CFP
[professionals] to hurry their work and possibly produce inferior results.
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As a professional in the industry for over 25 years and 3 years as a CFP [professional] registrant, I would like to
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propose a solution that every 2 years CFP [professionals] must complete 3 hours of online new laws/good practices w
a mini online 15 question exam w 80% pass threshold. The 3 hours would count toward the 30 hours every 2 years but
the Board would know that good practice and new laws were made aware of and examined. And proof to legislative
bodies that we are correctly policing ourselves.
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CFP [professionals] read and follow new laws and regulations, otherwise their professional peers would stop referring
to them. Over reaching is good, but extreme over reaching impinges, reduces and restricts too much.
The aging of Americans and greater need of financial planning should put more of us in the field, not the classroom.
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Make the CFP [professional] applicant exam tougher or raise the passing grade required, not the renewal hours.
Ben Champion
Proposed CE guidelines
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Increase total hours. I feel this is unnecessary and a massive waste of time and energy for CFP [professional]
holders. It is far more important that the right things are studied than just adding more hours. The rationale for this points
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out that the financial world is fast changing, and this is certainly the case. But a CFP [professional] holder taking 2
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online CE courses or 100 on a couple of topics for CFP [certification] CE credit is not going to bring them up to date on
all of the things that are changing. Far better to have 5 to 10 hours mandated on important changes in financial world
(tax law change, etc) than to just broadly increase total hours.
Credit for Pro Bono. Encourage Pro Bono work by making CE credits for Pro Bono a 1:1 ratio with a cap of say 5 hours
and then 4:1 after that, especially if you are increasing the hours from 30 to 40.
All other changes look good.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Benjamin Lupu, CFP
Subject
®
Re Proposed New CE
Requirements
Page 10 of 379
Comment
I am AGAINST all of these proposed requirements.
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They are pointless, and a needless added burden to the CFP [professional] practitioner.
Increasing the CE burden will do nothing to improve service to clients.
Improving the quality of the current requirement would be a preferred
means of improving CE.
More is not always better. Bigger is not always better.
Why are you trying to fix what is not broken?
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A. Raymond Benton,
®
®
CFP , CRPC , EA*
Changes to CE
requirements
I am generally in favor of the proposed changes to the CFP [certification] Continuing Education requirements, and
commend the Council on Education for its work. I am particularly in favor of encouraging increased rigor and quality of
all CE program delivery methods, and I favor increasing the hours required to 40. However, the addition of a boardproduced ethics program appears self-serving, and is likely to introduce unnecessary added costs (for the board as well
as cetificants). Furthermore, coursework leading to various professional designations should be approved on a case by
case basis and according to the general requirements and subject matter and the provision to exclude this category
should be dropped.
Anthony A. Benvenuti,
®
®
CFP , CRPC
Proposed Changes
As a wire house advisor, my general thoughts are that we receive more than adequate CE and learning opportunities.
Often I do not know what constitutes CE and what does not. I am not in favor of adding more of a workload to our plates
as well as capping various topics.
Bernard D. Rabbino,
®
CFP , CLU, ChFC
CE Requirements
As a provider of on site CE courses I was disappointed that you allowed all the CE credits to be earned on line. I believe
that most on line courses are selected based upon " how many credits can I earn with the least expenditure of time and
money.
On line courses rarely provide issues that are new, based upon experience and cover solutions. They do cover rules
and regulations.
The issues that are presented with client contact are few. The planner is not encouraged to resolve issues presented on
line as they must by their nature avoid the complex ramifications that are part of real experiences.
Discussion generates thinking and makes reality part of Continuing Education.
I believe that 50% of CE credits should be earned on site.
Stephen R. Besse,
®
CFP
Continuing Education
As an 18 year industry veteran at a major wirehouse. I undergo extensive internal continuing education annually. As I
am registered with the SEC, Finra – I undergo periodic training to maintain my licenses. As I am insurance licensed. I
must have 24 hours of insurance continue ed every two years, as well as annuity continuing ed, ethics, and long term
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care. As being CFP [professional] licensed, I need 30 hours plus ethics every two years.
I undergo enough Continuing Education.
I say no to any more requirements. Enough is enough.
What you have is fine. No more changes.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Karen E Hightower,
®
CPA, CFP
CPE comments
Page 11 of 379
Comment
Since the CFP Board is requesting feedback regarding the proposed CPE rules, I think this the appropriate time to voice
my opinions. I have not in the past, as I did not think there was a forum that was interested. I am a CPA in Texas. I
earned my marks in 1994 before the TSBPA changed it "ethics" rules to disallow Texas CPAs from earning commissions
from clients if they prepared financial statements for those clients. My dream was to help my clients manage their 401(k)
plans and defer costs through commissions. I started the process to get licensed to sell products then the rules
changed!! Since the Texas ethic rules for preparing financial statements are now complex at best, and to do an
adequate job of financial planning requires a financial statement, I decided to limit my firm's practice to tax and
accounting (no commissions!) until I retire. So, I do not actively practice "financial planning" but hope to do ONLY
financial planning when I retire from Public Accounting in a few years. So, I want to keep my marks and stay abreast of
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the CFP [certification] world while being a CPA. The CFP Board's position on "what qualifies" for CPE causes
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problems. MOST CPE sponsors who do seminars for CPAs and Attorneys do not want to hassle with the CFP
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[certification] rules to make otherwise qualified courses qualify for the CFP [certification]. I take a minimum of 40 hours
a year of CPE, mostly live classes, each year for my CPA license. I always have classes on Estate Planning, Trust
Administration, Income Tax compliance and planning, using insurance products, etc. as I provide consulting services in
all of these areas. When I can not get credit for an 8 hour class given by the larger law firms in Houston, TX or
universities ONLY because the way the CFP Board requires their sponsors to report hours, etc., I get frustrated! I have
had to buy online CPE classes to get the required hours to report to the CFPB. These are NOT the best courses. The
BEST classes ONLY qualify for CPAs and Attorneys, as the sponsors have told me that they are not going to do the
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extra administration JUST to give CFP [certification] holders CPE credit. It is not worth their time and effort. Some of
these are Texas A & M University, University of Houston, University of Texas, Chamberlain, White, ... Attorneys, Texas
Society of CPAs, etc. So, now that you are asking for input, you have heard my dilemma. Is it possible to evaluate
GOOD CPE courses that CPAs and Attorneys take for the State Boards for licensing on a case by case basis in some
manner so I do not have to take classes twice? This is a waste of time, money, and effort. YES, I have considered letting
my marks go just because this is a hassle every two years. But, I guess I just can not give up on the idea that when I let
my Public Accounting License expire that I can do financial planning without the TSBPA's interference.
Thank you for listening to my complaints and opinions. I only wish the best to you all of you in determining what is best
®
for CFP [professionals].
Beth A O'Shea, CFP
®
Comments
®
The entire revamping of CFP [professional] licensure will definitely impact me in a negative way. I do not practice, but
earned my license back in 1993, I have always complied by doing the Continuing Ed and paid my license fee in order to
keep my own skills up to date, for my own personal benefit and for the benefit of my family members. i am caring for a
medically handicapped grandchild who is 6 months old and currently on dialysis and waiting to be old enough to qualify
for transplant. I cannot afford the increase in hours or paying a yearly licensing fee..I do understand that we must keep
standards at their highest level, ethically in a world that seems to become corrupt in every corner, but I am sure that
there are a lot of practitioners that cannot afford an additional "tax" on their earnings... I cannot say I have a solution to
this entire situation, so unfortunately, I most likely will have to allow my certification to lapse.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Wiliiam A. Andersen,
®
CFP , CPA, EA
Proposed Additional CE
Comments
Page 12 of 379
Comment
In general your proposals are sound.
The Ethics CE increase from 2 to 4 hours:
®
You can keep shoving all the CFP [professional] Ethics courses (along with all the CPA, EA and State Insurance
Course requirements with which many of us comply also) down our throats but to what avail?
Can you say that “studies show…” that for every additional Ethics hour required that 1 fraud will be not be committed? I
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believe that people (CFP Professionals included) are either honest or dishonest. Requiring additional CE hours serves
only to irritate honest Professionals.
William J. Bullock, CFP
®
CFP Proposed Changes
I'm not in favor of the proposed changes.
Proposed change to CFP
CE
I am opposed to the proposed changes to CE requirements. The most meaningful CE is what you learn while diligently
pursuing your career.
Proposed Revisions to
Continuing Education
Requirement
I support the CFP Board’s proposed revisions to the continuing education requirement as outlined in an email dated
August 17, 2012 with one exception, the CE credit for pro bono services. I believe a credit of one CE hour per four
hours pro bono service is inadequate to encourage pro bono service by financial planners. The CE credit for pro bono
service should be more generous, such as one CE hour per two hours pro bono service.
CE Requirement Going to
40 Hours
With the increased regulation coming from the SEC and FINRA, we don’t need the increased hours. Any practicing
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CFP [professional] has to know keep up to date on most laws, rules, and regulation to do every day business anyway.
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Most of the CE requirements are just going over information a decent CFP [professional] already knows. I would rather
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stay with the 30 hours but take the 30 hours through approved courses on the CFP [professional] website in different
categories that the Board thinks are appropriate. Just restructure the requirements, don’t add to the hours just for the
sake of adding hours. It makes no sense.
Tracy L. Bird, CFP ,
CIMA
®
Proposed Revisions to CFP
Board CE Requirements
"Eliminating CE credit for completing professional licenses and designation examinations." Seems arbitrary. Exam
prep, review courses - these could be very high level content and germane to someone's practice and efforts to serve
the public at a high level. I am not sure that a case by case basis review comes through and the absolute on the prep
and review courses is inconsistent with maintaining high standards. There is a wide ranges of areas covered here.
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RE: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Please leave them alone.
William R. Glock, CFP
William H. Newcomb,
®
CFP , MBA, JD
®
Bill Stade, CFP ,
®
CRPS
Bobby Mattei, CFP
®
The “Grading Panel” thing is ludicrous!!! Has nothing to do CE. Totally oppose
Research: Oppose
Increased hours: Oppose. Your analysis of “other professionals” lacks documentation!!
50% Cap: Support
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Darren Bobley, CFP
Brad Cougill, CFP
®
Page 13 of 379
Comment
I feel the CE requirements are too rigorous already, and don't need to be increased. Thanks.
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CE Comments
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I have held the CFP [certification] for 15 years now. I see no reason to make any changes to the current continuing
education requirements. Below are some thoughts on the specific proposal.
1.) Increasing the number of total hours from 30 to 40 – I agree that continuing education is important. However, 30 or
®
40 hours is a bare minimum. I spend many hours reading and studying materials that are not approved for CFP
[professional] continuing education. Given the speed at which the industry changes and the costs and complexity
associated with getting CE materials approved by the Board, I question whether raising the number of hours will have an
impact on obtaining timely information in today’s fast paced, technologically driven era. I would rather see the CFP
Board try to address this by significantly expanding the types and amounts of materials that are approved for CE rather
than increase the number of hours. More is not the same as better.
2.) 4 Ethics hours versus 2 – You cannot regulate ethics, period. Either one is ethical or one is not. Learning more rules
and regulations will not help. I feel this will only serve to be a burden on ethical planners by having them focus more
time on a requirement that will not directly benefit their clients. Unethical people will continue to exercise poor judgment
regardless of the number of hours they are educated about ethics.
3.) Capping the total hours in any one subject – again, more change, more complexity, questionable benefits.
I could go on and on but do not feel any increased requirements or other changes to the current rules will have any
practical positive benefits for the members. The only benefit would be for the Board to say to the public that they’ve
made it more difficult to maintain the designation. Other than the PR, I think it is an unnecessary burden on the industry
which is already dealing with significant increases in regulations and is declining in numbers due to age. This may
accelerate this decline which would hurt the public by having fewer qualified planners in the industry.
As for comparisons with other industry groups, consider that if each compares to the other, it will lead to a continual
upward spiral of requirements. This sounds like “keeping up with the Joneses” to me which is something we try to teach
our clients not to do to be financially successful.
C. Brant Steck, CFP
®
Terry J. Brawand, CFP
CEP
®
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Thank you for your request for feedback. I’m sure you already are aware that increasing the CE hours will certainly not
be a popular decision. Many CFP professionals have other designations, licenses, etc. that also require a significant CE
commitment. The rigorous curriculum and examination it takes to become a CFP quite properly prepares an advisor
with a comprehensive knowledge base. A person who goes to these lengths cares about their practice and will
undoubtedly educate themselves in critical areas of planning. Increasing the CE hours will cause advisors to be away
from their clients’ needs for an additional 10 hours (now an entire 40 hour week). While education is important,
responsiveness and attentiveness to clients needs is also important (and should be important to the CFP board as they
continue to try to enhance the brand). I believe the CFP board’s consideration of the increase has positive intentions,
but I think it is a bit misguided to believe the 10 extra hours will actually pay dividends and that it will more likely cause
clients to sacrifice their level of service (thus diminishing the CFP brand). Just my opinion…
CE
Personally I take 30 credits for CFP [certification], 30 for Texas Dept of Insurance and 15 for IRS (soon to be CPA 30
credits). I think the subject matter has many crossovers and 30 credits is enough! Additionally these credits and all the
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dues cost a fortune. Why would CFP [certification] require more than the others? I do not feel it is justified or
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beneficial. I get plenty of continuing professional education without an expansion by CFP [certification]!
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Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Chris Breckon, CFP
Subject
®
Brenda Friedlander,
®
CFP , EA
Brent L. Abney, CFP
Brian L. Wade, CFP
®
®
Page 14 of 379
Comment
CFP CE changes
What should change is not the hours but the rigor of the content. CE courses as they exist now are simplistic. I have met
long-time certificate holders whom have forgotten how a living trust works, for example. If you don’t use it, you lose it.
Increasing the hours required will more likely only increase revenue to CE content providers, rather than the acumen of
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CFP certificants.
CE Guideline Comments
1) Regarding the proposal to increase the Ethics CE requirement from 2 to 4 hours, I feel that this is not necessary.
First, I do not believe that requiring ethics courses does anything to stop unethical behavior. If someone is unethical, an
ethics course won’t change that, nor will two ethics courses. Secondly, I believe that the ethics classes that we take
currently are repetitive and common sense and do nothing to improve the quality of service that I provide. My time
would be better spent building and improving my knowledge in a subject area that will actually be of some value to my
clients. Lastly, for many of us with multiple designations we are already taking multiple ethics courses.
2) Regarding the proposal to implement a 50% cap on a single topic area, I feel that you are exerting too much control
over designees with this. We know our areas of specialty and also our areas of weaknesses better than anyone. We
should be able to choose which subject areas we want to study and which we don’t need at all.
please leave CE as is
please leave CE as is, and do not make the proposed changes
Comments on CE
Requirements:
Increased regulatory oversight is already resulting in increased CE requirements in the Financial Services fields, not to
mention a whole host of other inconveniences that make it difficult to have the time to operate a successful business. In
addition to my broker-dealer / FINRA required CE, I am required to take regular hours on LTC, REITS, etc. I would ask
that you take these facts into consideration and proceed with caution before you increase and / or further complicate the
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CFP [professional] CE requirements. Increased or more complex requirements could be harmful to certificants and
increase the likelihood that smaller clients will not have access to our services.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Brooks Slaughter, CFP
®
Page 15 of 379
Subject
Comment
CE Requirement Changes
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
AGAINST a change. Foolish to think that approved CE courses are the end all of learning. Honestly, my best learning
is in areas that are cutting edge and do not want to go through the hoops and expense of CE approval. To divert myself
from those types of classes and my clients is a disservice. The reason other entities require more is a money raising
function for themselves. I hope this is not the real reason behind this and the ethics proposal.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
FOR this change
• Increasing the Ethics CE requirement from 2 hours to 4 hours.
AGAINST a change. Rediculous to think more hours of training makes you more ethical. Spend the time and resources
you would on this or ridding the profession of bad apples through vigorous enforcement
• Expanding the professional activities that qualify for CE credit.
FOR this change
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours.
AGAINST a change. While “diversity” is a noble goal, I trust each practioner to know the areas of CE that would best
serve them and their clients.
• Eliminating CE credit for completing professional licenses and designation examinations.
FOR this change
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
For higher quality, but sounds more expensive
• Encouraging increased rigor and quality of all CE program delivery methods.
Motherhood and Apple Pie. This is fine.
e. Bruce Carlsten, CFP
®
CE requirement revisions
I attend C.E. seminars every month for about 8 months each year.
These seminars are on differing topics and they, along with independent reading, keep me up to date in the field. I 5hink
that these 30 hours/2 yrs. is sufficient requirements to keep me up to date.
I am basically retired and deal with several clients on a pro-bono basis.
An increase in hours would make me consider dropping out.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Bruce W. Miller, CFP
®
CE Requirements
Page 16 of 379
Comment
I am in favor of raising CE requirements to 40 hours from 30. I find that 30 hours in two years is a ridiculously small
amount of CE.
I am against increasing ethics hours from 2 to 4. I find the 2 hours to be trying and not very valuable. I do not believe
that an additional 2 hours will make one more ethical. It will simply may CE less compelling for the 99% of CFPs that ‘do
it right’.
I am against not granting CE credit for pursuing other designations. Education is education and regardless of the box it
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comes in, it makes a CFP [professional] better for it. If a CFP [professional] is creative enough to use education to
further benefit his career, more power to him.
I hope this helps.
Bruce Robson, CFP
®
Bruce D. White, MS,
®
CFP
RE: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I fully support the intent of the proposed changes: increased rigor, mandated diversity in the coursework,
encouragement of pro bono work, etc.
But I question whether this approach will be effective in achieving the intended results.
My concern is that it would result in an entangled, expensive bureaucracy: expensive for the organization (CFP Board),
practitioners and perhaps a practitioner’s employer.
I hasten to add that potential added expense does not in and of itself serve as a deterrent to my support of this approach
– if it indeed leads to higher quality.
I have serious doubts that it will.
What about simply having a mandated comprehensive refresher course every two to three years; or even 5 years, with
lesser requirements in between? E.g. annual ethics trainings.
This could take the form of online, or classroom; and could include current topics and developments in addition to
refreshing basic knowledge.
The pro bono idea is a good one in theory. I like it. Personally I do very little structured pro bono work; but rather set
aside a certain amount of time to work one on one, pro bono, with individuals or famiies that
I know will not be a revenue source but whom I think are deserving of my help. Maybe your idea would prod me to, in
addition, be more pro active to do some more structured pro bono work.
Thank you for the opportunity to comment on this,
proposed CE standards
CFP board, these all seem reasonable.
My big gripe is the poor presentation of CE material-maybe the approval of University sponsored CE would solve this.
My optimal CE course would be presented in a “Cliff Notes” format so that I can quickly get to the points and then use
these CE as a reference material. The cliff notes format would also allow me to tackle a wider range of subject areas.
®
Bryan K. Hanner, CFP ,
ChFC, CLU
Comment
I do not like the idea of increased CE hours, however I do support improving the quality of the hours obtained.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Bryan Rex, CFP
Subject
®
comments
Page 17 of 379
Comment
I strongly urge you not to substantially change the CE requirements as you have proposed.
Especially the ethics element.
The ethics element is one of the most frustrating CE courses in our industry and it is widely understood to be a colossal
waste of time and effort. (no disrespect intended, just speaking from the heart)
I don’t mind the 2 hours but 4 hours of this topic will NOT make us more ethical. Please understand that. Our
government believes that more rules are the solution to all problems. This has never, in the entire history of the world,
ever made a substantive difference in people’s behavior. Another 2 hours of a miserable course will only serve to
frustrate certificants and it will not result in any changed behavior.
The change from 30 to 40 hours of general CE is of little consequence to me and while, naturally I resist an increase to
the amount of time I must spend on this sort of thing, instead of working with clients, this change is not a big deal to me.
Please recognize that every time we turn around, someone else is demanding more from us and leaving us with less
time, less revenue, and less energy to do what we love to do. Please be cautious about being a part of the problem. Of
course, thank you for trying to maintain this association and I recognize my general ignorance on the issues you face
every day…I’m speaking only from my personal perspective.
Thanks as always,
®
Michael F. Burke, CFP ,
CTFA, AEP
Change in CE
Requirements
Per the recent e-mail notification of the proposed increase in CE renewal hours from 30 to 40 every two years, I do not
believe this will serve any purpose for those of us who practice regularly and keep current out of a simple sense of
responsibility to our clients and to the public. (I typically have two to three times the required amount of CE credits.)
It is my opinion that this will only serve as an additional barrier to entry and may provide a hardship for those of us who
regularly devote 50-60 hours per week to our profession.
Thank you for considering this as the board makes its decision.
Carol Sandstrom, CFP
®
Carole Nese, CFP
®
RE: Proposed rules
These are fine for those practicing on a daily basis. But, as a large group of us face retirement age, I don't want to lose
the credential even after I stop working. Just like Dr., JD etc, I want to be able to refer to myself as someone who was a
®
CFP [professional] in my working years and even have it listed in an obituary when the time comes. In the meantime, I
don't want to increase my CEU and even pay the ever increasing dues. Why can't you create a designation like
"CFP,Ret" so that you can still be proud of the designation you earned and retained for several years and refer to
yourself as such but don't have the stronger requirements. Maybe even a small annual fee like $50 to be listed and get
email updates would bring in more money to the group as opposed to several dropping out completely. If financial
planning has been part of your life for years, you remain interested and keep up with the news on a more limited basis
so being involved makes sense.
CFP changes
I am absolutely against increasing the CE hours and the ethics hours for CFP [professional] re certification. It is not
necessary for those of us who follow the rules and practice due diligence, ethics and integrity every day.
The increase in requirements would just be additional expense and hours away from serving our clients and putting
our client's interest first.
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Carolyn "Kay" Bruns,
®
LUTCF, CFP
CE Requirements
Page 18 of 379
Comment
I see the point of increased number of hours.
I would like to see the Board approve “Ethics” classes which are already required in the state of Michigan (and probably
other states) as acceptable for the additional 2 hours of Ethics. I was quite surprised last time I renewed that the course
Michigan required was NOT acceptable to the Board.
®
There were quite a number of areas which did NOT overlap between the MI required courses and the CFP
[certification]. It would be nice to be able to apply the ones required to Michigan (24) toward the 40, which will probably
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be approved as this is changed for all CFP certificants.
Casey D. Hunt, CFP
®
Catherine Turner, CFP
®
Cathy Juilfs, AIFA ,
®
CEBS, CFP
40 hours every two years to simply too much. There are other designations that we hold in the industry, other priorities
and time commitments. I personally have to maintain a securities license (series 7), compliance (series 24), insurance,
oversee SEC audits for our small firm every five years, not to mention hopes for sitting for other designations such as
®
the CMT. The CFP [certification] designation is not ALL we do. This organization is not the only body we function
under. We are accountants (CPA’s), portfolio managers (CFA’s), etc. The time burden for all these endeavors will
unfortunately result in more and more individuals dropping their designation. The extra time we have should be spent
educating ourselves in those area’s that we believe will help our clients.
®
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
With regards to the proposed revisions to the CFP Board’s CE requirements all seem to be reasonable with the
®
exception of the additional 2 hours of Ethics. I say this because most CFP certificants also hold insurance licenses and
as such are required to have accumulated 2 Ethics hours for state requirements. That would also add an additional 2
hours to the already proposed increased in CE hours.
Feedback
I am 100% in favor of all of these proposals. I appreciate the diligence and research put into them. I agree that it's critical
®
to maintain the integrity of the CFP [professional] designation and hold ourselves to the highest fiduciary standards.
This cannot be achieved only through lifetime learning but can be promoted.
Again thank you very much for dedication to the profession.
Carter Johnsen, CFP
®
Ryan Groose, CFP
®
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
am writing in response to the proposed revisions. I don’t think it is necessary to increase the CE to 40 hours. I
understand we want high standards. But, I also know that many of us are always “learning and studying”, continuing to
increase our knowledge in many ways…its just that many of the things we read, research ect, are not officially
considered as CE according to what qualifies as CE. Does that make sense? 30 is sufficient, we are busy people.
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I am opposed to increasing the CE requirement from 30 to 40 hours every 2 years. I can live with the other
requirements if implemented, but as a practicing Financial Advisor I don’t see the benefit of 10 more hours of CE and
most of us don’t have the time to take away from our business for the additional hours.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Thea Glazer, CFP
®
Joan S. Spear, CFP
®
Lynne Graham, CFP
®
Page 19 of 379
Subject
Comment
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I am a CFP [professional] and focus on divorce planning. I give many seminars to family law attorneys and the public. I
also attend many bar association sponsored programs which focus on financial planning aspects of divorce. I have not
been able to get any credits for that work. I feel the 30 hours is sufficient and that the proposed increase to 40 hours
every 2 years is both costly and unnecessary. You are already raising the cost by having us renew our licenses every
year rather than bi-annually and this will add to the cost for all of us. I already sent a comment, but I thought of another
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thing. I take the CFP [certification] quizzes in FA magazine. How will you apportion a variety of questions so that we
could meet the various practice area CE requirements?
Thanks,
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I was unable to reply by the link send to me in your e-mail. I have no problem with the 25% increase on the education
hours required. I feel that doubling the hours for the ethics requirement is completely a waste of time. People are either
ethical, or they're not. This will do nothing to change people's practices and I strenuously request you keep the ethics
requirement unchanged!
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
In response to your proposed changes I ask you to consider the following:
®
We have continuing education requirements from our employers/companies.
We have continuing education requirements for our many licenses, i.e.,commodities, insurance, etc.
We have continuing education requirements for our many Finra licenses.
We work with our clients at least eight (8) hours per day.
®
We have committments to our communities in terms of volunteerism in many fields. We use our CFP [professional]
skills on many levels of our lives.
We are longer college students, although many that I know are taking their courses online.
The lawyers that I know earn their hours on a golfing trip to some island.
®
The CFP [professionals] that I know are very hard working, serious and conscientious people...always working to use
their skills properly.
Including more Ethics to the already required courses makes sense since Ethics seems to be a lost art. Perhaps 4
hours instead of two.
®
Perhaps you feel that there are too many CFP [professionals] and you would like to get rid of some of us....which is
what will happen if you try to carry our these rules. I applaude the people who spent so much time working on this...but
their ideas are simply impossible in the real world.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Wayne R. Brunck,
®
CFP , CLU
Page 20 of 379
Subject
Comment
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
As a 37 year veteran in the financial services industry, I have seen a great deal of changes in our industry. Many of
those changes brought about by educators, legislators and SRO’s who do have the best interest of the public in mind.
Unfortunately the financial industry is a complex network of people, companies and business models that is difficult if not
impossible to get ones regulatory/compliance arms around. No one group of people in our industry moves through their
careers on a single path. We operate on a network of many separate financial highways that cross back and forth over
each other and at times run parallel to each other throughout our working years.
The number of CE hours or the method of distribution or the method of assuring mastery of the subject matter cannot
replace the most basic financial services principal. I and my colleagues of similar ethics & tenure have survived the
years and changes of our industry, by putting our clients’ best interest above that of our own, our employer or for that
matter anyone else.
I do not make it a regular occurrence to respond to surveys, committee reports, etc. However, I feel that this request
may benefit from the point of view of a conservative financial services contrarian.
The idea of continuing education is not new. However, the platforms for learning, the platforms for assuring mastering
the subject matter and the coordination with CE courses offered through other financial services industry companies or
SRO’s is. I am sure that the CFP Board cares about establishing a base knowledge requirement to permit CFP’s to
continue to use the designation in our fabulous industry. What I am not sure as to who is driving the horse. In search of
the answers, SRO’s including the CFP Board may inadvertently be over regulating some groups in our industry while
under regulating others. Merely increasing the CE requirements will not equalize this problem. Rather it compounds it,
®
unless they take into considerations the different highways that we CFP [professionals] may be traveling along during
our careers.
®
®
Most of my fee only CFP [professional] advisor friends do not have the onerous requirements as those CFP
[professional] advisors who are fee & commission or commission only. The latter two have additional layers of
®
compliance and oversight that the fee only CFP [professional] advisor does not. The later 2 are already completing far
more CE than the fee only advisor. The later 2 are already held to a higher standard.
®
Further some CFP [professional] advisors who are fee & commission or commission only are employed as captive reps
of major insurance companies. These major insurance companies have the resources to establish their own qualified
schools. These schools develop educational seminars in a matter that will permit the attendees to get CFP and State
Insurance CE requirements. Most if not all of the CE credits are earned without ever passing any formal testing
requirement. The CE credits are awarded to those proprietary reps who simply attend required meetings which have
®
been approved for CE credits. This method in no way guarantees that the CFP certificant has mastered the subject
matter.
®
Independent CFP [professional] advisors who are compensated by fee & commission or commission only usually hold
one or more licenses and one or more certification is being regulated, each of which subjects them to ongoing training
and/or CE. Some broker dealers require extensive ongoing training through independent training companies such as
Reg Ed. FINRA has ongoing Firm Element requirements. On all of these platforms the subject matter has been gained
and there is usually a required passing test grade in order to receive credit for the course/requirement completion.
Taking online course(s) mandated by broker dealers, followed by a test does at least establish a base line
understanding of the material. In most, if not all, cases there is no coordination, prior approval or certification of these
courses and therefore, no credit is offered/accepted by the various SRO’s or state insurance departments. In order for
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 21 of 379
Comment
these courses to provide CFP [Board accepted] CE credits we have to pay additional fees to either the training center to
obtain or to provide a CFP [Board] approved course passing certificates or to the CFP [Board] self reporting process.
Ongoing State insurance licensing requirements are not automatically recognized and given CE credit. Ongoing
securities Firm Elements are not automatically recognized and given CE credit. FINRA S101 requires ongoing testing
every 3 years requiring the passing of a 3 hour exam.
Not every CFP has the same employment, licensing or professional designation backgrounds. Not every CFP has the
same type of practice or area of expertise. Not every CFP receives or has access to free or less costly programs as
those offered through larger organizations. Not every CFP receives the CE material via the same distribution platform.
The coordination of all ongoing training and CE programs from the various financial services industry and licensing
requirements is different and not adequately accounted for by the CFP Board CE approval process. I would ask that
before you add hours, why not find a way to credit those of us who care about our clients and this industry to get credit
for the efforts we are already putting forth. Based on my years of industry expertise, time, effort and desire to help keep
our industry independent of deep pocket financial partners, political agendas and public knee jerk boomerang policy
making, I feel that you can start the process by crediting me with 1 hour of CE.
All kidding aside, I am 100% in favor of CE and ongoing testing. I am not for CE for the sake of CE which results in the
reduction of time spent servicing the needs of our clients. If you have a CE program that does not certify in some
manner the mastering of basic knowledge, then you are merely acting in a manner similar to a hamster that runs for
hours on a wheel in their cage and never get anywhere. My Final thought: Maybe a single CE test every couple of years
similar to the one used by FINRA (S101) would allow for uniform knowledge of all CFP’s on an ongoing basis.
I am available should you have any questions or require any clarification to the above. Good luck with the process, I
appreciate your efforts and will abide as always with your final decision.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Leon Rousso, CFP
Subject
®
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Page 22 of 379
Comment
®
I’m always happy when CFP [professionals] are engaged regarding changes that affect us personally and the industry
at large.
I have only a few comments which I will leave brief and am available if anyone wishes to discuss in more detail. Please
assume if no comment on a change then I am in agreement .
1. Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
I strongly suggest this not be implemented
Because of the ever increasing regulatory requirements coming from all directions I do not believe increasing our CE
requirement will be in the best interest of practitioners. Thirty hours is plenty considering many of us also have additional
time requirements for other licenses, registrations and from our broker dealers.
2. Granting CE credit for practice management programs
This is an excellent idea and also works as an incentive for Pro Bono & Practice management work
3. Increasing the Ethics CE requirement from 2 hours to 4 hours
In my opinion, ethics cannot be taught. I suggest we DO NOT increase this area of our CE requirements.
The planner either has them or he doesn’t. From my experience there is plenty of ethics missing however giving the
unethical more education is like telling a thief not to steel twice as much. We need more enforcement , not more words
on ethics.
4. Reviewing online courses for academic credit monitoring of unethical behavior and practices
Excellent idea
Nicholas J Lardieri, Jr.,
®
CFP
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
In general I agree with all of them except bullet 6.
®
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I am confused by what you mean by "CE for competing exams & licenses"
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I disagree with the changes. I think the requirements are stringent enough. A 100% increase in the ethics hours will not
®
make you more ethical, nor will it stop an unethical CFP [professional] from his actions. These increased costs may
®
deter good people from maintaining their CFP [certification] designation.
Marvin Huttman, CFP
Lawrence P. Kennard,
®
CFP
®
I am a CPA who takes CE for Taxes that qualify for my CFP [certification] & CPA licenses. I also have an insurance
license and take CE courses to maintain my insurance license. If your proposals involve eliminating CE for duplicate
licenses then I am totally against your proposals. I am also against the increase from 30 to 40 hours. I already take 80
®
hours of CE for my CPA & 24 hours for my insurance license. This increase will impose a burden to CFP
®
[professionals] who have more than 1license and will cause many to drop the CFP [certification] title and membership
from your organization.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Comment
®
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I am appalled at these recommendations. I think you should eliminate all continuing education requirements for active
®
CFP [professionals] with over ten years experience. Our broker dealers have increased their CE requirements enough.
Stop making it harder on us to do our jobs. We don't need more CE. The board
must have better things to do with their time than to think of things that make our jobs harder.
®
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I do not think the first, the third and fifth bullet points are necessary!
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Please review the CFP Board policy on “Conflict of Interest” and apply it to this situation:
William N. Hytner, CFP
Robert H. Depew, CFP
®
Richard Hale, CFP ,
CIMC,CPWA
Page 23 of 379
Expanding required CE Credits, especially when it requires more classes that must be sourced from the CFP itself,
makes it clear that the issue is revenue for the CFP. Please remember that the role you play is to protect the credibility
of the designation and to represent those who hold the designation. It concerns me greatly that you would create an
excuse to extract additional revenue for CFP under the guise of “protecting the value of the designation”.
A choice to exercise the muscles of this monopoly greatly cheapens the value of the designation. Others will , and
should, point this out to future potential candidates.
Daniel C. Danese,
®
CFP
Pupke, Henry R, CFP
Natasha Antonakos,
®
®
CFP , CRPC
®
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
As a program director and practicing planner I am beginning to wonder if the board has lost touch with reality in terms of
just how busy an engaged planner really is and how much new information we learn in every day practice just by simply
serving our clients. Furthermore, the amount of other CE we are required to complete makes this additional requirement
all the more onerous. I think this is a very bad idea...although with good intention.
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Over doing it. Probably will let CFP [certification] designation expire.
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
FYI
®
increasing # of ce credits needed and decreasing the ways of getting those credits!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Susan E. Bayliss, CFP
Robert Stanley, CFP
®
®
Page 24 of 379
Subject
Comment
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
As a CFP [professional] for over two decades, I absolutely do not agree with the Board's proposals to increase the CE
requirements. Not only is it unnecessary, except perhaps for the result of increasing revenue stream for CE providers,
such an increase places Over-regulation/burden on the many of us who must also meet extensive CE demands for other
licenses such as insurance, Series 7, CPA, etc. I believe there will come a point of diminishing returns for the Board and
®
®
CFP [certification] industry, when along with fees, CFP [professionals] including myself will reevaluate value of
continued renewal of our licenses. Thank you for your consideration in maintaining the existing sufficient CE
requirements.
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I disagree with the entire proposal, what you are doing is imposing an additional tax on my business to supposedly
improve/solve my alleged lack of education/knowledge. In such a case the burden of proof should be on you to show a
documented NEED on my part for additional education and not on me to simply pay up because you think it’s a good
idea. In fact after reading over the proposal yet again I still find no documented NEED for additional CE and in fact I
have come to believe that those who wrote it somehow believe continuing education does a profession make.
®
If there exists an urgent need for additional CE then there likely exists an even larger need for rectification/retesting.
Here’s an idea, let’s start by testing the… maybe I will just keep that to myself.
Kevin J. DeKrey, CFP
®
David S. Coult, CFP ,
®
®
CLU , ChFC , QPFC
Elwyn Brown, CFP
®
James Hughes, CFP
®
®
FW: Proposed Changes
My reaction to the proposed 10 hour increase in CE’s every two years is that a 25% increase seems overdone. I am all
for training, but we already have a lot of training at Morgan Stanley Smith Barney just to stay working here. If you
®
decide to add to the hours for CE’s, you risk pushing out the CFP [professionals] at the wirehouses, because we
already have a lot of time invested in training, and find it hard enough to do our work with the current training load. We
®
might have to drop the CFP [certification] designation just because it becomes too much, and the overlap of training is
unnecessary. Thank you.
FW: New CE Standards
I oppose the new CE standards. Specifically, not providing credit to CFP professionals when they complete other
designations is clearly motivated by the CFP Board serving its own competitive interests rather than providing fair and
®
honest credit to CFP professionals’ continued education.
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
More CE requirements only enhances the educational providers. Until there are meaningful education programs every
®
year would be a worthless exercise. Continuing to make a CFP [mark] more difficult and expensive to maintain makes
it a less attractive designation. More is not better - focus on quality not quantity - this proposal does not do that.
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
If it ain’t broke, don’t fix it.
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Bob Fowler, CFP
®
Page 25 of 379
Subject
Comment
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Thank you for the opportunity to comment on the proposed CE changes. My response is a definite NO. 30 hours is
®
sufficient. In fact, if you are a true CFP [professional] and study religiously everyday, then NO hours should be needed.
Case in point: I am now studying for my ChFC degree. I liken your proposal to the increased government regulation put
down on the financial services industry.
Additionally, 30 hours is sufficient because I am working a good 65 hour week in marketing, doing seminars, researching
for clients, writing proposals and attending many conferences that are NOT CE approved. We do need time to SELL
and manage our practices. In the real world, because of the economic climate we are in, cases do need to take longer
times.
Shawn C. Glogowski,
®
CFP
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I agree with all the points below. Especially the extra hours and increased rigor. The higher we can set the bar the
better for us as professionals and for the public.
Can you provide some clarification of the point below? Would American College courses count towards CE?
• Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
Also, I teach a LUTCF class through the American College, would this provide me with any CE?
David M. Arthur, CFP
®
Warren Knowlton, CFP
®
®
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
If you make any increases in CE requirements or fees, I will drop my CFP [certification] designation. I have had the
®
CFP [certification] designation for approximately 20 years and during the years fees and requirements have steadily
®
increased. Insurance CE and the Firm element along with CFP [certification] has created an industry that creates very
little when compared with time and expenses they take. I have come to the conclusion that you need me,( financial
professionals), more than you are needed. If I were new in the business, I may feel differently; however, after 30 years+,
®
I feel you are quickly becoming a hindrance to business. Don’t make my decision to drop the CFP [certification]
designation easier, find another way to feel good about your place in our profession.
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Please do not increase the number of hours to 40. The idea of two added ethics hours is fine and 32 should be max
number .
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Joseph W. Thomson,
®
CFP
Page 26 of 379
Subject
Comment
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I remain baffled over last 2 years in courses that are accepted for continuing education hours. For example, I recently
submitted on August 15, 2012, for approval 21 hours from an AICPA Advanced Estate Planning Conference held July
23-25 of 2012. There was NOT one course listed among the various break-out sessions that I attended and listed that
do not come within one of the 7 Topic areas. In fact, each of the courses listed were for either Income Tax or Retirement
and Estate Planning. I received a response today showing approval for just 9.5 of the 21 hours. This has happened
before with no explanation as to the denial of the other courses. While I have met my Continuing Education requirement
of 30 hours, it remains frustrating to attend high quality courses taught by nationally recognized speakers on one of the 7
topic areas and have courses denied.
If continuing education hours are to be increased, I would appreciate a better understanding of why some Topic areas
are denied and others accepted.
Thank you for your quick response on my recent submittal of hours so that I may renew my license by September 30,
2012.
Clarence E. DiSabatino,
®
III, CFP
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Most CE courses provided little if any real information. After 15+ years in the business they all are redundant. These
proposed increases appear just another way to collect more fees.
Luana Mobley Corral,
®
CFP , CFS, CLTC
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
As an industry we are regulated to death. I oppose increasing the total to 40 hours. I don’t believe the increase in CE
requirements is warranted or necessary. If you want to increase the ethics from 2 to 4, that would be fine, but the total
number of CE credits, including the ethics should be kept at 30 hours. I think the practice management of 4 hours
should be allowed in the current 30.
Fernando Alvarez,
®
CFP , CLU™
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Working and studying to make possible success takes more than the time that I wish to devote to this aspect and role of
®
life. Of course updating knowledge and capabilities is important to keep the profession in good standing and the CFP
[certification] should not be an exception. But increasing the already demanding activities every two years is too much,
in my view.
Also, as experience increases with tome devoted to the field and seniority is stablished, the CE credit requirements
should decrease and eventually vanish with time of service and age as a recognition of the wisdom and knowledge
acquired.
Thank you for lessening to the voices of the professionals. Hope this notes are of some practical use and consideration.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 27 of 379
Subject
Comment
William G. Hammond,
®
CFP
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
The proposed changes under consideration are:
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
[Bill Hammond] Comments: Not really a problem.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
[Bill Hammond] If you want more hours then you should add Practice management.
o Pro Bono (volunteer personal delivery of financial planning) services.
[Bill Hammond] Although a worthwhile cause I am not no really in favor of giving credit for pro bono. What does that
have to do with continuing education? Very little if anything.
• Increasing the Ethics CE requirement from 2 hours to 4 hours
[Bill Hammond] Absolutely not in favor of adding more Ethics requirements. This is a total waste of time and money to
®
do this. You could however send out actual case studies every quarter of how CFP [professionals] have been
reprimanded or how they have broken the law and use that as an example.
• Expanding the professional activities that qualify for CE credit
[Bill Hammond] Not on favor of this one.
o Study Group Activities that meet certain guidelines;
[Bill Hammond] Good idea but in needs to be a formalized study group. Problem is how do you monitor it?
o Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
[Bill Hammond] Not sure that I understand this one or even what it means. Not really in favor of getting credit to
someone who does research.
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours.
[Bill Hammond] Of that makes sense.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
[Bill Hammond] makes sense.
Donna Waldron,
Associate Professor of
Business & Marketing,
Personal Financial
Planning Program
Administrator,
Manchester Community
College
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Overall, I believe your parameters for continuing education are sound.
Mickie Constantino,
®
CFP
CE credit
Please revise the CE reporting period to 3 years. 2 years is too short a period.
Perhaps I missed this and I think it is currently allowed, but teaching courses in a Board-approved program should
continue to count towards CE credits, in my opinion. The rationale is teaching keeps an individual current in a subject
area and good teaching requires complete understanding of topics. Further, instructors who teach in our programs
receive minimal compensation and, in effect, are doing a community service by agreeing to teach. Finding qualified
adjuncts is not easy as it requires a balance of knowledge and experience in the field, academic credentials, and the
ability to teach and invest needed time. Perhaps a limitation on percentage of CE hours is appropriate, but a substantial
number should be allowed.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Charles Michael
®
Anderson, CFP ,
C.P.A.
Subject
Dual Professionals-Chuck
Anderson
Page 28 of 379
Comment
®
I am a CPA and would like to have some of my hours count for both my CPA and CFP [certification] licenses
®
I also need to take 4 hours already for ethics as CPA and Insurance licenses. This should count for CFP [certification]
too.
If I try to sell any products as Insurance agent I need to take courses on each of the products before I can sell them
Too many hours of continuing education with duplication all over the place as dual pro. Call if you like to discuss
I am in a hurry right now.
Charles W. Dibner,
®
CFP
The Commentary attached
Although I’ve been certified for quite a number of years, I’ve not previously taken the opportunity to write a commentary.
®
I do so now because professional development, as reflected in our continuing education, is a singular void in the CFP
[certification] program.
In more than a few instances, I have submitted courses for credit that have been rejected for, what appear to be,
reasons having more to do with bureaucratic decisions than with content, importance or application. In every instance,
these rejected programs were full day, intensive courses that were produced and administered by national companies
and carried accreditation for both legal continuing education and CPA/accounting continuing education. They were all
programs for which I would gladly pay $300 to $400 (plus travel) because they provided high caliber educational
content, usefulness, applicability and timeliness. They also kept me up to date on changes in our profession, related
professions, ideas, practices and societal circumstances. They were, in all instances, either not approved in advance or
did not receive approval because the decision maker did not see the relevance of, for example, Structured Legal
Settlements to financial knowledge.
®
In contrast, I attend programs administered, on a quarterly basis, by the two CFP [certification] chapters to which I
belong (Massachusetts and Northern New England.)To attend meetings, I travel a minimum of 4 hours and incur, in
addition, hotel expenses. Many of these programs incorporate presentations which are made by vendors or individuals
who have an associated product to sell or by individuals who have no business teaching anything. And, yes, I’ve twice
served on chapter programing committees and am familiar with the limitations associated with getting qualified
educators.
The point is that I am willing to pay for high quality, true educational courses if they help my profession. The adjustments
in your letter do little that will directly effect the quality of our education or make more resources readily available. What
is readily available, currently, is a mélange of decent professional presentations and sad excuses for product sales. The
®
change in hours will do nothing more than make it more difficult to find qualified presenters. Apparently, our CFP
[certification] profession is willing to accept the lesser choice.
Please understand that I will waste neither your time nor mine by discussing the open book tests, for credit, in the back
of magazines.
• Increasing the hours: What does this accomplish? As far as experience dictates, we will spend more time trying to find
the same quality of educational programs. It would seem more logical, more in line with our espoused goals and would
increase our functional knowledge if we focused on and resolved the quality issues rather than the quantity issues. If we
intend to elevate the stature and character of our profession, more hours makes no sense unless the quality of
education is improved.
• Pro bono activity and professional activities in lieu of CE credits: The availability of such opportunities is directly
related to population, socio-economic level and demand. It is, then, only to be expected that rural areas offer few, if any,
such opportunities in contrast to suburban or urban communities. It is only logical that higher family income communities
offer more attractive opportunities than moderate income communities. Remember, we’re talking about education
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 29 of 379
Comment
credits, not fees. Would it not be more effective to allow considerable benefit for personal involvement in related civic
activities or for financial services to the community or charitable institutions?
• Ethics: Professional ethics is an area far better done by the Legal CE programs in terms of quality, useful learning and
educational depth. Would it not make sense to utilize interdisciplinary ethics education taught by people who are
®
infinitely qualified? Would it not make sense to permit a CFP [professional] practitioner to attend, and get credit for,
other professional ethics classes, e.g. legal, medical, education, accounting?
In the early years of my certification, I enrolled in, and benefitted from more than 100 reportable hours per each
reporting period . . . check the record. I no longer do so simply because there are obstacles to learning and barriers to a
quality continuing education built into our system. Please do not act to make continuing education less valuable and
more onerous.
Charlie Lucas, CFP
®
Charlie Nemes, CFP
Please leave the CE requirements alone
®
CE
I am really disgusted that you are increasing the ethics requirements. It is already a joke to take the same test over and
over again every two years, and now you double the requirement to 4 hours. I am also a CPA where we have our ethics
®
CE requirement which, I might add, is much more stringent than the CFP [certification]’s ethics course. You should
®
exempt all CPA’s from the ethics requirement, much less double it. By the way, if a CFP [professional] hasn’t had any
ethical issues why should he have to take the same course multiple times? If there have been violations or complaints
then make him/her take additional courses. Otherwise, it is a complete waste of my time and just more money in the
®
pockets of those who benefit from the CE training (not to be cynical, but does the CFP [certification] organization make
more revenue from additional CE credits? I sure hope not, that would be unethical!!!)
I have been a member for almost 25 years and have had just about enough of these intrusions. Maybe you should
consider grandfathering members with clean records who have more than, say, 20 years of experience. It would be a
great reward for running clean businesses and being the best advertising you could possibly buy!
Charles T Hill, Jr., CFP
®
CE Comments
I have a few comments regarding the proposed changes for the Continuing Education (CE) requirements:
- I agree with the increase in the overall hours from 30 to 40 and the cap on individual subject matter hours.
- I also agree with including some hours of practice management. My local chapter of the FPA is reluctant to include any
practice management topics in their programming because it does not qualify for CE. I would really like to get some
exposure to more practice management topics.
- I think the approval process for getting CE courses approved ahead of time is cumbersome. Compared to some other
professional designations (CPA), it is much more difficult.
- I think ethics is very important, but don’t think the hours need to be increased from 2 to 4. Maybe requiring that at least
one ethics course per year be completed (1 hour each) would be more effective.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Chris Frampton, CFP
®
Regrading proposed CE
changes
Page 30 of 379
Comment
I can understand the rational for many of the recommended changes as listed in the e-mail. However, there is one that
does jump out at me that I do disagree with.
1) Eliminating CE credit for completing professional licenses and designation examinations. As someone who completed
his Masters in Personal Financial Planning from the College of Financial Planning in 2010, my purpose of getting this
®
degree was not to utilize the time toward my CFP [certification] CE requirements. The purpose was to further my
education in the field of financial planning to be a better advisor to my clients. However, through the courses I took, I
®
can’t think of any better knowledge to apply to my CE than that. In addition, as other CFP professionals seek additional
licenses, degrees or designations, most do this while continuing to work full time and have lives outside of business. To
tell them that what they are doing doesn’t count as “Continuing Education”, I feel is a mistake. We should be
encouraging this type of activity, not hindering it. We all have only 24 hours a day and to tell these people you are
increasing their CE requirements and eliminating CE for furthering their career in this industry seems counter-productive.
Chris Gullotti, CFP
®
new CE requirements
discussions
I don't see it in the discussions but I hope that with the bar being raised in nearly all aspects of these CE requirements
that you will consider allowing some excess hours to carryover into the next CE period.
Selfishly, I hope to see the results of some of the Board's marketing efforts at some point. I am finishing my tenth year
®
in practice. In that time only one person has asked me if I was a CFP [professional]. And that was my Mom. And she
wasn't even sure what it meant.
Increasing requirements and costs are fine if our clients and the practitioners will benefit.
Thank you for your work.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Chris Morris, CFP
Subject
®
CE for CFPs
Page 31 of 379
Comment
®
I am both a CPA and a CFP [certificant]. I also am an insurance agent an RIA and have a Series 7, 66 and 24. The
reason for getting into details about certifications is I spend a lot of time taking continuing education credits. Also,
®
FINRA has me take additional brokerage training as well, none of which counts toward the CFP [certification] exam.
®
Many of the things I have to study do not get CE credit as a CFP [certificant]. I understand that you are trying to add
®
®
“legitimacy” to the CFP [certification] profession. All of the credits I get as a CFP [professional] count toward my CPA
®
continuing education credits. The CPA license is in fact a professional license. The CFP [certification] license is really
not a professional license. It is a non-profit license. Yet when I receive training as an insurance agent, you often will not
accept that training. When I do training in my CPA profession, you often will not accept my training. When I read books
about investing, taxes, estate planning, determining what investment products are available for my clients’ use, you will
not accept that time as CE credit. When reading a book about tactical asset allocation, or studying investors’ business
daily on a daily basis, you will not accept my training or study in those fields. Yet taxes, estate planning and investments
®
are a part of the CFP exam.
I taught finance at college and taught accounting at colleges for many years. As a college professor, no one asked me
for my continuing education credits.
Yes you want to be a profession. But adding tons of CE makes me wonder whether I should even keep my license as a
®
CFP [professional], because the costs and headache are on a path where they may become more expensive than the
benefit.
I’m not trying to be critical. I do agree that we need training. But the CPA society takes all training and takes my word
®
for it when I tell them that I did the training. There is no equivalent way of getting credit when getting CFP [certification]
training. I spent 8 hours studying long-term care insurance. But because I did not have a witness present to “authorize”
my training, and because the course did not meet the CFP’s minimum requirements, I didn’t get 1 minute credit for the
training.
If I do a lot of training, yet it feels like I have to have ten witnesses and four scribes to review what I did, or I don’t get
credit for it before the CFP board. If we are a profession, shouldn’t you take our word for it when we tell you we read
Henry Abts book on Living Trusts, or Choate’s book on Retirement Benefits? Should you not give us credit for a longterm care course that while basic took me four hours to complete. Yes it was an 8 hour course per the insurance
commissioner, and it took me four hours. But if you asked me I would tell you the truth, I spent 4 hours taking the
course.
Let’s not become a Government agency that has us filling out so much paperwork that we can’t perform the duties of our
profession.
A concerned member.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Christopher A.
®
Schipske, CPA, CFP
Subject
New Proposed CE
Requirements
Page 32 of 379
Comment
®
I commend you on your ongoing effort to maintain higher standards for the CFP [certification] designation. I can see
why you feel the need for the revisions.
My only comment/suggestion would be to increase the flexibility of "crossover" CE hours. I am licensed CPA as well
which requires 80 hours of CPE every 2 years. Often times I find myself searching (to no avail) for courses and CE
opportunities that would satisfy both CE requirements. In the past it has been difficult to find enough opportunities to
®
take one course or program that would credit CE hours for CFP [certification] and also for CPA. Please explore more
opportunities in this area. CE should be used to keep a professional knowledgeable of current regulations, standards
and practices, but not be so taxing on a practitioners time that it prevents them from putting these items in place.
Christopher G. Weber,
®
CFP
Contining Ed Proposals
I am not in favor of changing the continuing education requirements for three primary reasons:
®
• Through FINRA, my broker-dealer, the Minnesota Insurance Department, the banking industry, and my CFP
[certification], I must spend approximately 6 full days per year on continuing education that cover similar topics. A while
ago, I was able to receive multiple credit for classes to comply with requirements for each area, but that has become
®
mostly impossible. I would think many other CFP [professionals] would have at least one of the same overlapping
designations that I do. For this reason, I think the existing 30 hours is sufficient as I must perform many more related
hours anyway.
• I do find some of the information valuable, but for the most part it is redundant. I am finding that the classes are not
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very scholarly and I am not learning much beyond what I already know. CFP [certification] courses are among the
more interesting, but I still feel like I am relearning the same things over and over. I am not choosing the same classes,
either, and I have tried different providers.
®
• If a CFP [professional] must be competent, staying up-to-date would be mandatory with or without any CE
requirement.
• The expense. The added expense of the CE and the expense of being out of the office would have to be offset
somewhere.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Christine L. McLynn,
®
CFP
Subject
Increased CE
Requirements
Page 33 of 379
Comment
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I will likely be dropping the CFP [certification] designation next January because of the difficulty and cost of
accumulating CE hours when not employed in the profession.
®
Unfortunately, I am a creative analytic (CFP [certificant], CFA) in Charlotte, NC who can not find a position. I searched
for 19 months before finally calling it quits last May. To find work in the profession here, one basically has to be a
producer or a call center type willing to field up to 40 calls per day. Expert support staff are almost non-existent!
®
In contrast to the CFP [certificant] profession, my CFA designation will be relatively easy to maintain. Many FREE CE
hours are available, and I have accumulated 50+ so far this year. The CFA Institute wants its members to stay current,
and therefore, provides many platforms for learning. Note: As a retiree, my membership in the CFA Institute plus local
society costs only $150 per year. That includes access to a plethora of free CE and society luncheons!
®
For the CFP [certification] designation, I must pay dues to the CFP Board for marketing ($360), dues to the FPA ($295),
and still pay CE luncheon costs ($325) - totaling almost $1,000 per year. You send me notifications of programs, but if
they are free, no CE credit is provided. Since I'm not employed, any costs I incur are non-deductible and nonreimbursable. As an involuntary retiree, $1,000 per year is just too much.
You need to make CE accumulation easier and more cost effective IF you desire to retain more types of people in the
profession. Otherwise, sales and marketing people will define who you are. Personally, I think the ethics of the
profession would be better served with a more diverse population.
Long story short, raising the CE requirements only makes my departure likelier. I love learning, but not when the meter
is always running for the privilege.
Christopher M. Parks,
®
CPA, CFP
CFP Strengthening CE
Requirements
I whole heartedly support the CFP [board]’s proposal to increase the CE requirement from 30 to 40 hours every 2 years.
However, I would challenge the CFP Board to strengthen the CE requirement to be equal to the level required by a CPA.
®
After all, public accountant’s only deal with compliance issues. CFP [professionals] are entrusted with the financial well
being of their client’s lives!
Charles J. Root, Jr.
®
CFP
CE Comments
I read your proposal with interest.
®
First I'm a perpetual learner and your system of CE s is the worst. First of all, not of the CE units available for CFP
[certification] are allowable for state and federal CE units. This requires taking additional and similar courses. You need
to coordinate with these other agencies to make it consistent.
Second adding 10 more units is nonsense, in that for people who are studying, it won't make any difference and for
others who just do minimum it won't either. Seems to me you are only trying to benefit your friends who teach CE
courses. What will you accomplish by making us listen 2 more hours to ethics? Either you are ethical or not.
Third, reading the FP magazine and getting CE units that way is ridiculous as well. That is not studying, since most of
the articles are not in-depth.
If you want to make it attractive for newer certificants, you should have a system that is consistent and workable. I don't
see the current system as workable.
Thanks for listening.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Cinda Jones, CFP
Adding CFP CEs
Page 34 of 379
Comment
I don’t agree that we need more CEs.
Additional ethics CEs are not necessary. Anyone with a modicum of intelligence can read and demonstrate in 2 hours.
More hours won’t matter to those who aren’t ethical and for those who have ethics well in hand; it’s just more perfunctory
compliance.
®
If you must have distributed hours across categories, please consider exempting CFP [professionals] who have been
practicing 10 or more years? Successful practitioners generally have an established field of work. More houses
scattered across categories seems a waste…. Or compliance again.
Seems to me this movement to increase CE’s is about PR / Marketing. You did a survey, you are promoting the brand,
and this is part of the plan. I am not in favor of the proposed changes.
®
Clarence E. DiSabatino,
®
III, CFP
New CE Requirments
For CFP [professionals] in business for 25+ years should get some credits say 5-10 automatically.
Clarissa R. Hobson,
®
CFP
Comments
I am in support of these changes, as I think they will make the designation more meaningful and credible.
CFP Continuing ED
What is wrong with the present requirements? Keep the current CE system. If it ain't broke, don't fix it. Thanks.
CE Requirement
I wouldn’t change any of the current rules. Leave things alone, thx
Proposed Changes
I understand that no changes have been implemented since 1990, but why does that necessarily predicate a need for
change? I don’t think the hours or ethics hours should be changed. Most of us in the industry have other designations/
firm mandates/ ethics courses required for insurance that keep us all busy. I also think that achieving the CE credits
with other designations should be encouraged. It allows a planner to have a broader scope of knowledge that then
®
allows for a better CFP [professional].
Clark E. Morrison, CFP
Mark D. Cooperrider,
®
CFP
Ronya Corey, CFP
®
®
As for the other changes, I have no comment or thoughts.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Craig B. Forney, CFP
Subject
®
Comments on Proposed
Changes
Page 35 of 379
Comment
The CFP Program has been around a long time so change should always be considered. I think about the change in the
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Ethics policy and realize that not only do I do the CFP [certification] ethics exam every two years but have an Ethics
exam every year at work. I am not sure adding two hours is going to truly make a difference. And will taking a four hour
exam versus a two hour exam make one a better or more honest planner?
®
More and more CFP [professionals] are specialized, therefore, it makes sense for them to have more credits in their
area of specialty so again, I don’t think the 50% cap rule really helps anyone. Are not the mandatory 30 hours every two
years not enough. I know with busy schedules there are times that I may have 60 hours and other times it doesn’t make
economic sense just to go sit for a few hours for some required time.
Personally, I believe the program is well structure as it has been for many years and these changes just add to the
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financial load many of us face each year in maintaining our relationship with the organization. I have heard other CFP
[professionals] who are dedicated in serving others in specialized fields comment that these new changes could very
well dim their prospects for renewal.
®
I would add that being a CFP [professional] comes with a lot of pride and honor as well as a tradition of service to the
community. I would hate to see the program drastically change from its present position.
Craig S. Janus, MSEE,
®
MBA, CFP
Craig Lindemann, CFP
®
CE CFP comments
The proposed changes under consideration are:
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours. I find this to be
unnecessary.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
I feel the purpose of the CE is to keep us on top of our game with regards to delivering quality planning for client. As
such, I think this is outside the scope and should not be included.
o Pro Bono (volunteer personal delivery of financial planning) services. These activities must be supervised by a
registered CE Sponsor organization and will be accepted for 1 hour CE credit per 4 hours pro bono service. I do not
agree, pro bono services are not educational.
• Increasing the Ethics CE requirement from 2 hours to 4 hours The ethics requirement is fine where it is and I do not
want it increased.
• Expanding the professional activities that qualify for CE credit I agree with these, it furthers the education of both the
participant and our profession as a whole.
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. Do not agree. Planners should have the flexibility to educate themselves where they see fit to do
so.
• Eliminating CE credit for completing professional licenses and designation examinations.
Agreed
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
Not quite sure what this means. Hopefully, it does not reduce or eliminate the ability to take online self-study courses.
• Encouraging increased rigor and quality of all CE program delivery methods. Agreed
more CE???
Don't you folks have anything better to do? I was excited to read the most recent email anticipating FEWER CE
education hours in the future. You have far too many idle hours on your hands. I would strongly object to an increase in
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 36 of 379
Subject
Comment
CE hours. STOP IT!
Craig Van Winkle, CFP
®
Comment: proposed
revision to CE
requirements
I have concerns about the 50% cap rule. Many of us specialize in a few areas of practice.
During my 25 years of practice, I approach each CE cycle by searching for quality courses that will best help me serve
the interests of my clients.
Many times, that has resulted in a concentration ( for that cycle) in courses that fall into just one or two areas.
I agree it is important to maintain a broad knowledge base, but the 50% cap will often be too restrictive.
Perhaps a 75% cap and/or extending the cap period over two CE cycles would give us more flexibility to choose courses
that will best enable us to meet our particular client needs.
Increasing the requirement to 40 hours must be coupled with providing more quality online courses. All to often,
conferences tend to cram 3 hours of useful information into 3 days.
Also, in most of the other professions that require higher levels of continuing education the professional designation also
serves as a license to practice. The increased CE requirement should be coupled with increased efforts to restrict the
practice of financial planning disciplines to those who maintain the professional designation. While this would benefit
practitioners, it would even more serve to protect the public interest.
Please find ways to make available for credit more courses with new information. CE should be about expanding our
knowledge base to better serve our clients, rather than "filling a square" to meet registration requirements.
Paulette J Hubbard,
®
CFP
changes in CE
®
My name is Pauli Hubbard and I have been a CFP [professional] for over 20 years. I believe, in light of the recent
Congressional discussions that we as a profession must show that we are intent on providing the highest appearance of
integrity, service and education.
I support this move
Thank you,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Curt Kruse, CFP
Subject
®
Continuing Ed
Page 37 of 379
Comment
®
I just finished reading the new proposal for continuing ed for the CFP [certification] designation. I want to also say that
this is the first time I have ever responded to anything at the board (though there have been some topics discussed and
actions taken that I find troubling). In this instance, however, I find that I must comment.
I feel confident that the individuals tasked with looking at CE requirements are good people who probably know a great
®
deal when it comes to the education that is necessary to become a CFP [professional] and I am also quite sure that
several have good practices. I am not sure, however, if the overall time was well spent in analyzing this topic. As I am
sure you all know, the amount of regulation that is being pushed is exponentially increasing from year to year. If you
work for any sizeable institution (as I do), you will note that the response to this increase has led to an increase on the
internal requirements you must complete to become "compliant." All told, the amount of time has more than doubled
over the last three plus years in order to maintain current licensing and fulfill compliance demands. The one thing that I
fail to see in all of this is how any of this actually does anything to help the public and, by extension, our clients. As
more and more individuals achieve the designation, I believe the bigger issue to be an overall saturation of the
®
designation. Very few clients have the capacity or knowledge to determine if one CFP [professional] is more
knowledgeable or better at helping them with their needs. If certificants are helping their clients the right way, additional
continuing ed is not needed. If they aren't, all of the continuing ed in the word isn't going to change them.
At the end of the day, when determining how much more of my time the board is going to take from my clients, they
should do so with more consideration to the vast differences in time needed to complete compliance and other
requirements from firm to firm that the certificants will experience. Though the board strives to standardize as much as
®
possible, the firms, brokerage houses, wire houses, and RIAs do not. And to compare the CFP [certification]
designation in the same vain as a CPA, CFA, or Bar exam in terms of established requirements for continuing ed would
also be a mistake. In those three instances, those are the standards for their respected industries in order to practice
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their profession. As much as I (and my clients) appreciate what the CFP [certification] provides, it is by no means
considered the standard in our industry by the vast majority of the clients who seek financial planning help. When that
becomes the case (and I hope that it does), then I believe it to be more prudent to require the additional hours.
I would also hope that the board considers working with the major firms to coordinate the CE so duplication can be
reduced (ex. ethics course could satisfy both CE and firm element).
David B. Garing, CPA,
®
CFP
CE Proposed Changes
With your policy of having to pay you to review the continuing education courses I take through the American Institute of
CPA’s and the Texas Society of CPA’s along with your annual fee of $325.00 almost doubling the cost of maintaining
®
the privilege to use the CFP Marks I strongly considered surrendering my right to use the CFP Marks at the time of
renewal for the current period.
Increasing the CE hours required from 30 to 40, increasing the Ethics CE requirement from 2 hours to 4 hours and
implementing a “50% cap rule” will increase the cost to me even more and will probably be a deciding factor.
®
Dale Hearn, CFP ,
®
®
ChFC CRPC CMFC
sounds good to me!
I always get more than 40 hours anyway.
*I DO have some trouble with greatly increasing costs...which it sounds like it would b
**I’m getting older and studying is harder.....
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Desmond Daly, CFP
®
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Page 38 of 379
Comment
PLEASE do not add any more to our burden of doing business.
®
One year recently I had to do THREE ethics courses. One for the CFP [certification], one for the State of California
Insurance department and one for my broker dealer. It's as if requiring more and more CE the advisors will be better
educated or maybe the unethical will become ethical due to all the courses!
The REALITY is that by increasing all the required education for multiple source who do not coordinate with each other
that the advisor goal has become to "blow" through it as quick as possible.
The multiple CE requirements and the multiple other required courses have become self defeating.
I use to try to learn from CE etc but it is getting so repetitious that the learning component is been subdued to just
getting it behind me so I can get back to work is a difficult and stressful environment.
®
The cost of being a CFP [professional] has been rising and now adding more CE is just another straw on the camel's
back,
How many more straws until the back gives???
Damon M. DeLuties,
®
CFP
Dan Chester, CFP
®
Ce change
Why would they increase CE requirements from 2 to 4 credits for code of ethics. We worked very hard to get this
designation and run our practices. It just seems a bit ridiculous to change the rules that were in place for a long time. I
do not like the change.
CE changes
Present CE is fine! Why complicate it? The current list of proposed changes sound like how big can you make the list
of requirements, and how complicated. Some of it is downright unnecessary and is the work that happens when you
have a comittee.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Daniel Dorval, CFP
Subject
®
Continuing Education
Comments
Page 39 of 379
Comment
“Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.”
While I agree with the rationale that personal financial planning practices are fast changing and require ongoing learning
to maintain competency, I do not believe increasing CE requirements from 30 to 40 hours will meet the goal of improving
knowledge and learning. Most of my ongoing learning about financial planning tends to come from real world planning
experience and not from CE. Much of our CE requirement is filled in the most convenient (and least expensive) way
possible which does little to promote active learning. We are often completing CE for any number of reasons such as
firm element, insurance licensing, etc. and sometimes the CE will fill multiple requirements, but it often does not. We are
®
already completing far more than 40 hours of CE, but not all of it is available for CFP [certification] credit.
I think it would be more appropriate to add rules making existing CE requirements more effective than to arbitrarily add
another 10 hours that many practitioners will simply fill in the most convenient method possible without regard to
learning.
“Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.”
Ethics CE is ridiculous already so adding an additional 2 hours of “training” makes absolutely no sense. People do not
learn their ethics from CE. Unethical practitioners will be unethical regardless of their completing a couple extra hours of
ethics CE. Ethical practitioners will be ethical regardless of their completing a couple extra hours of ethics CE. Also,
ethics education does not tend to change so once you have taken an ethics CE course, you will likely end up taking
essentially the same course over and over and over again. This is similar to the firm element and insurance anti-money
laundering courses we are forced to take. They rarely change in any meaningful way and yet we are forced to take them
over and over and over again without gaining any tangible benefit.
There are many ethical considerations as part of our business so having an honest discussion about how to deal with
real and perceived conflicts of interest in an ethical manner makes some sense. However, arbitrarily adding an extra two
hours of CE requirement focused on ethics will add little if any value to the average practitioner in my opinion.
“Encouraging increased rigor and quality of all CE program delivery methods.”
In my opinion this should be a much more important goal for the CFP Board than arbitrarily adding more required CE
hours.
Dan L. Hammond,
®
CFP
Comments
I request that the number of hours remain at 30 for the two years. It is my opinion that this is sufficient to maintain
competency and professionalism. Furthermore, the two hours should remain for the “Ethics” requirement for the same
reasoning. Please take my comments under advisement.
Thomas Daniel Searles,
®
II, CFP , CEP, RFC
Proposed Revisions to CFP
CE Requirements
Please keep all CE as it is.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 40 of 379
Comment
Daniel B. Rohlfing,
®
CFP
RE: CE--comments
I would say I have no problem with tougher CE if it actually meant something. By that I mean I would support it if there
®
was some enforcement against and/or expulsion of CFP [professionals] who are incompetent or unethical. In addition,
instead of using that additional fee revenue for marketing (for which I have yet to see an advertisement in
print/TV/Internet or otherwise so not sure what we paid for) -- use that fee to work with firms and FINRA to help them
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promote the CFP [professionals] they already have on staff such that financial planning is being done by actual
financial planners rather than the faux planning all firms throw out there by unqualified individuals. In that sense a
tougher regimen of CE would be justified because it would mean more qualified planners and clients would know that
when they get financial planning, it has been performed by the appropriate people.
Danette Gay Lowe,
®
CFP
Continuing Education
As a practicing CFP [professional] who is also a financial advisor –series 7 and insurance licensed I’m frustrated by the
lack of crossover between the required continuing education. Our total obligation for CE is a lot more than the 30 hours
currently in place. So my argument is that in total we are getting more CE. If you raise the total number of hours
required by 33%, then you need to accept other forms of CE that we are obligated to take. There also needs to be a
consideration of the cost involved. You doubled our licensing fee for your public awareness campaign, that frankly
hasn’t brought us any business yet, and now you have to consider the financial cost of taking CE classes that I can’t use
anywhere else.
®
We all take pride in knowing what changes are happening in our industry and we typically learn about these changes
before anyone has a chance to put a class together.
Daniel M. McDermott,
®
ChFC, CFP
CFP Board CE Proposal
I have reviewed your proposal to increase the number of Continuing Education Credits from 30 to 40 hours and other
recommended changes and would like to provide additional input.
I fully support the increase in Continuing Education hours as well as the increase in the required number of Ethics hours
from 2 to 4. Additionally I support the % maximum for each discipline.
Since I am also a licensed registered representative and insurance agent I am required by both of these organizations to
meet continuing education requirements for these licenses. Some of the continuing education requirements are also
®
allowable CE credits for the CFP [certification]; however, many are not. Often the courses that are not eligible are very
difficult and practical to financial planning. I propose that the CFP Board give greater consideration to inclusion of these
outside CE courses.
My ultimate dream would be to have one (1) continuing education body\requirement for all of these organizations.
Thank you for your interest.
Daniel W. Leveroni,
®
CFP
Comments
To whom it may concern:
I feel the current structure works for me, especially since I am also regulated by FINRA, SEC, DOL, etc.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Darrell C. Claytor, CFP
®
Darrell Claytor
Page 41 of 379
Comment
I believe the current CE requirements are ample. I am sure that most planners exceed the CE requirement by a wide
margin, but adding more complexity is not a good idea at this time.
27 year - due paying member
Darrell W Shideler,
®
CLU, ChFC, CFP ,
LUTCF, FIC
CE proposed adjustments
In changing the CE requirements I would ask that a strong effort be made to coordinate with the state insurance
licensing departments so that any CE that is completed will be accepted by state insurance departments for their CE
requirements.
Darren R. Sardiga,
®
CFP
CE Comments
I strongly oppose increasing CE hours.
®
This process is burdensome enough and I am personally at the point which I may discontinue use of the CFP [mark]. I
know many of my peers who are very compentent but do not want to deal with the cost of compliance issues with very
®
little in perceived value to use the CFP marks.
®
While the education and coursework is good, I really do not perceive nor do my client perceive value in the CFP
[certification] standards for certifcation. The hassle for receiving "approved CE" and the fact is that much of what we
learn in our profession is hands on and a dynamic of our client and peer interaction with no CE credits. I really find
approved CE of little value and the hassle of documenting it burdensome. To add another 10 hours is of no benefit to me
or my clients. I perceive this more to be CYA for the CFP Board and to give the appearance of continuing education and
learning. Those likely to profit are the CE providers.
®
CFP [professionals] can take an online course concerning subject matter that they are already familiar and receive 10
credits hours for 2-3 hours of work. I rather this process not come to this. I am sure you are aware of this, which also
occurs on other profesions such as CPAs and CFAs.
I suggest any CE ethics should be available online in a time and cost effective way. In all honestly, I took my 2 hours of
ethics about one month ago and can not remember anything of relevance from it. I am not learning anything new from
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the material, it seems to be the same "stuff" year after year. CFP [professionals] primarily deal with ethical situations as
they arise based upon the facts and circumstances and consult peers or others professionals as appropriate. Common
sense goes a long way.
Please let me know if you have any questions.
Daryl Graham, CFP
®
Proposed CE Revisions
My overview of the proposed changes suggests program development evolving into the kind of “cottage industry” of
expensive courses demanding excessive time and money I endured for over 35 years to maintain my CPA licensure in
the State of Florida and Personal Financial Specialist designation before the AICPA. Though general knowledge in all
areas of financial planning is important and valuable, establishing criteria that have little relevance to the existing
®
practice of any particular CFP [certification] to satisfy continuing education requirements is an inefficient use of
resources.
Thank you for your time and consideration.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 42 of 379
Comment
Marlene A. Dattilo,
®
CFP , CFBS
comment / pending
changes
1. Increase in hours of CE required. Probably not practical for what you are trying to accomplish. If someone is
interested in keeping up with their industry they will embrace the changes and take on the education to remain
competitive within their field. More CE credits is not going to push those along who need to be more interested in this.
Those individual will find ways to acquire “bogus” credits to meet your new number.
2. I agree with giving credits for practice management and or pro bono programs. I pay a large fee to a strategic coach
®
who encourages me to be a better more efficient business owner. This also makes me a better CFP [professional]. I
bring a positive appearance to myself and this designation with my increased skills. I should receive credit for that.
®
3. Increasing Ethics Hours. Not a good idea and again will not solve your ethics issues with CFP [professionals]. You
cannot teach ethics. I think this was actually mentioned in my last ethics CE for my designation. By adding additional
credits you will not increase better behavior from individuals with the designation. If someone is ethical they will behave
that way in all areas of their life not just their professional life.
4. I am in a professional study group that is for professional with advance planning markets. Much of the material we
discuss is far more advanced than the online training programs that would currently qualify. It would be helpful to
acquire credit for this. It is 4 days annually.
David and Joyce
®
Dormady, CFP
CE changes
My wife and I are 20 year CFP [certification] recipients. We strenuously disagree with the thrust of the proposed
changes. Specifically, if you take away the self study option we will likely terminate our certification. You should move
very cautiously in this area.
Perhaps a grandfather provision could be crafted for those of us who have been around awhile.
Ce requirements
I am okay with the increase in ethics training by two hours. I fail to see the benefit of moving the 30 - 40 hours
requirement. Quality vs quantity should be the focus. Just putting in the hours seems like a poor way to improve the
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quality and competence of the CFP [certificant] practitioner. Thanks,
Response to proposed
changes
Your proposal seems to me to be a well thoughtful and comprehensive approach. I support it 100%.
Proposed Revisions to CE
Requirement
I am NOT in support of the proposed CE changes included in your email dated Friday, August 17th. The current CE
requirements are more than adequate. In fact, the actual time required to complete the current requirements rivals that
®
of my CPA certification, due to the manner in which the CFP [certification] CE hours are calculated.
Dave Horan, CFP
®
David E. Jones, CFP
®
J. David McCurdy, CPA,
®
CFP
®
Additionally, while I have your kind attention, the increased annual fees to cover the marketing campaign have not paid
®
off in my opinion. The “CFP [certification] Commercial” is ineffective and off-putting, in my opinion.
David Buskirk, CFP
®
re: proposed CE changes
Why stop at 40 hours?
Why not 60?
Why not 80?
And why is 4 hours of ethics so much better for us than 2 hours?
Ridiculous
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
David R. Butts, CFP ,
CMFC
Continuing Education
Proposal
Page 43 of 379
Comment
Give us a break. Between requirements from B/Ds and State Insurance Departments we are already
OVERBURDENED with continuing education requirements and now the Board wants to increase their requirement by
10 hours. With all the increased regulatory time requirements it would be nice to know the Board is actually on our side.
®
Our C.E. requirements are already more stringent than they need to be. At a time when we need more CFP
[professionals] to increase our presence in the Financial Planning community, the Board wants to make it even more
difficult for no good reason. What?
Please, do not increase the hours of C.E. required. What a dumb, administrative thing to suggest.
David W. Hayes, CFP
®
Concerning the Proposed
Change in CPE
Requirements
My main concern in the proposed changes is that they need to intentionally overlap with other professional designations’
requirements. I need 28 hours plus 2 hours ethics per year for my Enrolled Agent standing. Currently, I am able to
®
satisfy most of this and the CFP [certification] requirement together. Were you to limit this by, for example, limiting the
®
ability to rely on tax-related coursework to meet the CFP [certification] requirement while simultaneously increasing the
®
CFP [certification] CPE required hours, you could put me in a position where I would have to decide between one or the
other.
I realize that I am a bit of an anomaly since I also do not have a securities license.
Thank you.
David L. Hoyer, CFP
®
Proposed CE Credit
Changes
I applaud The CFP Board’s Council on Education for proposing to stiffen the continuing education credit requirements.
®
The primary benefit will be to strengthen the CFP [certification] designation by requiring more continuing education and
more balanced subject coverage with the 50% rule. As an active FPA Chapter & FPA National Pro Bono volunteer and
current Chapter board member I welcome the proposed changes as they will offer some incentive for additional pro
bono volunteerism. Chapter membership and attendance at Chapter meetings will also be enhanced as members seek
to obtain the additional CE credits required in the subjects that they need.
Other benefits of the proposed changes which I really like are the 4 hours of practice management CEs per reporting
period and increasing the ethics requirement. Practice management sessions on subjects such as how to value and
sell a financial practice are extremely important to practitioners and the profession. Effectively integrating young
planners into financial planning practices and transitioning ownership of practices to the next generation is not always
easy. This will become increasingly important to the profession in order to retain good young planners and insure that a
sufficient number of practitioners will be available in 10 and 20 years as older established planners retire.
Thank you for these proposed changes and I hope that they are approved in November.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
David J. Levine, CFP
®
New CE requirements
Page 44 of 379
Comment
Regarding the new proposed CE requirements...
®
I think you need to take into account that many people such as myself hold the CFP [certification] designation but are
not practicing financial planners. I put in a tremendous amount of effort to get this designation and I am very upset with
the way things are changing. I am a life insurance wholesaler and work with financial planners but do not practice
financial planning myself. If you want to increase these requirements for people that hold themselves out as financial
planners and that comprises the majority of their time, that is one thing. However, there are many people like myself
where these additional requirements create an unnecessary burden. It is bad enough that you doubled our dues (again,
being that I don't hold myself out as a financial planner, I don't really get much benefit out of all of this extra spending
that is going on) but now with these additional requirements, I think you will see many people like myself dropping off
your rolls.
If you feel it is absolutely necessary to make changes, it should only effect practicing financial planners.
Thank you for your time.
David P. Robinson,
®
CFP
David Strege, CFP
®
David H. Jacobsmeyer,
®
CFP
®
Proposed CE revisions Feedback
Since many CFP certificants are now between the ages of 55-60, we are now more focused on practice management
issues than in years past. For this reason, I suggest that up to five (5) hours of CE credit available for this topic area.
I also vote for three (3) hours of ethics requirement instead of four.
In favor of most of the
proposed CFP CE
requirement changes
After reviewing the proposed CE requirement changes I am personally in favor of all of them except this one:
CE
The new requirements are well intentioned but are likely to end the qualification of firm and wholesaler CE. They will be
a windfall for the firms that sell CE classes. To simultaneously increase the requirement while eliminating many of the
current sources is not going to help anyone but the online CE venders. Increase the requirement but create more, not
less, access to CE. For those of us on the firm’s speaking circuit a one hour presentation requires at least four hours of
research and prep. That should be valued more highly.
• Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
The rationale seems to argue against eliminating CE credit for completing professional licenses and designation
examinations. If program content or coursework may be eligible if consistent with CE topics and other requirements
then how can you eliminate it for completing the examination. If there is a passing grade on the examination that proves
a required degree of knowledge attained to receive CE credit on approved CE topics. You don’t want them claiming CE
credit if they don’t pass the exam. Many top notch professional certification programs that have CE requirements allow
some of the fulfillment to come from passing other designation exams. So personally I don’t see verification of best
practices of professional certification programs that agree with this proposal.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
David J. Pater, CFP
®
proposed changes
Page 45 of 379
Comment
Don't care for the changes, most qualified planners already spend many more hours on continuing education that just
those hours that are approved for cfp credit.
We take personal accountability to keep ourselves current on investment, tax, retirement planning changes etc. I really
don't need more requirements or rules or to complicate things with stipulations that only a certain percentage of courses
can fit within this category etc. We'll spend more time tracking things and double checking to make sure we are within all
the new rules than is needed.
David Wilkins, CFP
®
comments on CE changes
I am generally opposed to the increase in CE hours from 30 to 40, though I support more rigor and diversity in study
areas. I can tell you that in the 13+/- years since I have taken CE, I have received much more benefit from working with
clients and using the marks than I ever did from maintaining the marks. Therefore I think some credit should be given
for client-facing individuals who use their training in their daily job function.
Thank you
®
Dan E. Droeg, CFP ,
MBA
Increasing and Improving
CE requirements
I am in favor of increasing the total required CE hours each two year cycle from 30 to 40, providing the quality of the CE
offerings can be improved. Currently many of the courses available through the traditional channels aren't challenging
and offer little in the way of new information. If this is to be a true continuing education program it really must afford the
membership an opportunity to expand their knowledge and not just test how well they've read a passage or listened to a
case study. This does not mean merely increasing the volume of material to be digested in order to pass a 3 hour
course, it means increasing the content value of the material.
With regard to increasing the required hours of ethics courses from 2 to 4, ethical behavior isn't a function of how many
hours of courses we take nor would expanding the hours guarantee more ethical behavior. In that vein, ethical behavior
isn't something that's based on a sliding scale, that is, having 4 hours of ethics courses vs. 2 hours won't make someone
twice as ethical. There is really only so much to be said in an ethics curriculum.
In summary, merely increasing the number of CE hours will not improve the quality of our designation and the value of
®
being a CFP [professional]. Improving the quality of the coursework is the key. More challenging CE courses will do
more to weed out the substandard practitioners than more hours of courses.
Debra Behm, CPA,
®
CFP
CE requirements
I have two comments/suggestions regarding the proposed changes to CE. 1) Allow up to 10 CE hours to carry forward
to the next renewal period if someone has more than the required 30-40 hours, and 2) keep the required hours to 30 if
an individual also holds a CPA license. As a CPA I am required to get 80 hours of CPE every two years. Many of the
®
seminar topics are very relevant to the CFP [certification] profession as well.
Thank you.
Debra L. Gallant, CFP
®
Proposal sounds good to
me
I welcome increased CEU requirements from the CFP Board, particularly as a NAPFA member I already need to have
60 CEUs each year anyway.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Anthony J.
®
DeGerolamo, CFP
®
CLU
Increasing continuing ed
requirements
Page 46 of 379
Comment
I support ongoing continuing education programs, but I must say our industry is becoming onerous with
®
requirements/education. Besides the CFP [certification] continuing ed requirements, prior to any possible increased
requirements, I have responsibility for ongoing education for my Series 7 and life/accident/annuity insurance licenses. I
also have ongoing continuing education as a requirement of my broker dealer and also FINRA. Frankly, a portion is
duplication without duplicate credit.
I submit, to you, that increasing the continuing education requirements is just another burden to us in the field.
Thank you for your consideration.
Cathy Robertson Del
®
Nero, CFP
Enhanced CE requirements
I am begging you all not to implement these changes.
®
I have been a CFP [professional] since 1989. I have worked for “wire houses” or large brokerages from 1986 through
now. I am bombarded with CE requirements. Bombarded.
I am an adult and am well-aware of what I need to know, for what I need to update knowledge, and in what I ought be
competent. I am mandated by my own institution, as well as the government, to do copious amounts of CE. I do not
®
want to be required to do 10 more hours for CFP [certification] or to increase to 4 hours of Ethics – I do enough. All
year long. At the expense of time I need to spend working with my clients and marketing for new ones.
Please reconsider this proposal.
®
CE requirements
Your CE reporting requirement is already very cumbersome. Please don’t make it more complicated.
Dennis J. Foegen,
®
AAMS, CFP
Comments on Additional
CE for CFP's
It seems to me that increasing the number of hours just adds more volume of time devoted to trying to meet those
requirements without necessarily increase the quality and variety of content in those hours. Most of us already have 24
hours or more of insurance CE and I don’t remember how many hours to meet SEC and FINRA requirements, both
compliance and ethics. In addition we have to have product specific training on insurances, annuities, and non-publicly
trade investments. In other words, we spend numerous hours on training without a lot of quality. It seems to me it
®
would be better to have more structured requirements that covers the specific competency needs of a practicing CFP
[professional] and not so many hours.
Dennis M. Allen, CPA,
®
CFP
Proposed changes
I would like to comment on the proposal to increase the number of ethics hours required for license renewal.
Dena M. Minning, CFP
While I wholeheartedly agree that licensees should be held to high ethical standards, I truly think that additional hours of
ethics training would be a waste. Currently, the ethics courses are essentially a review of the rules and procedures
related to disciplinary actions taken by the Board against a licensee. I fully understand why this exercise is of benefit.
However, in reality, no ethics course is capable of bestowing ethics on a person that doesn't already have them. If you
didn't have any before the course, you're not going to have them after the course. Adding additional hours of ethics
training is just window dressing and serves no useful purpose.
Please reconsider this proposal.
Dennis Vaughan, CFP
®
As long as these proposed changes do not take place until after the current CEU cycle (which is 4-1-12 to 3-31-14, in
my case), I’m fine with the proposed changes.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Carol J. Hays, CFP
®
Diane T. McIntee, CFP
®
Page 47 of 379
Comment
®
Changes to CE
I cannot believe you are even considering changing the CE requirements, not in less you want to lower them. If a CFP
[professional] is active in the business the CE hours are mostly a waste of time.
®
If you increase the hours, neither myself of my husband will renew our CFP [certification]. We have been in the
®
business for over 25 years and have never been asked if we have a CFP [certification]. Most of our clients have never
®
heard of CFP [certification] or what it stands for until we explain the credential.
You increase the annual fee and now you are trying to take more time from our business. What a waste. We have to
take 20 hours for insurance every 2 years and 4 or 5 courses for our broker- dealer each year, that is enough.
Changes to CE
Requirements
I have reveiwed the proposed changes to the CE requirements and have the following comments:
1) I do not oppose the increase in hours, and do like the proposal to increase rigor, as simply requiring more hours will
not increase competancy unless you increase rigor.
2) I would like to see it specifically stated that hours would be granted for participation in a broader menu of courses,
such as CPA CPE courses, Legal CE, State Insurance courses, and the like.
3) Re: Ethics requirement increases - this is not a "big deal", but frankly, this is the most useless CE I take! It is difficult
to find ethics CE that is not costly and redundant. Those of us with broker/dealers also take in-house Ethics CE anyway.
I would keep this at 2 hours.
4) Re: the 50% cap - this I am against. My reason is that if you develop a practice with a concentration and you are a
true specialist, it makes sense that you would concentrate your CE in the area of your specialization. Also, if your
practice does not include clients that have great, for example, estate issues, why take additional CE in Estate Planning if
you have no need for that? I believe the practicioner should be able to determine where their CE needs lie and take
courses that they will be able to apply to their own practice. This, to me, is common sense.
Thank you for the opportunity to provide my feedback. I hope these comments are helpful.
Thomas Dias, CFP
®
Dumb idea to increase the CE just a way for you guys to make more money what a joke!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Richard M. Ringgold,
®
CFP
comments
Page 48 of 379
Comment
Why fool around with 40 hrs of CE vs. 30? Heck, 50 is better than 40, right, so why fool around? Brothers, we must be
committed to excellence!
Alternate solution: really shape up, eliminate CE completely, and require all Certificants to fully retest every 3 years.
Yep, retest; we want to be assured that everyone is current in their knowledge, right? Require everyone to take the new
courses , too. Come to think of it, let’s jump up to 10 courses, similar to 30 hrs for a degree, has a nice ring to it. This
paves the way for a masters level certification program.
Let’s not neglect our civic responsibilities either. Make everyone perform 100 hrs of pro bono service; this will really
resonate with the public. Maybe even half of that in a third world country or at least in an inter-city setting. We simply
can’t neglect giving financial advice to people without money.
I am on a roll here, so let’s take on a few other issues that properly concern the Board…
The fiduciary standard brouhaha: bite the bullet, henceforth everyone must be fee-only, no more sleazy commissions as
that is surely beneath our professional dignity. No insurance salesmen; hourly charges only. By the way, AUM is really
®
a thinly disguised commission, so out with RIA’s too. No more attorneys or CPA’s as CFP [professionals] either, can’t
have obvious conflicts of interests!
The government regulation/SRO issue: By inspection the feds know an awful lot about financial disasters and corruption,
so please advocate to harness that resource and create a new Financial Services cabinet position and write 10’s of
thousands of pages of new law to regulate ourselves to honesty and integrity. Let’s push real hard to make the financial
services industry achieve the successes of the medical industry. As a point of departure, I say everyone must purchase
50 hrs/yr of CFP advice or pay a tax!
®
If we work at it, I expect that by 2015 there will be, maybe, 10 CFP [professionals] in the USA, but the public will
rightfully have complete confidence in them.
Or maybe realize that you are over steering the ship, grasshopper.
Richard DiLeonardo,
®
®
CFP , CRPC
Don C. Hubner, CFP
®
Ce credit changes
Whatever changes you make by increasing hours only helps. If this is going to cost us more money I am against any
changes. What do you do for the annual fee? Please tell me. I earned the title and continue to meet all the standards.
Why do you change money and don't provide us with much. Please explain to me.
new potential changes
I will likely resign my membership and certification if you choose to proceed with the changes. With my series 7 license
ce requirements along with my insurance ce requirments, it is becoming overwhelming! I have to take 3 different ethics
courses for each of these licenses and now you are proposing more? Why don't these reciprocate? It appears to me that
the proposed changes most benefits the ce industry!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
B. Don Snyder, MBA,
®
CFP
Proposed changes to CE
requirements
Page 49 of 379
Comment
I am not in favor of any increase in CE requirement. We are increasingly becoming more burdened with regulatory
requirements to the point of negatively impacting our ability to effectively serve clients and market our business. If you
want to narrow the types of education required to be more impactful, I am fine with that.
If you take my firm element with my broker / dealer, my insurance CE requirements, my long-term care state
®
requirements, my CFP [certification] requirements, and others….It is becoming quite burdensome. In addition, there
®
seems to be a decent amount of overlap among some agencies. I am proud of my CFP [certification] designation, but
adding more hours is not a solution in my opinion.
Thanks,
®
I vote no
The work load is enough. Additional CE requirements does not make for a better CFP [professional].
®
I have been a CFP since
1981 my thoughts
I just scanned the proposed changes....I am very distraught about the possibility of 40 hours instead of 30 for each
cycle....I am also a ChFC and CLU with the American College with separate CE requirements...this is all overwhelming
®
to me.....Karen Schaeffer just told me that U.S. CFP [certification] CE requirements are lower than the rest of the world
and the U.S. Board wants to keep up...I can see the sense in some of the proposed changes but changing to 40 hours
®
may be a deal breaker for me...I may give up my CFP [certification]...I am 65 years old and do not work as much as I
®
used to ....are there lower CE requirements after age 65 or 30 years as a CFP [professional]? If you would call and let
me know I would be most appreciative
Proposed Changes to CE
Requirements
Hi! I don’t mind the increase in CE credits that are being proposed. I attend numerous conferences so it is easy to
acquire CE credits. However, tracking them is a hassle. I love the fact that the FPA submits the CE credits to the CFP
board. Unfortunately, NAPFA and many other sources do not. It is the administrative function that is a chore.
Donald G Vliet, CFP
Donald Simon, CFP
Donna Skeels Cygan,
®
CFP , MBA
®
My other comment is regarding increasing the ethics requirement. I try to attend an ethics course when I see it on a
conference schedule. However, many conferences do not provide an ethics course. My vote would be to leave the
ethics requirement at 2 hours. If the courses are not readily available, then it requires time to find a course online to
complete the requirement. I am already “ethical”, and I prefer to limit the administrative chores necessary and keep
more hours available for my clients. This is analogous to the requirements for compliance that RIAs face. Compliance
could easily be a part-time job. There are only 24 hours in a day, and many of us who are getting older are trying to
“have a life”. I prefer to simplify the “back office” functions of tracking CE credits, unnecessary compliance
requirements, etc. so I can devote more time to clients and my family.
If you would like to discuss these suggestions, please feel free to call me.
Thanks!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Doug Kinsey, CFP ,
®
AIFA
CE Requirements
Page 50 of 379
Comment
With reference to your proposed changes, I am very sensitive to additional CE requirements, as I have had my CFP
[certification], NAPFA, Insurance, AIFA and CDFA requirements all due this year.
®
Here are my thoughts:
1. 30 hours is adequate.
2. Practice management should be granted at least 8 hours. Not enough attention is placed on this by ANY
organization currently.
3. 2 Hours is adequate for ethics.
4. Eliminating CE credit for completing professional licenses and designation examinations - Seriously? This is
ridiculous. Receiving CE credit helps offset the cost of obtaining additional certifications and provides some incentive to
do so.
5. Reviewing online courses for academic credit delivered by regionally accredited colleges or universities....
NOT necessary, and only serves to further the interests of traditional education providers, who really have been lacking
in relevant financial planning education. Why support institutions who really serve little purpose in ongoing professional
education?
These are my initial comments. Much of the CE industry is a complete joke as it is, and the requirements of the CFP
board, and other organizations don't really serve much of a purpose at this time. After a certain point of time, there
really isn't much new that happens in this industry that requires more training except perhaps estate planning and tax.
Sorry to burst your bubble, but this profession would be better served by delivering practice management and business
management skills to advisors so that they can improve and grow the business.
Doug O'Rear, CFP
®
Doug Roberts, CFP
®
Since I am already doing most of what is being proposed I don't have a problem for now. The expanded ethics format
is confusing. Please clarify exactly how this would be verifies and implemented. Also the pro bono work done through
my chapter sponsored projects should be a litmus test for acceptable projects.
Comments and Feedback
for Continuing Education
Requirement
Does the board feel that 30 hours is not sufficient? I am fine with moving this to 40 hours as long as it is not being done
just to "sound better".
I do not think that Pro-Bono work should count towards CE credit. I do not believe this falls into the learning category
and would weaken the CE requirement.
I disagree with the proposed elimination of CE credit for other designations and programs. This can be an ideal way to
increase skills in specific practice areas.
I think ethics should be left at 2 hours. Good CE programs will usually address ethics as part of the material covered.
Douglas R Oleson,
®
®
®
CFP , ChFC , CASL
CE
I disagree with almost all of your proposals regarding CE. It is already nearly too expensive to maintain the CFP
[certification] designation, and now you want us to spend even more money on more credits.
I still haven't seen any results of your expensive and nearly invisible marketing/advertising program.
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Dudley Barnes, CFP
Subject
®
Comments
Page 51 of 379
Comment
®
I have been a CFP [professional] since 1981 and have practiced financial planning since that time. I proudly tell clients
®
and friends that I am a CFP [professional] and a practicing financial planner.
®
®
I have 3 candidates in the CFP [certification] program, a partner CFP [professional] and two partner CPA’s. My junior
®
partners are working hard to complete their requirements for CFP [certification].
®
We now are getting 11 hours of insurance CE, 12 of Finra, and 30 of CFP [certification hours]. There is NO reason to
require more CE of us. Even though I am 64 and a long term mark holder, I can assure you that I am extremely current
on what’s happening in the world of investing and planning. What will 2 more hours of ethnics do for us? If we have a
dishonest member, 2 more hours will do nothing to bring him or her into compliance.
®
The CFP [certification] exam requirements are too hard and the exam is not testing our new members on the real world
®
in which we practice. We need more CFP [professionals] and not ones who can just pass the academics but those with
practical skills in communication and investing.
Please don’t make it so difficult that no one will want to enter our business.
Karl A. Dunajcik, CFP
Comment Regarding CE
Changes for maintaining
CFP credential
I appreciate the effort that has gone into the proposed changes in CE requirements and in general I am in favor of doing
®
what is deemed appropriate to make sure the CFP [certification] credential is recognized as valid and important as
other professional designations.
Just reading this through though it seems that the additions/changes add too much complexity in terms of what qualifies
for CE credit. I don’t have an alternative solution I am just saying that it seems like too many exceptions and rules are
®
being created and it will cause difficulty for those of us trying to maintain our CFP [certification] credential and it will
create a great deal of headaches in terms of policing the members as to whether they met the CE requirement. I am
always a fan of the simpler the better.
J. Charles (Chuck)
Dunham,
®
®
CFP , CRPC
Dwight Erskine, CFP
®
®
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Additional CFP [certification] requirements reminds me of more regulation from the federal government, just different
entities burdening the practitioner with more non-productive issues to handle. An individual either conducts himself
®
ethically or does not, neither the government nor the CFP Board can dictate ethics. As a CFP practitioner, I need to
spend my time in front of clients or potential clients, not negotiating the intricacies of how to meet additional CE
requirements.
CE proposals
Yes on everything except the ethics model.
Actually, one hour is more than enough, and if anyone needs the present two hours or the proposed four hours, they
probably aren’t going to be more ethical than those who may need thirty hours of ethics CE.
A renewal of the basics – even yearly – is a good idea. But anything beyond one hour generally puts to sleep half of the
classroom, in my observation. Isn’t the theory to just remind everyone to be thinking about consequences, rather than
®
trying to get CFP [professionals] registrants to memorize a bunch of rules and regulations?
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Jeffrey A. Earl, CFP ,
JD
Comments on CE
requirements
Page 52 of 379
Comment
®
The need to require CFP [professionals] to further our education is a very valid and important issue. However, many of
us hold dual professional designations and multiple licenses with various Federal, State and organizational entities.
Each of which have continuing education requirements that they feel are valid for the licensee in that particular State or
®
organization. For instance I am a CFP [professional], a member of the Virginia Bar (JD) and am licensed by four
different state insurance commissioners for various life and investments products. As a financial professional it is
impossible to meet the educational requirements separately for each of these organizations. We need to start
automatically accepting CE course already approved by an equivalent regulatory body such as the legal, accounting and
insurance industry.
Each of these entities all agree that more and more education is required for financial advisors to do our job properly.
The problem lays in the fact that each of the regulatory bodies employ a review process for continuing education specific
own industry. Most times any particular course offered would satisfy CE guidelines of each regulatory body separately.
Today when a provider of an educational program wants authority for their courses to receive CE credit they need to
register each course with each governing body for each designation that the course could satisfy.
To control costs these companies complete a cost benefit analysis of what audience would most likely attend a specific
course and then they apply for continuing educational credits from those specified regulatory bodies. They cannot and
usually will not expend the recourses required to get CE credit approval for each and every course from every
organization that it's members would benefit from.
For instance, if the local company offers a CE approved course for attorneys in Virginia, Maryland and the District of
Columbia on estate planning principals. Why must this same course then be reapproved by the CFP board? At some
point the CFP board needs to accept that if the bar associations of Virginia, Maryland and the District of Columbia have
®
approved the course on estate planning for attorneys that it most likely will satisfy a separate CFP certification process.
The bottom line is I agree that more education is needed in general. However we need to make sure that the forty hours
®
needed for the CFP [certification] designation are not cumulative with the 21 hours required by Virginia insurance
department and the thirty hours required by the Virginia bar association. It is getting harder and harder to find courses
that will satisfy all of the competing CE requirements at one time.
Edward P. Carvalho,
®
CFP , CLU, LUTCF
Proposed CE Changes
®
I am writing to voice my opposition to the proposed CE changes. I voluntarily became a CFP [professional] for the skills
it taught me.
It is complicated enough complying with the regulatory authorities that I am required to deal with. I do not appreciate
being regulated and potentially punished by an association I voluntarily belong to. Keep it up, soon you will have fewer
member to deal with.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Edward J. King, CFP ,
MSFS
New CE requirements
Page 53 of 379
Comment
®
Really??? I know from a desk in CFP [professional] world, this sounds really smart. (I am surprised you didn't raise it
to 80 hours to make sure everyone stays current on financial planning etc. And to make our industry more respected!)
with all the insurance requirements and broker dealer training(AML etc) we are getting killed with tracking CE credits.
Do you really think that these increases and changes are going to make that much of a difference? That somehow this
will help clean out the bad apples?
®
Please feel free to contact me if you would like to discuss this topic. I am begging you to speak with other CFP
[professionals] out there and I am sure you will hear the same things. Why not make our broker dealer CE credits
eligible? Have the people who are making these rules ever worked in the field?
Thanks,
Edward J. Lizotte,
®
®
CFP , MBA, ChFC
Comments
®
I am patently against needing to earn more CE credits and more complex rules to maintain my CFP [certification]
designation. I am a 22 year practitioner with a sterling record. Between the requirements in place and the other training I
must do for my licenses, I receive way more training that the 30 hours required by the Board already.
In fact, I feel there should be an Emeritus program that exempts exceptional long term practitioners from the current
level as other designations (ChFC) and professions have. Why not a heavier burden of ethics courses for those
practitioners with ethical issues and complaints?
People would be required to fulfill greater requirements only when they are not demonstrating a professional and ethical
commitment to the marks. Instead, your suggestion burdens all the other professionals for the actions of a few.
Please call or write me if you wish to discuss further.
Thank you for your time.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Elaine Manley, CFP
®
Fw: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Page 54 of 379
Comment
Thank you for requesting input. I will try to keep this as succinct as possible.
1. No. Please do not increase the requirement from 30 to 40 hours. The amount of training we have to do for
insurance and annuities and Compliance and FINRA has increased dramatically. I am spending at least another 20
hours if not more on those requirements.
2. I'm neutral on granting credit.
3. Ethics - prefer not to go to 4 hours. I found the 2 hour was sufficient.
4. Yes on the expansion of what qualifies.
5. Yes on the 50% cap rule - I agree we need training in many areas.
6. Prefer you not eliminate the credit as that is still appropriate training and should count.
7. Neutral on the Academic training
8. No - as I have found every course I've taken has had quality content.
Thank you for listening.
Eliot Weissberg, CFP
®
new CE
Jeffrey Christopher,
®
CFP
Just a quick note opposing the changes.
I also don't understand the possible decision to add an extra 10 hours of CE reqirements. In the field I am required to
®
complete CE credits for CFP [certification], state insurance and FINRA. It's too much to add an additonal 10 hours. I
am writing you with my comments as per the recommendation of your call center. Thank you.
E. Karen Shasky, CFP
®
re: CE proposed changes
It is my viewpoint that the CE requirements should NOT be changed.
Thanks,
®
Elliott Chernin, CFP
It seems to me, a long term practitioner with an unblemished record, that we ought to receive some “credit” for our
longevity and not need as many hours of continuing education as someone with, say, less than 10 years or 15 years or
20 years.
I agree that things change and it is important to keep up to date, but they don’t change an additional 10 hours worth
when we already have 30 hours to do.
All that happens with the additional hours requirement is that we look for what is fast and easy because it is so
duplicative.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
®
John Englin, CFP ,
ChFC
Page 55 of 379
Subject
Comment
Proposed changes to CFP
CE requirements
I like the system the way it is and I strongly oppose the proposals that are being considered at this time. Most CFP
®
[professionals] already have many other ongoing CE requirements they must fulfill in addition to their CFP [certification]
®
requirements. Those additional requirements do not always qualify for CFP [certification] CE credits (insurance,
®
securities, etc.). These new proposed requirements would force CFP Professionals to spend substantially more time
simply trying to figure out if the CE’s they are looking into will actually count toward their 40 hours or not. This would be
time spent outside of the classroom figuring out which classes to take and when to take them. That equates to
additional time that is not available to take care of what is most important, helping our clients create successful financial
futures.
®
On one other point, requiring additional ethics hours seems silly to me and is overkill. The 2 ethics hours are fine, but,
unfortunately, requiring 4 hours, or even 10 hours, of ethics every 2 years will not turn someone who is “unethical” into
someone who is “ethical”. We all know right from wrong and taking even more classes on “ethics” does nothing to
change the heart and soul of people that do not possess high integrity. 2 hours spent every 2 years on ethics seems
like a sensible amount of time in order to keep current on new compliance issues, etc.
®
So, if this were to be a vote of CFP Professionals, and my choices were to leave it as is or go with all of the new
proposals, there would be no question that I would vote to leave this as is.
Thank you for your consideration of my concerns.
Blake P. Epstein, CFP
Eric Beyrich, CFA,
®
CFP (and a whole
bunch of other things
besides).
®
The current amount of CE credits is more than enough. Increasing from 30 to 40 hrs will be an unnecessary burden.
Proposed changes to CE
requirements
I agree with the intent of the CFP Board to review the CE credit program, with the intent of making it "better." However,
the proposed changes to the CE requirement seem more regressive than superior to the current standards, as they
®
propose to make sustaining one's CFP [certification] credential more costly and burdensome than it already is, instead
of making the process easier and more informative. Consequently, I do not support the suggested changes. However, I
®
do support the idea of improving the CFP [certification] program, so let's go through each of the proposals and talk
®
about some constructive changes that might advance the objective of improving the competence of the CFP
[professional] community, and lessen, instead of increase the headache and costs associated with maintaining the
credential.
The proposed changes under consideration are:
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations. The proposed increase in required hours is consistent with
recommendations from CFP Board’s 2007 and 2008 Education Task Forces.
My belief. The # of CE hours is a false standard, as it does not really measure anything -- except perhaps serving as a
®
rate-basis for the cottage industry that has sprung up selling approved CFP [professional] courses to those like me,
who have to hustle around every couple of years to meet the standard. IMHO, The CE requirement should be made up
®
100% of FREE, Internet-graded multiple choice competency exams, across CFP [certification] topic areas. Equally, the
materials to prepare for them should be posted for FREE by the CFP board for all to take, whenever they wish. In this
fashion, the CFP Board could truly be the standard bearer for CFP knowledge.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 56 of 379
Comment
o Practice management CE programs. Defined as programs focused on the planning, development and management of
®
a CFP professional’s business operations, office management, business model design, budgeting processes and
leadership. *Scroll down for more comments*
o Pro Bono (volunteer personal delivery of financial planning) services. These activities must be supervised by a
registered CE Sponsor organization and will be accepted for 1 hour CE credit per 4 hours pro bono service.
Rationale: Recognize the importance practice management plays in the delivery of competent and ethical professional
financial planning services to clients. Encourage pro bono service for the public benefit.
My belief. Again, the # of credits is meaningless. However, it would be helpful if the CFP board would compile best
®
practices coursework / case studies and offer them as free PDF downloads to CFP [professional] members. Offering
®
free materials that would improve CFP [professionals] holders business practices would be a tangible benefit to many
®
CFP [professionals] holders, and thereby increase the value of the designation and the CFP Board to members.
Instead of compelling people to pay money to take potentially worthless courses, this free choice method would allow
individuals to optimally allocate their time and resources. It would cost the CFP board some time and effort to compile
®
these materials, and perhaps a fruitful way for CFP [professionals] holders to demonstrate competence and earn
"points" towards maintaining their credential, the Board could email requests for copywrite-free articles on various topics
that would be helpful to the community, for expressly this purpose.
Offering pro bono work seems wholly unrelated to competence. One could give a lot of bad free advice and maintain
®
their CFP [certification], which is the opposite for having a CE requirement in the first place.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.
My belief. The current ethics requirement seems more than adequate and redundant. Having done it for a number of
cycles now, I would prefer to spend less time on this topic and more time on things that would improve my scope of
competence. If you want to change this topic, why not offer an elective program in ethics, that talks about the
®
philosophy and psychology of doing the right and wrong thing, as opposed to having CFP [professionals] regurgitate
®
the CFP [certification] code, again and again.
• Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following:
o Participation in Registered Program Financial Planning Development ("capstone") course grading panels. These
activities must be verified with documentation of active participation, written assessments and qualitative feedback;
o Study Group Activities that meet certain guidelines;
o Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
Rationale: Encourage body of knowledge expansion and no cost CE opportunities.
My belief. Giving credit for grading panels and study group activities seems nebulous to absurd. Once an answer sheet
its handed out, a monkey can score and grade tests, so how meritous might this activity be? On the second topic, study
groups may or may not possess rigor or substance, and the effort needed to ascertain these subjective qualities seems
likely to be excessive and uneven. However, Publishing research in serious financial journals, or even popular
magazines might be an excellent way to earn CE credits and share knowledge. One question is, who will determine
how many "points is an article worth?" The one point you make here that I really like is the no cost CE opportunities.
®
Indeed, I don't think there should be any incremental cost to CFP certificants to maintain their credentials, other than
the effort needed to remain competent.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 57 of 379
Comment
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule."
Rationale: Ensure diversity of learning experiences across breadth of planning topics.
My belief. Since there is very little correlation between CE credit hours and actual effort, I don't think this rule change
will accomplish the objective of maintaining competence across a broad base of knowledge. However, if the Board
would like th change the requirement to something like: 2 hours minimum across 5 topic areas, I would be OK with that.
However, I am against increasing the number of CE hours. Just working forces one to maintain competence in ways
that are not formally recognized. So, jumping through the hoops it takes to meet the CE is nothing more than a burden
®
to most CFP [professionals] holders, and does little to improve their competence.
• Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
®
My belief. You should encourage CFP [professionals] to pursue as many other related forms of education and
®
licensure as possible, and give them full credit for it. By not giving CFP [professionals] credit for these activities and
potentially increasing the amount of CE that they must do, you would be doing the opposite and would likely reduce the
®
qualifications of the CFP [professional] community, as there are only so many hours available to study and work.
Again, not to be negative, but this is truly a ridiculous suggestion.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
Rationale: Recognize the quality control measures that regionally accredited institutions are required to incorporate in
the development and delivery of self-study courses offered for academic credit.
®
My belief. All this would do is increase the cost of CE, and probably convince folks like me to let my CFP [certification]
lapse, as the cost to maintain it would exceed the benefits.
• Encouraging increased rigor and quality of all CE program delivery methods.
®
Rationale: Help ensure that CE programs available to CFP professionals contribute to their professional competency.
My belief. I think works like "rigor" and "quality" sound good, until you realize that the only benefit of having a CE
requirement is to make sure folks stay current with the rules and best practices of the profession, and doing usually
happens naturally, without great rigor, except in paying attention. The second word "quality" is a subjective term. If an
article is published by an unknown, but he conveys a topic clearly, is that of less merit than a cumbersome article written
by a member of the CFP Board? I would not say so, but I've seen many folks in credential programs use them as selfenrichment vehicles for approved faculty, and this suggestion, along with the others in this proposal, smack of that
direction.
Hopefully, this feedback is helpful to you. If you would like to discuss this topic further, please write back. If you would
like to discuss these ideas over the phone, please send me your number and a convenient time to call.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Eric Cramer, CFP ,
®
CFA
CE Comments
Page 58 of 379
Comment
®
I’ve read the proposed revisions and believe that the increase in required hours is too burdensome. Every CFP
practitioner I know is very busy, on a daily basis, furthering their personal knowledge and delivering planning services to
investors.
And while it may be tempting to increase CE requirements to some level that absolutely ensures that EVERY certificate
®
holder is up-to-date, where is the end? Shouldn’t we all just take the CFP certification tests again every two years?
At some point, the Board must simply trust that if a certificate holder passed the original tests, and is in the business,
and is taking 30 hours of CE, that they have done enough. If the Board is convinced that the current CE requirement is
not effective, I suggest that it spend its efforts on reviewing the content of the pre-approved program providers to make
sure that the content is relevant (as the proposed revisions do suggest).
I do like some of the flexibility suggested by the proposed revisions, but eliminating CE credit for completing all
professional licenses and designation exams smacks of egoism. For instance, does anyone seriously question the
®
value of completing any of the three CFA certification tests when compared to 28 hours of CFP [certification] CE credit
from pre-approved courses in the investments area? Nobody with the CFA designation does.
Thank you for soliciting feedback.
Eric J. McClain,CFP
®
Comments regarding
proposed CFP(R) board's
continuing education
requirement
I believe the proposed changes are a step in the right direction. Let me comment on a couple of items which I disagree
with.
1. 30 to 40 Hours every two years. I think it should be 30 hours per year; 60 every two years.
2. I don't think any hours should be granted for practice management. While it may be beneficial for the owner, I don't
see how it advances the profession or the designation to learn about: business operations, office management,
business model design, budgeting processes, etc. CE should be focused on topics about financial planning or the
delivery of financial planning such as pro-bono.
3. As a member of NAPFA and frequent attendee to study groups, I can tell you the education "hours" awarded there
®
generally pale in comparison to a CFP [certification] CE registered programs. I think you should omit study groups all
together as quality can vary significantly.
Thank you for your efforts.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Eric McMurdie, CFP ,
QPFC
CE commentary
Page 59 of 379
Comment
®
While I appreciate the board’s diligence in reviewing the CE requirements and striving the make the CFP [certification]
designation the premier designation in the industry, I have to take a stance against some of the proposals. Well, one in
particular, and I’m sure it is the one you will find most of your comments towards. Increasing the CE credit hours from
30 to 40 is yet another misguided attempt at overregulation in our industry. I hope to propose where the change really
needs to be.
®
If you are concerned about the education of those individuals using the CFP marks, then monitor more closely the
types of CE that they are doing. You’ve addressed that in some of your other revisions. I don’t necessarily have a
problem with the other provisions. In fact, I really like the idea of increasing the Ethics requirement to 4 hours.
Surely the Board is aware of the other CE requirements incumbent upon us that we maintain regularly: Life/Health CE,
Long Term Care (now including partnership programs), and even product specific requirements (on VA’s in particular).
®
This is not to mention other designations we hold, since believe it or not, the CFP [certification] designation is not the
be all end all for certain specialty areas.
I have not even got into the cost of more CE classes, but the CFP Board has brought that on themselves since they last
raised designation fees quite dramatically. All of this on top of maintaining our practices and serving our clients.
The problem is not the NUMBER of credit hours required. It is the QUALITY of those hours. Again, I believe you have
addressed some of those concerns with some of the other proposed changes.
®
At some point I think the advisor has to say enough is enough. I’ve only been a CFP professional for 3 years, and
already I am feeling like I was sold one bag of goods and forced to buy another. I think the CFP Board does run the risk
of souring advisors in their attempt to make the designation shine. The fact is, despite all of the new ads, logos, extra
®
efforts to promote the designation, I have not had a single client come to me and say: “Oh, you are a CFP
®
professional, I’ve heard about that designation on TV (or wherever). I will only work with a CFP [professional]
designee”
I am a VERY strong believer in continuing education and I think that advisors who utilize their CE credit hours wisely will
benefit from the greater knowledge in their practice. Perhaps the renewed focus needs to be on how advisors
accumulate those hours, versus incentivizing them to find the quickest way to rack up 15 hours of CE credit in a 3 hour
sitting just so they can fulfill the requirements. Unfortunately, I have to count myself with every other advisor out there
who has had to find the “quick” way to comply with the CE requirements. Why? Because of the number of hours
required of the advisor forces their hand when renewal time comes.
If it were up to me, I would limit the number of CE classes to the providers/classes you have deemed to be the most
effective, most quality, and most up to date available. But keep the hours at the same level, please.
If you’re trying to find a breaking point with advisors, you’re getting very close. Advisors, including myself, will probably
®
still comply, despite some attrition. The reason: I have too much invested into the CFP marks to drop the designation,
®
especially so soon after acquiring it. I hold the CFP [certification]designation in high regard and I am proud to have
earned it. But increasing the credit hour requirement doesn’t make me feel “more proud” of the designation or think it is
“more special” than others. It doesn’t even make it more difficult, but rather, just more of a nuisance.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Eric C Sams, CFP
®
Eric Schaefer, CFP
®
Page 60 of 379
Comment
Continuing Education
Requirements
I’ll simplify my comments below.
The requirements being proposed are all seemingly important. My concern, however, is that these additional
requirements are not ABSOLUTELY necessary. The current levels of CE are perfectly adequate (especially when you
combine outside CE such as FINRA, Insurance, Firm, etc). Adding additional requirements for the sake of elevating the
®
designation puts an unnecessary burden on all CFP [certificants].
Response to proposed
changes
Regarding the CE Changes
1) The added cost will be a deterrent for younger or lower revenue producing financial planners
2) The requirement of the CFP board to be the provider of a certain number of hours should absolutely be struck unless
this is included in current dues. This is not in line with the organizational structure of The Board; will add unnecessary
cost and layers to The Board. The cost will almost certainly be passed along to certificants in either higher dues or an
additional fee for the class/sessions. Perhaps increasing the oversight and qualification of CE offering parties would be a
more efficient use of funding/time.
Thanks and Best Regards,
Erik Wolfers, CFP
®
proposed CE changes
Wow, those are a lot of changes.
I can see the desire to tighten things up by a board who feels like they need to get things done but I disagree with some
of what's being proposed. While there's always more research, and certainly more sophisticated investment strategies
designed to entice people into something "new," I don't think the profession really changes much over long periods of
time. The basic math will always be there. The basic concepts will always be there. The stock and bond markets work
the way they do.
In my 11 years of experience I've found that the fundamentals hold true and lots of fads and fashions come and go much
to the detriment of those who jump on the bandwagon.
I am against raising the number of CE's required to renew.
To call them hours is incorrect. They are really continuing education units. Sometimes it takes much longer than an hour
to get one credit. Adding more to the pile will not make me better at my job.
To me ethics are very simple because I choose work in an environment where there's extremely limited opportunity to do
anything other than what is good for my clients. To ask me to spend more hours on ethics would be a waste of my time.
Anything that takes me away more from my clients without making me better at my job is not good. To me many of these
changes look like larger bureaucracy and time away from clients.
I can see getting UNITS for practice management or pro-bono.
Expanding professional activities that qualify. Yes.
50% cap rule. Yes.
• Eliminating CE credit for completing professional licenses and designation examinations.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 61 of 379
Subject
Comment
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
Rationale: Recognize the quality control measures that regionally accredited institutions are required to incorporate in
the development and delivery of self-study courses offered for academic credit.
• Encouraging increased rigor and quality of all CE program delivery methods.
®
Rationale: Help ensure that CE programs available to CFP professionals contribute to their professional competency.
Yes to all of these.
®
To be completely honest, I only became a CFP [professional] to be able to better serve my clients. The overwhelming
®
majority of my clients do not understand what a CFP [professional] is and they do not care. They only care that I take
®
good care of them and their money. I have never gotten a client because I am a CFP [professional]. I hope this
changes someday.
If the process of maintaining my status becomes cumbersome or more wasteful than it already is I will give serious
consideration to not renewing.
There are some good ideas in there which I support, the whole system could certainly be made better, and continuing
education is good and necessary but I don't think more of it will improve the profession. Tighter controls and more
sophisticated materials I think could be goo.
I personally think the test should be made harder. I found the material in the test to be not too tough and when I meet
®
CFP [professionals] who thought it was very challenging, but passed, I'm wondering how well they can do their job.
Thank you,
Erin M. Carper, CFP
®
comments regarding CE
requirements
Thank you for the opportunity to comment. I’ll keep brief and to the point:
- Encourage you to keep the required total to 30 hours. Everything is always fast changing, that is a façade of a
rationale …. That is what we are doing with our 30 hours CE now. We are no longer students, utilizing all of our time for
course work. We are practitioners taking time away from our clients to do CE.. which is fine, we accept the 30 hours,
but stop demanding more and more of our time. And doing CE on line is onerous on us, just another expense for us.
- 2 hours of Ethics CE is sufficient. A refersher here is fine. Duely noted. If someone is going to act unethically, 2 more
hours is not going to change that. Don’t punish those of us who have continued to conduct ourselves ethically and
professionally.
I have taken the time to honor your request of a response/input. I would appreciate reciprication that you received and
noted my comments.
Thank you kindly.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 62 of 379
Comment
Michael A. Farrell,
®
®
CFP , CRPC
Feedback on Proposed
Revisions
Limiting or eliminating self study would restrict time for everyday business. Wire houses such as Merrill Lynch currently
®
demand many hours of ethics training due to compliance demands. I see no reason for CFP [certification] to add to this
®
workload. Soon we will be spending more time on training to comply with in house demands and CFP [certification]
qualification than on the business of caring for our clients. Using outside “academic” sources for grading will only add
more fees to the CE qualification process.
Fernando Alvarez,
®
CFP , CLU™
Re: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Working and studying to make possible success takes more than the time that I wish to devote to this aspect and role of
®
life. Of course updating knowledge and capabilities is important to keep the profession in good standing and the CFP
[certification] should not be an exception. But increasing the already demanding activities every two years is too much,
in my view.
Also, as experience increases with tome devoted to the field and seniority is stablished, the CE credit requirements
should decrease and eventually vanish with time of service and age as a recognition of the wisdom and knowledge
acquired.
Thank you for lessening to the voices of the professionals. Hope this notes are of some practical use and consideration.
Continuing Education
I think CE on balance is a good thing but I think we need to take a look at it as professionals from a 10,000 foot level
®
rather than through a microscope. What do a I mean by that? It is all well and good that the CFP [certification]
community demand of itself that it keep current on trends and the evolution of knowledge in the industry but we cannot
®
just look at the CFP [certification] designation on its’ own in that context. Three of the five accreditations I have demand
CE. On top of that my Firm demands many hours of mandated training, including Ethics. On top of that I am required to
attend CE courses to maintain my Series 7. Finally, many of the states with whom I am licensed to do insurance
demand that I do CE to satisfy their state requirements.
®
Gus Fingado, CAP ,
®
®
CFP , CRPC , CFM,
CSNA
®
From a microscopic perspective, increasing the CE for the CFP [certification] is not a big deal, but from a 10,000 foot
level, I am spending A LOT of time on CE. It would make sense to take a look at providing some sort of base-line credit
®
across accreditations. Moreover, for those of us that are CFP [professionals] that work in “wire houses” (I REALLY
detest that term) who have a rigorous compliance training program ought to get some credit for that.
Richard Fitzsimmons,
®
CFP , CSNA
Enough
®
Between real estate ,insurance, ria, mortgage ,broker licenses and CFP [certification] ,and all the other mandates from
regulatory agencies etc everyone is overdoing it with an overlapping of continuing eduation. Someone has to say it.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
®
Rich Zito, CFP , CMFC
Page 63 of 379
Subject
Comment
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I do not think that changes to the CE requirements need to be made. As it is the additional burdens placed on financial
advisors (by government, the SEC, FINRA, our clearing firm, our B/D, etc.) in the last several years have significantly
limited the amount of time we have available for clients. Adding additional CE burdens is not the answer. Perhaps the
CFP Board could spend its time convincing the various entities mentioned above that there are good people in the
industry and that its one-size-fits-all approach to trying to protect the public is just wasting my time and hurting my ability
to work with the public to try to help them achieve their life goals.
I am sure that these new regulations and requirements are aimed at preventing bad folks from hurting the public but I
can’t see how it will achieve that goal (making me enter duplicate suitability information into a database or make an
official “explicit hold” recommendation on a stock will not prevent the next Madoff). What I can see directly is how it
hurts the good folks in the industry by wasting their time.
In the end, if you must increase the CE burden then at least allow me to use the time I spend doing firm element CE, or
®
fulfilling some other ridiculous requirement to qualify for CFP [certification] CE.
Thank you for listening.
®
Freeman Jelks, CFP
Proposed changes to CE
requirements
®
CFP Board - I have been a CFP [professional] for almost 10 years now, and am a sole-practitioner RIA.
I am not in favor of any of the proposed changes, in fact, when I first received the email, I assumed it might be to
announce a lowering of the current 30 hours/2 years requirement.
In essence, I feel that the CFP Board is over-reaching here. I think that if a client of mine feels that my financial planning
knowledge is lacking or behind the times, then they will likely fire me and move to another planner they feel is more
proficient - regardless of whether the CFP Board requires 30, 40 or zero hours of CE credit.
®
Further, if you make the renewal requirements too onerous, you will start to see some CFP [certification] holders decide
®
that they can probably do well enough without the CFP [certification] brand. Because, honestly - despite all the
®
®
attempts at marketing and branding the CFP [certification] name - less than half of my clients know what 'CFP
[certification]' stands for, much less what is required to maintain the designation. In fact, most clients couldn't care less
®
whether I hold the CFP [certification] designation or what the CE requirements are - they just want good, honest advice
from someone who holds their best interests first.
As for the idea of doubling the ethics CE requirement, you guys are fooling yourselves (and wasting our time) if you think
that spending 2 more hours answering silly, common-sense questions, is going to prevent a few unscrupulous planners
from taking advantage of some hapless investors.
I trust you will make the decision to leave alone (or even reduce) the CE requirements once you realize that the extra
work is counter-productive to us serving our clients.
Fred I. Johnson, CFP
®
CE Credits
The proposed rules on CE Credits sounds like a bonanza for companies providing CE courses and increased
®
discouragement for CFP [certification] candidates.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 64 of 379
Subject
®
Marcy Furney, CFP ,
ChFC, CFS
Gail Buckner, CFP
®
Comment
®
Re: Proposed changes in
CE requirements
CFP [certification] – 30 hours every two years
Firm Element for broker dealer – every year - 3 approved courses related to investments, know your client, and ethics
plus an anti-money laundering course.
Yes there is some overlap but not much.
On top of everything else, the reporting periods are different and require an excel spreadsheet just to make sure I have
the right hours for the right things at the right time. I do not feel that I am alone is this situation. I think your records will
®
prove that the majority of people holding the CFP [certification] designation and are currently in some type of “pursuit of
income” are NOT fee only planners doing comprehensive plans. I would think that most are in self employed practices
doing both planning and investment business. When you say that the 40 hours reflect industry standards of other
professionals, are you really looking at other professionals that have a multitude of different CE requirements? The only
ones I can quickly call to mind are CPA’s, Attorneys, Doctors/Medical, and Beauticians. Most of those do not require
multiple licenses with their own specific CE attached and most do not have multiple designations.
Greater consideration needs to be put into this proposal to increase hours. To run a practice in the financial services
industry already carries considerable financial burden as well as time away from money-making activities which are
required to keep the business running. Now you wish to increase that burden with both the time and cost of additional
®
hours. The CFP [certification] is already the most expensive designation to obtain and maintain and it appears that the
Board is doing everything within its power to make that an even truer statement. If you feel that there is a lack of
®
competency within the ranks of those who hold CFP [certification] designations, I feel that more time and money should
be spent in identifying and educating those people. This proposal reflects the same attitude I saw in grade school. If
someone acts up, keep everyone after school. Give us a break out here.
Proposed Changes to
Certification
You’ve GOT to be kidding! Do you have ANY idea how much time CFOs already have to take from our practices in
order to complete the existing 30 +2 hours requirement? Due to travel time, It can easily take half a day to get to a
meeting to earn a couple of hours. How many more days of potential production are we supposed to give up to keep
these letters after our names?
®
If you want to improve the ongoing education of CFP [professionals], I suggest you start by upgrading the CE courses
you sanction. Some are a complete waste of time.
Gail Pemble, CFP
®
Gali Sherman, MBA,
®
CFP
®
Comments on new CFP
programs/restrictions
I am totally against all of the changes and will give up my CFP [certification] designation in 1/13 when I would have to
give you another $300+ just to keep the designation. You should be ashamed of yourselves.
Comments regarding the
proposed CE changes
In general, I'm against increasing the number of CE hours required each 2 year period. We are bombarded by more
regulation, more oversight, and plenty of CE for other licenses (Series 7 Firm Element, and State Insurance). I'm also
against increasing the Ethics CE from 2hrs. to 4 hrs.
I'm in favor of the practice management and pro bono work.
I hope this helps.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Charles A. Galli, CFP
®
Page 65 of 379
Subject
Comment
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I do not support the proposed changes to the CFP [certification] CE Requirements. I have spent a lot of time obtaining
®
my CFP [certification] designation in addition to my Series 7, 66, 9 & 10 licenses. I also am licensed for health & life
insurance which I fulfill CE requirements for. And in addition to that I have Firm CE I need to accomplish at my brokerdealer employer. There is a lot of training / experience I partake in that goes above and beyond what I would get from
®
spending a few additional hours on a PC obtaining more CFP [certification] CE. Any additional CE is not going to teach
me something I don’t know nor is it going to change the way I handle my business with my clients. I see no value added
®
to changing the CFP [certification] CE Requirements to include.
®
Thanks,
Eleanor Galt-Lin, CFP
®
Updated CE Requirements
Comments
I have two comments below.
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours. – Many of us hold multiple
designations and an increase in CE requirements would be difficult, if you are going to increase the requirements, help
us by making more things overlap. For example, if you’re insurance licensed, please accept more of our Insurance CE
or, if you’re a CPA, please accept the CPE credits.
Alternatively, only increase the CE requirements in years where there are a lot of changes in a specific area. For
example, taxation may have a lot of changes but then next year there may be none.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content. – An increase in the number of
hours of coursework won’t make us more “ethical”. Either someone is going to behave badly or, they aren’t. My guess
is that the people who aren’t ethical, are going to ignore whatever program they are attending and those of us that are
ethical, are going to pay attention and not act any differently in any case.
Jaime Galvan, CFP
®
Antonette "Toni"
®
Gambini, CFP , MBA
Bad Timing
With all the new regulations going on today and the new rules that will come out in the near future, the last thing I want
to worry about is an 33% increase in my CE. I am also trying to run a financial planning practice.
CE revisions
I am not in favor of:
Increasing from 30 to 40hr CE requirement, nor the 50% cap.
The board has almost doubled the fee and now is considering more CE requirements to renew. Enough already. These
recommended changes do not enhance nor improve the quality of each certificate holder. It merely increases revenue to
the institutions providing the CE credits. Reduce the renewal fee and keep the current CE requirements as they stand.
Flexibility, not caps, need to be maintained.
Thank you for considering these comments.
Respectfully submitted,
Garrick Updegraph,
®
CFP
CE Comments
I believe the current CE requirements are appropriate and should not be changed.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Garry A. Greene, CFP
Subject
®
Proposed CE changes
Page 66 of 379
Comment
Really? Increasing bi-annual CE to 40 hours, with an added 2 hour Ethics requirement? Really?!
A. I am totally against these proposed changes, as the suggested rationale are contrived to support the
recommendations.
30 hours of required class hours would certainly be sufficient as long as the quality of course content would improve. By
suggesting a 25% in mandated course time may simply be admitting that current content is woefully inadequate. Don't
raise the number of hours, IMPROVE the content.
Additionally, there seems to be no stated concern for the cost of the added CE requirement. 40 hours represents an
entire week of lost production, lost client servicing and added time & travel expense with no tangible benefit other than
classroom time. STOP permitting weak online CE credit opportunities or 'free' hours proffered by product sponsors that
are simply a mask for product sales.
B. I completely reject the suggestion that practice management and/or pro-bono activities should qualify as CE
alternatives. There is no way to standardize this type of content, and might allow a small percentage of certificants to
avoid more diligent content in favor of simplified pro-bono work. The purpose of mandated CE is to deliver approved
content to the certificant, and practice management and/or pro-bono ignores any specified content mandates.
C. Increasing the ETHICS CE requirement to 4 hours would only be acceptable as an alternative to other course content
within the 30 requirement. Mandating a doubling of the Ethics content will not make certificants twice as ethical.
D. 50% Cap Rule - whatever... it is this level of micromanagement that typifies the lack of interesting available content to
begin with. IMPROVE the content is the only mission I hope you will be able to accomplish.
E. Eliminating CE credit for professional licensing - Why would this be suggested? Actually, this is amusing since
professional licensing content is probably the best source for actual useful content, and would certainly be better content
than any suggested pro-bono work or practice management activities.
®
I received my CFP certification in 1993, and have always diligently fulfilled my bi-annual education mandates. I am
celebrating 30 years as a financial services professional in 2012. However, the implementation of these added
requirements may cause many of those who entered the profession in the 1980s & 1990s to reevaluate the future
benefit of maintaining their credentials as they move towards the end of their careers. I know I will.
Gary A. Loftsgard,
®
CFP
Comments on Proposed
C/E Requirements
I am not in favor of the proposed changes to C/E requirements.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Gary Salach, CFP
Subject
®
comments on proposed
CFP Continuing Education
requirements
Page 67 of 379
Comment
I think that the current requirements are just fine.
It seems to me that the additional requirements represent a "Cash Grab" by some organization. Instead of having a
®
practice I should have the concession to provide continuing education, for a cost, for all the CFP [certification]
Continuing Education requirements.
It seems that my increase in dues has provided the board an opportunity to increase its administrative staff, to in turn,
®
increase the requirements for the CFP certificant holders.
Having observed how are government bureaucracy works, I am sure that you will disregard this memo and increase the
requirements as you wish, even though it will have no impact (except for adding additional cost to those needing CE
credits).
Gary Segiet, MBA,
®
CFP
Gaylord Rohloff, CFP
®
CE Requirements
I am writing to OPPOSE the proposed new continuing education requirements. My basic argument is that you appear to
®
be operating in a vacuum, looking only at CFP [certification]-specific requirements and assuming they are inadequate.
Many financial planners have multiple education requirements from various sources that must be met (in addition to
®
CFP [certification] requirements) in order to practice. In my case, I’m required to complete the following:
®
• CFP [certification] Requirements – 30 hours of CE every 2 years, to include 2 hours of ethics
• Insurance Requirements – 24 hours of CE every 2 years, to include 3 hours in ethics
• Long-term Care Requirements – an initial 16 hour CE requirement plus an additional 5 hours every 2 years.
• Series 31 Requirements - 1 hour of ethics every 3 years
• Series 7 Requirements – completion of the continuing education regulatory element requirement every 3 years.
• Firm-specific CE requirement – annual compliance meeting CE
• Firm-specific CE requirement – annual anti-money laundering CE
• Firm-specific CE requirement – annual branch office security procedures CE
• Firm-specific CE requirement – miscellaneous required CE required for advisors who utilize ETF’s, Structured
Products, Hedge Funds or who intend to perform a 1031 exchange
As you can see, a lack of CE requirements is not an issue. Adding an additional 10 hours, in my opinion, does not
appear to be warranted. I think those additional 10 hours would be better spent actually meeting with my clients.
Comments on proposed
CE changes
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
This is not unreasonable.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
o Practice management CE programs.
o
This seems silly. Why give me CE credit for managing my own practice? This idea was not suggested by anyone in the
field.
• Pro Bono (volunteer personal delivery of financial planning) services.
Likewise, this idea seems to be off-point if we're concerned with continuing education. I do pro bono work as a gift, not a
negotiation.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 68 of 379
Comment
•
What an incredible waste of time. Honest people understand the Golden Rule and doubling the time we spend reading
about it isn't going to make any difference in a person's character or lack thereof. If you feel you have 4 hours of
discussion on ethics, then your material is too vague.
• Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following:
o Participation in Registered Program Financial Planning Development ("capstone") course grading panels.
o Study Group Activities that meet certain guidelines
o Research.
o
These would be a decision for the Board, since they will be evaluating each separate request for credit.
o Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of
total required CE hours.
This makes sense.
o
o Eliminating CE credit for completing professional licenses and designation examinations.
o
Absolutely. Education and Continuing Education should be separate.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
I thought this was already an option; maybe I don't understand the 'change'. But live study should certainly be an option
for those who can't study by themselves.
Encouraging increased rigor and quality of all CE program delivery methods.
Don't you already do this?
Best wishes for you in your decisions. Please make every change count.
Gelasia Steed, CFP
®
CE Requirement
With all due respect to the CFP Board's efforts to improve the CE requirements, the current CE requirement is already
quite challenging for those of us that maintain several professional licenses and are solo practitioners. Increasing CE
requirements is another cost increase and the CFP Board recently increased our membership dues substantially. I
understand you are expanding what will count for CE - I think allowing pro bono work to count for CE credits is a
wonderful idea - but at the same time you mention you are going to eliminate and be more rigorous in what qualifies for
CE. Also, the suggested cap would definitely add to my cost because I typically receive most of my CE at a conference
which focuses on one or two topics. I think if the Board is concerned about the quality of CE provided, then reviewing
and monitoring providers and courses should be sufficient - the Board could just make the current courses a little more
challenging instead of increasing hours required.
Thanks
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
George N. Luciani,
®
CFP
Proposed changes to CE
requirement
Page 69 of 379
Comment
These changes are absurd. Why does the “government”, the Board, always have to “do something” to earn their keep.
Requiring more CE hours is not going to make me a better planner after 25 years in the business practicing financial
planning every day of those 25 years. Increasing the ethics to 4 hours is also absurd. Ethics should not be required after
®
®
5 years as a CFP professional licensee. Who are you protecting? The unethical CFP practitioners do not take the
courses.
Your increased requirements will encourage me to retire; stop using the mark and stop paying your fees.
George Sisti, CFP
®
Gerald P. Wick,
®
CFP ,CLU,ChFC
®
CE
Any CFP [professional] who is doing a good job for clients is doing plenty of studying and reading to keep up with our
ever-changing field. We don't need you to add the additional burden of telling us what we should read or how much we
should read. Personally, any work I do to acquire CE credits is more of an inconvenience than anything else and does
®
nothing to enhance my capability to act as a CFP professional. Surely there are other battles you could fight.
As noted
I believe 30 hours is sufficient! When I actively teach state programs for a number of years, keeping abreast on
applicable laws etc., should be adequate.
Where you need to address your energies is to the state levels, (regulatory agencies) regarding consumer protection /
practitioner practices. Here is where we should address an increase in CE requirements etc.
I have no problem with the introduction of 4 hours of ethics. I also encourage the Board to recognize & accept state
provider approved (classroom only) ethics courses as well.
Regina Embry, CFP
®
Proposed CE rule change
®
I DO NOT support increasing the number of required CE hours from 30 to 40. As a practicing CFP [professional], I also
have CE requirements for my securities license, insurance license, and b/d firm element that provide a great deal of
®
knowledge and require an extraordinary amount of time to complete. Increasing the CFP [certification] requirement by
33% is TOO MUCH! Increasing the Ethics requirement by 100%, doubling it from 2 to 4 hours is also TOO MUCH.
Between all the added time burdens of recently enacted regulations by FINRA and the SEC, combined with increasing
requirements from the CFP Board, we are taking significant time away from serving our clients’ needs. I spend more
time each week on paperwork and compliance issues than I do on serving my clients and effectively managing their
needs. These increasing requirements have got to stop.
George F. Sanders,
®
CFP
CFP continuing education
changes
The changes that you are proposing have merit, however, increasing the number of hours for ethics seems a bit much
as many of us have to take other ethics courses on a yearly basis in connection with other continuing education
requirements associated with our state and federal licenses.
Increasing the total number of hours is also something that adds to the tedium of continuing education as other courses
®
for our licenses are often required in addition to the CFP [certification] continuing education requirements.
Requiring diversity in the type of courses taken is a good step and helps keep a more rounded education in place
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Glenn S. Daily, CFP ,
ChFC, CLU
Comment on Proposed
Revisions to CFP Board's
Continuing Education
Requirement
Page 70 of 379
Comment
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
GSD: This does not seem onerous. You can easily fulfill this
by reading the major trade publications and taking the exams
each month.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
GSD: It will be interesting to see if the additional two hours
lead to a reduction in disciplinary proceedings. I'm betting
that they don't.
I find it useful to review the code of ethics every
two years. Perhaps the CFP Board should leave
the requirement at two hours and produce a
mandatory program that changes periodically.
How powerful is the lobby for third-party
ethics programming?
Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours.
GSD: This strikes me as unnecessary micro-managing.
How many practitioners are violating this proposed rule
now? If you read trade publications and pass the exams,
won't you inevitably have diversified learning experiences?
Glenn Moore, CFP
®
I hate the idea of all your
suggestions. Count me a
big NO!!
We do need time to actually do the work we are paid for. The current CE program is adequate. More ethics program do
not make people more ethical. If so, show me the study! Taking accredited courses towards a designation program is
better than all the lame CE you take. In my view it should count double because the work is harder and more in depth.
This CE program sounds like it was written by staff people and college professors who don't have to worry about making
®
a living. The initial CFP [certification] examination programs are rigorous enough so why do we need to pile on with
this stuff? Pro bono should be for it's own reward, not for CE. The next suggestion will be giving CE credits for holding
®
offices in CFP [professional] organizations.
®
My view is the current program meets our needs. Is there some study that shows that CFP [professionals] are
incompetent and need additional training? The recommendations have too many bureaucratic finger prints. At the end
of the day, we are entrepreneurs and provide a much needed service. The proposed regs will not improve the quality of
®
CFP [professionals]. It may surprise you but there are additional training programs that our broker dealers, FINRA, etc
require and for all the states we have to take insurance CE's. Please come out of the ivory tower and try living in the
real world!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Gary L. Kirk, CFP
Proposed Revisions
Page 71 of 379
Comment
First, Drop this silly advertising campaign (I mean really…a daily Twitter? Are you kidding? Plus full page newspaper
Ads…Your attention please-No one reads newspapers anymore) and move the headquarters office out of the expensive
D.C area. No fulltime employees except a secretary who works from home….use volunteers. Board members need to
meet? Use GOTOMeeting. No air fares, hotel costs, meal reimbursements. It’s a beautiful thing. Reduce fees to
previous levels.
Then and only then let’s discuss requiring more CE hours which takes time away from our helping clients.
I think you can count me as a NO.
®
A CFP [professional] since 1987,
JOHN R. GRAYEM,
®
CFP
CE changes
The CE changes the Board is proposing are excessive, in my opinion. When I became certified there were no CE
requirements or annual fees. I applauded the original implementation of CE because it lends credibility to the marks and
competence to the service. Over time, however, the requirements have become more exclusive to for-profit courses
offered by the The Board or its affiliates. I have other license obligations and CE requirements that are more vital to my
practice.
I have completed enough credits in this cycle to exceed the proposed requirements. Still, your changes would require
me to spend more time and money taking additional ethics courses, or whatever, for no other reason than to meet your
new guidelines.
I am due for renewal right now. I have completed the CE and the application. I have until the end of August to pay the
fee. I am opposed to the changes and this brings into focus the fact my designation adds little or no income to my
practice. No one seeks me out. No one cares. You were supposed to change that.
Again, I oppose the changes.
Katrina M Greening,
®
CFP
proposed changes to CE
requirements
®
My employer provides many hours of training for which I receive no CFP [certification] CE credit. I read a lot of industry
material. I have difficulty finding additional time (let alone paying) for CE programs to meet the continuing education
®
requirements for CFP [certification], Insurance, and FINRA.
I do not support increasing the CE required hours or limiting allowed activities such as professional licenses.
Thanks for your consideration of my opinion.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Marc R. Greenlee,
®
CFP
Subject
Comments
Page 72 of 379
Comment
®
Increased CE hours. I’m a brand new CFP [professional] and I make a point of keeping abreast of the market on my
own. I am strongly against additional hours. The average investor has no idea of the depth of knowledge it takes to
®
become a CFP [professional] today. Most of what I learn isn’t CE material, so that time is wasted by your standards,
but certainly not by mine. 3 0 hours is adequate if the quality of the material is good.
CE credit for pro bono: Absolutely against this. By definition, a pro bono financial issue shouldn’t be challenging for a
CFP. No CE credit should be granted. If they want to do the pro bono, fine, we all should. But, it’s generally not of a
high enough difficulty level to suffice as CE. If the board allows it, there should be a very low cap on the hours that can
be earned in this manner.
Ethics: Make it 20 hours and there are still going to be major issues on Wall Street that damage all financial
professionals. Go ahead and increase to 4 hours, just don’t increase the overall level for it.
Expanding: No comment.
50% cap: makes sense.
Eliminating: Why can we kill two birds with one stone? Good content is good content. Leave it alone.
Review online courses: The description I got is too concise for me to understand the point. Please expand the
explanation.
Encourage Increased Vigor: Qualify should be reviewed and should of course be adequate. Leave the “vigor” part out.
Sounds to me like Ivory Tower monsters run amuck.
®
Overall comment: 47% of the people that took the exam I took to become a CFP [professional] failed. Isn’t that tough
enough? Relax you guys.
Roger Greenwood,
®
CFP
CE requirements
®
Having had my CFP [certification] since 1999 and also having AHIP training requirements, anti-laundering requirements
from companies I represent and RIA requirements as well as in my case NYS Realtor requirements (e.g. fair housing
®
ce)- we already have ample if not excessive CE requirements thru CFP [certification], CMS and NYS as well as fees in
®
all of these areas- when will it end!!! These proposed CE changes for CFP [professionals] are over the top- we already
have excessive regulation and our clients are adequately protected with all the laws and rules we have if they were
enforced properly!
Sincerely, Roger Greenwood- a 68 year old grandfather who is already overwhelmed with requirements and without a
defined benefit pension- unlike all our school teacher and public employee friends who we are still supporting with our
taxes! Another 4 years of Obama and there won’t be any jobs in the private sector – Ayn Rand had it right!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Greg Auman, CFP
Subject
®
proposed changes
feedback
Page 73 of 379
Comment
1. Changing total hours required each renewal period. While planning knowledge and practices are fast changing, I see
no reason to increase the total hours required every two years. In my state of Missouri, I would actually have to earn
more CE credits than the attorneys practicing in my state. If you are concerned with the fast changing nature of our
industry, change the renewal period to every year instead of every two years while maintaining the 30 credit hour
requirement.
2. Not allowing someone to earn a designation or license while earning CE credit hours seems petty and the rationale
given for this proposal is flimsy at best. As long as knowledge is increased and competency improved, why does it
matter if they earn a designation or license at the same time? They are only being efficient with their time.
3. Requiring more ethics hours needs to be studied more thoroughly before being implemented. Has the 2 hour
requirement resulted in a reduction of complaints for the board to review? If the change has not been substantial, what
makes you think 4 hours will make the difference?
Thanks
Gregory E. Johnson,
®
CFP
Proposed CE changes
I think the recommendations all look good except 40 hours, with all that conducting business and associated compliance
requirements that amount of CE is too high. Thirty should stand, perhaps 33 or 34 but no more.
Greg Tamason, CFP ,
CLU
New CE requirements
I am not in favor of increasing either the number of hours for ethics, nor the total number of hours of CE. We may be in
a "fast changing environment" but nothing is new in ethics. Also, most of us have specialized to a greater extent and
much of the CE I take now is not that relevant to what I am doing. Frankly 20-24 hours every two years would be more
that adequate to stay on top of the items relevant to my practice and my clients. Thanks.
Guy G. Cococcetta,
®
CFP
New CE requirements
Please leave the CE requirements unchanged. You are making them too complicated.
Categories are not needed.
®
The ethics category is fine at 2.0 credits.
®
Ethics are taught in childhood and if CFP [professional] designees don't have them by now, an
increase to 4.0 credits is not going to make a difference.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Harold J. Rogers, CFP
®
Hal Rogers - Comment on
proposed change to 40 hr
requirement...
Page 74 of 379
Comment
I have been a Certified Financial Planner™ Practitioner since July 17, 1989. I have been meeting continuing education
requirements since that date.
The reality is that most of what is valuable for my clients, things like distribution strategies for IRA’s taught by nationally
recognized CPA and author, Ed Slott, I can’t even get CE credit for because of the nightmare of disclosure requirements
and the failure of the industry to standardize reporting requirements. However, for $69 I can get an approved course
that will provide 30 hours of credit, I can complete it in two hours, and I learn nothing that is valuable for my clients.
To compound this absurdity w/ additional hourly requirements which will cost advisors more money, add nothing of value
to the services we provide our clients, and allow me to say, “I have 40 hours of continuing education credit towards my
professional designation and licensing” simply makes no sense to me.
I applaud the CFP Board and what it represents. I applaud its intentions. I recognize that like a college education which
provides nothing more than basic training, leaving employers to train new employees in the skills they need to perform,
®
the CFP [certification] designation separates those serious about their career and those who aren’t. If I were bringing
my son into the industry today, I would insist that he become certified.
However, I think it would do so much more for the industry, for financial advisors, and for the members of the public that
we serve if the board would redirect its efforts towards getting disclosure and reporting requirements standardized
nationally.
I hope my comments will be received in the spirit in which they are proffered with an intent to respectfully request that
the board provide functional value vs. simply delivering a new flag to wave at ever increasing costs.
Mark Hammaren, CFP
Robert E. Hammond,
®
CFP , CLU, ChFC
®
®
Proposed Continuing
Education Changes
I will drop my CFP certification if you implement the changes you are proposing, especially increasing the hours from
30-40 and limiting the topic to 50%. You had course providers on the committee, of course they are going to say
increase it so they can earn extra income. You have already increased the renewal fee to more than any of my other
financial services licenses and this would be adding insult to injury. I think it is a horrible idea to make the proposed
changes and I will drop my use of the marks. The CFP Board has really lost touch and lost my support.
Proposed CE
I proposed that the current guidelines be left alone.
I have been licensed since 1998 and it appears that the new generation of Practitioners have nothing better to do with
their professional lives that to contemplate new rules and practice guidelines. Some of us actually have to work for a
living. I spend a considerable amount of time not only complying with the Board’s requirements, but I have to meet a
tremendous Firm requirement, along with CA Dept. of Insurance, FINRA and SEC requirements for CE.
I am opposed to the 50% rule. Should a Practitioner want to specialize in a particular practice area, a concentration of
CE in that practice area would only improve the Practitioner expertise in that practice area.
Why would the Board even consider eliminating allowing other professional licensing CE to not count towards the CFP
®
®
[certification] CE. If the CE qualifies for CFP [certification] CE it should count towards CFP [certification] CE. It is
impractical and unreasonable to require a Practitioner to duplicate the CE course work.
I agree that certain online course should be reviewed for “Increased Rigor”. Does this requirement mean that the
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 75 of 379
Comment
courses should be academically challenging for the elite “Academic Practitioners”? I am under impression that the
Board has approved these online courses as meeting the Boards requirement of “Rigor”. I suppose that that those whom
are in favor of this requirement are proponents that a Practitioner should study 24/7, not work and retake the Boards
comprehensive exam every two years.
I have become increasingly frustrated with the top heavy bureaucratic approach that continues to come down from this
Board. This approach is akin to the ever increasing growth of our Federal Government. “New Laws, New Regulations,
Higher Costs, No Results” There is no evidence that the new rules passed by this Board and those proposed rules have
protected or will protect the public. The only result is increased costs and the consumption of time that is shouldered by
the Practitioner. The Board did not protect the public during the “Tech Bubble” of the “Real Estate Bubble” or the market
decline of 2002 or any other event that has taken place over the last 15 plus years. It is naïve of this Board to believe
that imposing more cumbersome rules and practice guidelines on its members will force everyone else on “Wall Street”
to step in line with the Boards belief of how business should be conducted. Allow me to be further candid, the problem
®
lies outside the CFP [professional] community and lies within the rest of the financial services community and those
whom that are resistant to the Boards ethics and practice guidelines. If it were up to me, a minimum requirement in order
to state that one is a financial advisor would be to possess a Practitioner License.
An area the Board should consider the enforcement of the word “Financial Planner” is in business networking
organizations such as “BNI” BNI has an accepted practice of allowing persons to join the organization and hold
themselves out to the public as financial planners without the requisite licenses.
I am further disappointed, in that the board takes great pride in suggesting that its rules comply with Federal and State
laws while at the same time the Board walks upon and with contempt on the right of the Practitioner to file for personal
bankruptcy, a right that is Constitutionally protected at Article I, Section 8, of the United States Constitution. The recent
passing of the “Sanction” rules is yet another example of the Boards reach and intent to go beyond the rule of law. I trust
that the Board is aware that the Federal Courts have recently ruled that “FINRA” a private corporation authorized under
the SEA to enforce SEC rules does not have the legal authority to impose monetary sanctions upon its members.
Certainly this ruling would apply to this Board as well. On to privacy, this Board has for some time completely
disregarded the privacy rights of it members. Ever State Bar in the Country affords some rights to its members. In
California, even an Insurance License is considered a “licensing right” akin to personal property and afforded all
defenses available under California law. How can this Board have any credibility with the public or its members if doesn’t
believe in the rule of law for itself.
The Board’s states that it goal is to promote public awareness of financial planning and to protect the public. This goal is
admirable and should be the primary goal of the Board. Proposing CE from “30 to 40 hours” does not promote financial
planning or protect the public. Should this Board continue with its current trajectory of passing rule after rule, after rule,
the Practitioner will be inundated with rules he does not understand and the board with be inundated with disciplinary
hearings and legal proceeding attempting itself to make “heads or tails” of its own rules. The current rules are quite
adequate.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Thomas E. Hannah,
®
CFP
Changes to CE
requirements
Page 76 of 379
Comment
As a certificant who has held the designation for twenty-five years, I submit the following comments on proposed
changes to Continuing Education requirements:
1. Increase in hours: In general, I am neither supportive nor unsupportive of a change in requirements to 40 hours.
Having been subject to CE requirements for insurance and other designations for roughly three decades, I am not
convinced that most CE training is of any particular value to the individual certificant. That is particularly true when the
only alternative is to go back over the same few subject areas already studied many times in the past. There simply isn't
that much new information from year to year, and it is often a waste of time to log hours reviewing materials the
certificant has already understood and practiced for many years. Certificants therefore complete the "hours"
requirement in the most expeditious way possible, spending the least possible time away from productive activities, and
taking the least challenging coursework they can find to satisfy the requirements. The CFP Board of Standards may
profit by having stringent requirements to which it can point as it advertises its high professional standards, but individual
practitioners benefit very little, if at all. So, I don't have a strong opinion about whether the standard is 30 hours or 40
hours, because only about 3 - 5 hours of genuine new information is likely to find its way into the brains of practitioners
in either case.
2. In recent years the Board has created the appearance that it is at least as interested in collecting fees from various
sources as it is in upholding standards. Not only were the fees for individual certificants raised by roughly 80% a couple
years ago, but fees for reporting CE providers have also been raised significantly. Many CE providers and certificants
resent the money-grab, and some have quit reporting to the CFP Board because of those fees. When the CE providers
decline to report, the Board extracts the fees from the Certificants by charging $25 to review and approve a course of
study -- and, unconscienably, it assess certificants that "review" fee even when the Board has already charged other
certificants many times to "review" that same course! By raising the "hours" requirement, the Board is once again
increasing the fee burden on CE providers and certificants, and thereby increasing its own revenues. And once again,
the fee revenues create an apparent conflict of interest, to the point where people could begin to think the Board's
motives are suspect.
3. The other proposed changes -- practice management and pro-bono credit, expansion of what qualifies, 50% cap,
increased rigor -- all seem like reasonable upgrades to the current scheme, and I am generally supportive. The only
comment I would have here is this: Any fool knows the correct answers to a test question about ethics; any crook can
pass an ethics exam with flying colors, and then proceed to be unethical in his/her business dealings. Because taking a
course and sitting for exams on ethics has no influence on ethical behaviors in the real world, I am not certain there is
much merit in increasing the academic requirement. It is my opinion that, at least after the first two or three times an
ethics course is delivered all certificants will know the difference between ethical and unethical behavior, so increasing
the hours requirement will not be effective in curbing unethical behavior. Enforcement is more important than education,
in this instance.
Thank you for the opportunity to comment.
®
Christy Hayes, CRPC ,
®
CFP
proposed CE changes
These changes are extreme and intense. I see nothing wrong with the existing CE policies.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Helen A. Wunderlich,
®
CFP , CPA
Disagree with increasing
CE hours requirement.
Page 77 of 379
Comment
I am writing to disagree with increasing the number of CE hours from 30 to 40. These hours are in line with other
established professions and a lot more than others. CFAs have no hour requirement at all, CPAs have no requirements
at all. Therefore 30 is more than enough. If you have more than one license that requires CE hours, it gets very
®
expensive and time consuming to meet all of the CE requirements for more than one certification. No one CFP
Certificant can possibly review all of the new changes to the financial planning industry every year. Not every change in
®
the industry affects every CFP Certificant and therefore each Certificant should be able to choose what they need to
cover without having to take extra hours just to fill a requirement. If a Certificant feels a topic is important enough to
review having enough CE credits won’t stop them from going ahead with getting the information needed. Besides all
financial planning changes that should be covered may not be in the form of a CE course. Plenty are keeping current on
topics and it is done outside of CE credit courses.
I also do not agree with your 50% cap rule for a lot of the reasons listed above. Areas that need to be covered that are
®
relevant to the CFP Certificant are what need to be done.
I also feel that increasing the ethics CE from 2 to 4 hours doesn’t accomplish anything. If you feel that the CE courses
that are offered are not up to your standards than design your own ethics test and require everyone to take that test.
Thank you for taking the time to review my comments.
Henry L. Vernon, Jr.,
®
CFP
CE changes
I am very much in favor of increasing the 2 year requirement from 30 to 40 credits.
Also generally in favor of the other points/changes in the email I received.
One caveat – Additional professional designations might still be considered. Personally I’m currently committed to
achieving the APMA, and taking the course work seriously (although I guess some might not) is significant work and I
feel should qualify as investment or retirement CE credit.
Dan Hervey, CFP
®
Heydon Traub, CFA,
®
CFP
Proposed Changes
Somebody has to much time on their hands. LEAVE THINGS JUST AS THEY ARE.
Feedback
My thoughts on the continuing ed changes:
I strongly object to the increase in ethics hours. As it is, for the vast majority of situations, professionals should be able
to understand right from wrong and doing what’s in the best interest of clients. Taking classes or other continuing ed in
this area doesn’t really help change behavior. There is limited time we all have and spending more on ethics training is
a waste of time. Also, unlike other areas, I believe the only way to get acceptable ethics training is to pay for classes,
etc. and we are already under rapidly escalating costs for registration(s), regulations, and related matters. This would
just pile on.
In that vein, due to time constraints I would strongly prefer leaving the hours required at 30 hours for similar reasons.
The reality is that I attend and read many more “continuing ed” seminars and articles that are truly continuing ed, but
which for various reasons do not count toward the hours. So I expect that if someone is able to log 30 hours they are
typically getting additional “education” for at least double that.
Thanks for your consideration,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Mike Higgins, CFP
Subject
®
John Q. Hinds, CFP
®
®
Lance Hoffman, CFP ,
®
®
ChFC , CLU
Page 78 of 379
Comment
®
Comments
I believe the CFP [professionals] are the most qualified people in the industry and work hard to be on top - I feel the
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biggest problem is that the CFP [certification] is not recognized in the general public or business professionals.
®
Everyone know what a CPA means, but have never heard of a CFP [professional].
Proposed revisions
Has there been consideration to have different CE requirements for CFP [certification] practitioners vs. non®
practitioners? I understand, and agree with, maintaining high standards for the CFP [certification] designation, but
wonder if the more stringent CE requirements should apply to non-practitioners. Thank you.
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Reference: Proposed Revisions to CFP Board’s Continuing Education Requirement
®
Increasing the CE hours from 30 to 40. Disagree. Rationale: Many of us have other CE requirements for other licenses
and certifications that are do not qualify as CE for CFP Board’s requirements due to the provider not being qualified for
®
CFP [certification] CE requirements or because of the nature of the material. Reality is that most of us are already
doing 20 plus hours of CE for various licenses and certifications. Adding another five means less time to spend with
®
clients and more cost to CFP professionals in terms of cost and time.
Granting CE Credit for practice management programs…. Agree.
Increasing the Ethics CE requirements from 2 hours to 4 hours. Disagree. Rationale: Same reasons as stated above. I
have mandatory 3 hours for State licensing. I go to separate providers accepted by State or CFP Board to meet my
requirements.
Expanding the Professional Activities. Agree.
®
Implementing a 50% cap rule. Disagree. Some CFP professionals focus in certain areas of planning. Let them
become masters in those areas rather than a jack of all trades (areas).
Eliminating CE credit for completing professional Licenses and designations exams. Disagree. There are only 168
hours in a week. CFP Board already determines what is consistent with CE topic and therefore eligible for credit.
®
Again, only 168 hours in a week. Let CFP professionals submit all and award CE credit as it is currently done.
Reviewing online courses for academic credit… Agree.
Encouraging increased rigor and quality of all CE program delivery methods. Agree.
Overall comment. The CE program should allow for ease of obtaining quality CE credit with minimal impact to a
practitioner’s business and without overtaxing resources such as time and money.
Marjorie Hoffman, CFP
®
CE Credits
I think 30 credits are more than enough. The reason is that there are more and more required tests from FINRA and
®
our own firms. With as many tests now required outside of CFP [certification] credits-----there are easily another 15 or
20 credits done within each firm.
We need the time to be with our clients.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Patricia Emerson Howe,
®
®
CIMA , CFP
Subject
Proposed Revisions to CE
REquirements
Page 79 of 379
Comment
1. Increasing CE hours from 30 to 40 per biennium
This becomes increasingly pertinent the more time passes since the Comprehensive Exam. I think this should be
considered only for those who have NOT taken the Comprehensive Exam and for those who are past 10 years of their
passing the Exam.
2. Limit practice management CE to 4 hours / Pro bono 1 CE credit per 4 hours pro bono work
Fine
3. Ethics increase CE requirement from 2 to 4 hours
Fine
4. Professional activities that qualify for CE credit
- Course grading panels – fine with a max # of credits such as 5
- Study Group – same as above
- Research – Requires more definition. ?
5. 50% cap rule
Fine if this gets a lot of support; not a big deal.
6. Eliminating CE credit for professional licenses and designation exams
NO. If the material/license is pertinent, it should be counted. The Board should specify which credentials, i.e. CPA,
JD, CIMA, CLU, etc.
7. Review online courses
I would assume The CFP Board is doing that anyway.
8. Increased rigor – No change in rigor necessary. There are now so many ways to get low rigor CE in the Broker /
Dealer channel from wholesalers. This should be monitored or eliminated. But any class approved by The CFP Board
should be rigor enough.
Comment: The CFP Board should have much more focus on the public awareness of the credential. Certificants put
so much time effort and funds into the education process (at least all of those certified since the Comprehensive Exam)
®
that we “should” get something out of it. For example, the listing of CFP [professionals] by name/ contact info/
specialty is great, but how many responses? I would imagine you could count them on one hand.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 80 of 379
Comment
Harold R. Sullivan,
®
CFP
Proposed CE changes
I would like to voice my opposition to the proposed changes to the CFP Board's CE requirements. A substantial majority
of the CFP certificants are also licensed to market and advise clients on a variety of financial products. Therefore, they
are subject to oversight from a number of governmental entities. CE is required from a number of these entities already,
and many of the courses and curriculums needed by these entities are not acceptable in full by the CFP Board. This
action to increase the CE requirements will only add to the administrative burden on many planners.
I believe this is not the time to increase these requirements. My major concern is not the total hrs. required, but the
sources of those hrs that the Board will accept. It appear that the CFP Board would like to direct the sources of
education that planners can use and therefore build a network of providers that are in partnership with the CFP Board.
®
If the goal is to assure that all CFP [professionals] stay involved with only approved vendors then be direct and say that
is the goal. I am concerned that the CFP Board will then being to exclude vendors like The American College that are
legitimate but many be seen as competitors to the CFP Board. People get education from many sources. Respect those
sources.
If the goal of this current board is to purge the industry of "mixed"planners who draw compensation from both fees and
commissions then say so. However, I doubt that restricting revenue to the Board would be a real good idea at this point
in time. Losing 60% or more of your registrants would kill organization in a few years.
I have great concern that this current board is aligning itself too closely with this Administration' appointments in
Washington and that is not a good thing in my eyes. We do not need the CFP Board to become a quasi- governmental
agency with oversight on the industry. The SEC exists to do that oversight and many planners are already answering to
multiple layers of bureaucracy. This would just add one more time consuming layer of oversight.
Estelle Ilene Davis,
®
CFP , MBA
ce credits
I have no problem with increase, but believe that CFP board should be required to "rate" any CE programs so that there
is no question / conflict on what area of education applies.
any program, or CE test provided by various publications, should have each question indicate what category it would
apply. Otherwise it may be impossible for registrant to know if they have met requirements.
Israel Guitian Jr., CFP
®
the Continuing Education
requirement for CFPR
certification.
I think the proposed rules should not be adopted.
The current requirements are fine.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
J.R. Smith, CFP
CE revision
Page 81 of 379
Comment
I can see the benefit of increasing the Ethics requirement. And I can see adding those 2 additional hours to our existing
30. But I see no advantage to requiring yet an additional 10 hours of CE to complete.
Do you realize how much time it takes a sole practitioner to keep up with already increasing regulations?
I don't know if you understand how much time it takes to accomplish all required to just stay in business today. Our
broker dealers increase our time required, FINRA regulations multiply. And on. A person needs time to actually serve
clients and make a living.
Additionally, I spend hours a week simply learning all I can possibly, to keep up with new practices, chaning products,
economic education, and etc. The success of my firm over 33 years has come as a direct result of our ongoing
research. This is far more valuable learning time than what I can get from some approved CE course.
Please do not increase the hours. They are sufficient when one adds all the additional CE and training we must do
annually already.
"Already floundering in all the time spent in "ongoing continuing education"
Jack McCord, CFP
®
comments
I have received your request for comments with regard to changes you are contemplating in the CE requirement for re®
licensing. I am surprised and pleased by your attempt to include CFP [certification] stakeholders in your decision
making process.
I hope that you will give some weight to my opinions based upon the following facts®
1. I became involved in the financial planning profession in 1973. I became a CFP [professional] license in 1975.
2. I served for seven years on the Board of Directors of the San Diego IAFP beginning in 1975.
3. In the 1980's I served for five years on the Board of Directors of the Institute of Certified Financial Planners. As
Chairman of the Ethics Committee for two of these years I help draft and enforce the Code of Ethics and later worked to
conform this Code with the new Code adopted by the IBCFP.
4. In the 1990's I served for four years on the CFP Board of Standards - previously known as the IBCFP. This was in
the initial development stages of your organization. I chaired the Post Certification Committee for three years and was
the chair of the Practice Standards Committee in its first year of existence.
The Post Certification Committee was responsible for Continuing Education, Re-Certification and Ethics enforcement.
Having provided you with this background information, I will offer you my comments on your proposed changes in the
C/E requirement.
INCREASING C/E HOURS FROM 30-40 HOURS EVERY TWO YEARS
Go ahead and do it.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 82 of 379
Comment
It is basically a thing like “my daddy can beat up your daddy”. It is largely meaningless but if it has become a
professional standard - go ahead and do it.
It will not, however, improve the quality of service provided by licensees to the public. Simply put, the number of hours
spent on CE education has little or no correlation with the quality of service provided to clients.
C/E CREDITS FOR PRACTICE MANAGEMENT AND PRO BONO ACTIVITIES
A maximum of 4 hours credit is a good compromise on these issues. I support it.
ETHICS REQUIREMENT CHANGES
Increasing the requirement from two four hours is a good idea but increasing the quality of the courses is far more
important.
EXPANDING PROFESSIONAL ACTIVITIES
I have no problem with these additions.
50% CAP RULE
This is a great idea and I totally support it.
ELIMINATING CE CREDIT FOR COMPETING LICENSES AND DESIGNATIONS
The key words here are “inconsistent with”. This change is very vague and needs to be defined more clearly. I know
what you are trying to do and I support your efforts in this area.
REVIEWING ON LINE COURSES
You must set standards in this area and I’m pleased to see some concern about this issue.
INCREASED RIGOR AND QUALITY
If you can increase the quality and rigor of the CE programs, you will be doing more to improve the profession than if
you executed all of the other proposed CE changes.
Jacqueline L. Powell,
®
CFP
comments
Although some of the recommendations are sound, the overall requirement of increasing the CE hours from 30-40 hours
is a burden. Those of us actively engaged in practice already have other continuing education requirements thru our
broker dealer and other licensing (insurance generally). We are often times engaged in local estate planning councils,
etc. which do not always provide CE as parting of the programming. It is my opinion that the CFP Board will see a
decline in registrants if the increased hours are imposed.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jake Engle (email #2),
®
CFP
Subject
CFP Board needs to
sponsor 40 webinars per
year, with automatic CE
reporting
Page 83 of 379
Comment
®
In your review, you surely noted that CFP certificants face enough compliance pressures (even prominent ones who
are attorneys).
We face enough costs (and time away from family) for conferences and for CE, particularly the Ethics ones.
The Board should start a weekly webinar series, with automatic CE reporting. Webinars aren't hard, and other similar
entities do them.
The Board just needs to do more, particularly re Ethics.
®
Please show us that you can do a better job for us, as the press is reporting that CFP [certification] business model is
endangered, and is second class to
CFAs.
See:
http://advisors4advisors.com/industry/advisor-business/article/16163-cfp-board-falls-short-even-though-it-proposesboosting-continuing-education-requirement-from-30-to-40-hours-and-would-give-ce-credit-on-practice-managementtopicsThank you for trying to do more, and do it better.
Jake Engle (email #1),
®
CFP
Oppose every proposed
change to CE requirements
Do you want to become a standard obstructive and wasteful bureaucracy that harms business, or a Fortune 500-like
Corporate Board that
®
that enacts the Managerial Imperative instead of looking out for shareholders (CFP Certificants)?
First you double the renewal fee, and for what?
businesses who are certificants?
To expand your empire.
Does the advertising campaign help small
No.
You are like a university that says "You graduated, but we'll steal back your degree unless you jump through a bunch of
new hoops".
Now, to justify your existence, you want to change the CE requirements.
Each of the too many changes are useless.
1) 40 hours are too many, an entire workweek!
keep us all from doing more important things.
When we are all 80, what difference with this have made, except to
2) Ethics requirement increase - simply removes dollars from certificants and puts them in the pockets of CE providers.
These CEs don't make anyone
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 84 of 379
Comment
more ethical. Two hours is more than enough.
3) Implementing 50% cap rule -- More record keeping hassles for those of us trying to help clients. Don't start creating
categories, and making us track them. Useless idea, does nothing for our clients.
4) Eliminate credit for professional licenses and exams -- The Board wants us to take less exams and have fewer
credentials? This isn't well thought out,
and seems unfair to the other professional exams, and to those who are diligent and study hard.
In short, there is NO PROBLEM.
Spend your attorney time getting Congress to keep FINRA from turning us into salesmen, rather than acting like the
bureaucracy at a Wall Street law firm/legal
department.
The reason the standards are the same as in the 1990s is that they have worked.
No changes needed.
In reality, most of us spend many uncredited hours researching things that don't count as CE, but are functionally the
same thing.
Which is why there is no problem.
If you implement all these new requirements, then it is your duty to sponsor completely free webinars for Ethics, and all
subject areas. Ideally every
Thursday afternoon, about 48 weeks out of the year. That's what a professional organization can do to help us. And
use your attendance records to take care of
our CE reporting, which is a huge needless hassle for us.
Respectfully submitted,
James S. Graham,
®
CFP
James Hoffman, CFP
®
Additional credits
I would ask you to consider giving credit for the CE and ethics requirements from FINRA, CPA and any other similar
programs. I think there is a possibility of creating unnecessary overlap of similar credit requirements. This overlap can
create excessive expense and use of time that takes away from our profession.
comments
CFP board is already requiring enough and any more would be too much, thank you, Jim.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
James L. Schmitt, CFP
®
Proposed CE credit
changes.
Page 85 of 379
Comment
I don’t mind the proposed changes. But I would like to see some sort of ‘grandfathering’ for us that have been licensed
®
since the 1980’s or earlier. When I complete the required CFP [certification] or state insurance CE credits I learn
nothing new, and a ‘9’ hour CE course takes me 30 minutes to complete because I know the material so well. In fact, I
just go right to the exam every time. Making the requirement 40 hours instead of 30 only serves to make more money
for the CE providers.
Making the Ethics course 4 hours instead of 2 does very little to instill ‘ethics’ on anyone… you either have it or you
don’t.
Here’s my proposal….
•
20 or more years of uninterrupted licensing: 20 CE hours every renewal, with 2 hours of Ethics
•
Between 10 and 20 years of uninterrupted licensing: 30 CE hours every renewal, with 4 hours of Ethics
•
Less than 10 years of licensing, or any period of interrupted licensing: 40 CE hours every renewal, with 4 hours of
Ethics
James E. Nicholson,
®
CFP
Changes to CE
Requirements
I recommend NO CHANGES to the current requirements. Thank you for soliciting member comments.
JAMES M WHALEY JR,
®
CFP
CE
As a certificant for almost twenty years I emphatically deny the need exists for more onerous CE requirements. I'm
proud of the education I received by the College and use it to the best of my ability to provide my clients honest and
appropriate advice. I reiterate the idea that instead of continually seeming to focus on areas of our profession that
increase our already overwhelming regulatory burden, the Board would perform a great service to reverse course and
concentrate its efforts instead on relieving the self serving requirements forced on us rank and file by FINRA and the
numerous federal agencies we're subject to.
CE proposed changes
As a CFP [professional], I feel the changes would add another level of burden on individuals that are already being
overloaded with so many industry changes. We are required to keep up with so many changes to regulations and
various financial planning topics. I believe to formalize added CE credits just adds to the complexity but not the
®
professional competency of those carrying the CFP [certification] credentials.
Jim Bailey, CFP
®
®
I oppose these changes as unnecessary.
®
James C. Hanna, CFP ,
MBA
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I believe that you are making this too complicated and burdensome.
I agree with the idea of increasing hour requirements, but many of the other details I would not support. Specifically, I
would not support elimination of credit for past courses/training where credit has been allowed. By increasing hour
requirements you are raising the bar, which is fine. If you ALSO eliminate credit for many programs where credit has
been granted in the past, in my opinion this makes it more burdensome than it should be to meet the requirements. I
suggest that you pick one or the other, but not both.
Thank you for the work that you do, I do appreciate it!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
J. Kevin Waninger,
®
CFP , MBA
Page 86 of 379
Comment
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours. ABSOLUTELY NOT! 30
hours every two years is more than adequate. I'm sure you see this as another way to increase your revenues, just like
you have by nearly doubling the renewal fee. You folks are in the process of running yourself out of business. I think
the "Board" needs to do a serious self evaluation and you will see that you ARE NOT working in the best interest of the
public with your recent changes. You are clearly attempting to line your on pockets at the expense of the public and
Certificants.
Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period. ABSOLUTELY NOT! There is nothing valuable learned from these activities that can benefit our
clients. Sure, these efforts are noble, but certainly not a substitute for continuing ed classes.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content. I would be supportive of
®
increasing the ethics requirement to 4 hours. I believe that all Board members, whether CFP [professionals] or not,
should be required to take the training as well.
Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following: NO. You will just be complicating matters.
Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. YES, I think this would be a positive change.
Eliminating CE credit for completing professional licenses and designation examinations. This should NOT BE
ELIMINATED. This is much more instructive and valuable than some of the other items you want to give credit for.
Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities as
“live” CE programs, rather than “self study.” Don't care.
Encouraging increased rigor and quality of all CE program delivery methods. Yes, this would be good.
®
James E. Larsen, CFP ,
®
AAMS
Proposed Revisions to CE
Requirement
Dear CFP Board:
Thank you for your e-mail of Friday, August 17th and your request to elicit commentary from our membership. I believe
the CE Requirements, as they stand now, are more than sufficient in their attempt to keep us up to speed and we do not
need to be burdened with further educational requirements. I find the proposed enhanced requirement similar to the
regulatory overburden placed on businesses across the spectrum by our government. We then wonder why our
economy slogs along in mud. Each of us has a business to run as well in our attempt to help investors, many of them
small business owners, reach their financial goals and objectives.
Thank you for your consideration and for the forum to add my $0.02.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Janet Trigg, CFP
Subject
®
Jared S. Friedman,
®
CFP
Jarree E. Miller, CFP
®
Page 87 of 379
Comment
CE requirements
Increasing the hours from 30 to 40 hr only costs the participant more money. You are not going to make someone
honest who is dishonest by merely making one take more hours of CE.
You're not making them any more educated, because most of what is out there is redundant. Personally the entire CE
requirement of 30 hours is a waste of time. If you were to implement
training hours to be of specific law changes or something that gives the person " new " knowledge, then this would be
worth while.
CE
I feel the current amount of CE credits is acceptable. There are only so many hours in a week to get our work done,-working clients, building financial plans and managing money. Adding additional CE requirements take time away from
our clientelle
Increasing CE
requirements
I am totally against increasing the CE hours from 30 to 40. I think you are making a big mistake. I won't elaborate.
-------------------------------------------------Last night I responded to the CFP Boards email regarding the proposed CE hours increase from 30 to 40. I want to
retract and apologize for my statement that the Board would be making a big mistake. The mistake was mine.
I have always been an strong advocate of continuing education and ethical conduct. I have completed the CLU, ChFC,
®
AEP, CMFC & CFP [certification] designations, and the Master of Science in Financial Services degree. I also have
completed the Graduated Certificates in Estate Planning & Taxation, and Business Succession Planning from The
®
American College. Of the five designations I have held, I consider the CFP mark to be superior, and it sets itself apart
from the other designations due to the stringent continuing education requirements and the ethical standards required by
®
the CFP Board. I support the Board's recommendations.
Again, please accept my apology.
James F. Short, CFA,
®
CFP , CIMA
CE Comment
There are professionals in our business who spend most of their time marketing – rather than doing research. The
marketing focused professionals are probably the most likely sub-set of our industry to fail to stay current on continuing
their professional education.
Many professionals in our business hold more than one designation. I would encourage you to consider working with
IMCA and the CFA Institute to offer reciprocal credit for CE activity. I would also encourage those organizations to work
with the CFP Board.
For example, if I attend a CFA Society Tampa Bay CE meeting, it would be great to receive credit for CE towards my
®
CFP [certification] designation without having to apply to have the CFP Board look at the agenda and then having to
pay another fee for that service.
When financial crediting organizations get insular with their CE requirements, they run the risk of looking as if they
creating a profit center – rather than encouraging their professionals to stay current.
®
Jason W. Dahl, CFP ,
CLTC
CE Comments
Hello. I would consider adding CE requirements and credit for different types of communication skill enhancement. The
foundation of financial planning is the ability of a planner to communicate well with clients, prospective clients, peers,
and the general public. Thank you.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jason T. Wheeler, CFP
Subject
®
Continuing Education
Requirements
Page 88 of 379
Comment
I feel most of these changes are overdue and support all of them to some level. The areas of concern that I would like
to comment on are as follows:
1. I hope that careful consideration is given to the professional designation change regarding the content and that it is
communicated effectively. For example, pursuing a CLU designation through the American College is something that I
believe I should get credit for continuing my education. I believe the underlying coursework is the base for the credits
and not the designation itself. This statement makes me question whether the underlying coursework would still be
eligible since it is in pursuit of a designation. I think I am covered but clarification is needed for the final rule change.
2. I have concern for the expanded professional activities area. First, I think it is totally irresponsible to give someone
continuing education credit for grading. If I continually teach the same material and grade the same material, how am I
expanding/continuing my education? I think this should be removed. Second, adding research CE may be beneficial in
attracting more academics to the financial planning field but that is far from the scope of a financial planning
®
professional. If I am a finance professor at a university with a CFP [certification] curriculum course, then I would be
able to grade and do research, fulfilling my ce credits but never dealing with clients or expanding out of my area of
expertise. I think research should only be applicable to the domains and principal topics area (subject to the 50% rule)
and an exception could be granted for areas outside the current scope subject to a cap.
3. I would encourage a computer based test free from CFP board that would allow CE Credit. I think the use of new
questions from the last two years of testing would be a great base. The test would be 2 hours and allow you to get 10
®
credit hours. This would give the CFP Board a new data source to find out how existing CFP professionals are doing at
maintaining their CE. By providing this free and as on online exam, you would get a lot of last minute participants and
®
that would give you an great base for following up on CE providers. If a CFP Professional got all of her CE credit from
one provider and then performs miserably on the “Staying Current” exam, CFP Board could cross reference with others
using the same CE provider and then you could look into it in more detail.
Thanks,
Juerg "George" Ciceri,
®
CFP
Proposed Changes for CE
As requested, please find my comments on the proposed CE changes:
In my opinion, your proposals are not necessary, a waste of time and I strongly recommend not to make any changes to
the existing CE curriculum. Why change a system that has worked just fine? Increasing the amount of required CE will
®
help a small group of CE service providers but will not make a difference in increasing the quality of CFP
®
[professionals]. 30 hours is plenty of mandated lessons – good CFP [professionals] will educate on their own – without
the “guidance” of the CFP board. To increase ethics hours is a joke – as already today it is difficult to find decent CE
lessons on this topic. You cannot teach ethics, you can only live it!
®
As a single owner CFP [professional], I already have to deal with regulatory, accounting, practice management & other
administrative issues. To add even more complexity to the business is simply wrong.
All this proposals will require a huge increase in administrative cost to supervise CE activities – this should not be a
primary responsibility for the CFP board.
Joseph D. Jackson,
®
CFP
I think the current CE requirements are fine as they currently stand. There is no need to change them, and certainly no
reason to require more hours than already needed. Two hours is more than enough for the ethics portion. We are all
aware of what is and isn't ethical, and frankly the ethics courses are nothing but a joke and a money grab.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Jearl W. Meeks, CFP ,
®
CPA, CRPS
®
Jeffrey M. Garell, CFP ,
CLU
Page 89 of 379
Comment
Proposed CE changes
I approve the proposed CE changes. As long as CE credits continue for reading certain financial planning publications,
including the Journal of Financial Planning, answering a series of questions on the articles in the publication, and getting
CE credits for attaining a certain score on the exam.
Increase CE Hours
Thank you for soliciting comments. I appreciate the opportunity to respond. Of course I want to be part of a profession
and designation that has substance and barriers to entry. However, I’m generally negative on the proposal:
1. You should consider if the governing bodies are living in their own vacuums, ie is there really a driving force so great
that we need to increase obligations in our field? Is this coming from within?
2. More time spent (potentially, depending on conference and other credited time) on non-client, non-business
generating issues. Essentially it’s more compliance and Big Government gobbling our time.
3. Why is the comparison with other professions that valuable? How many people, except those in the CE business,
wander through each day worrying whether our CE hours are comparable with other professions? Just ask….are we
doing OUR job and minding OUR house in that area? The number of hours is irrelevant.
It’s a worthy consideration and topic. However, I vote “NO.”
Jeffrey S Hoadley,
®
CFP
Jeffery Sutton, CFP
®
Jeff Vistica, CFP
®
®
Changes to CE
requirements
Having been a practicing CFP professional since 1993 I have seen many changes in the industry- many are very good.
I do not agree that increasing the number of hours required is necessary. More is not necessarily better...If you
investigate other professions and designations you will find there is quite a bit of continuing education occurring anyway.
I have Insurance continuing education requirements, FINRA requirements and now IRS RTRP requirements. I like to
learn and improve, but I also like to spend time helping clients. I do not think adding another 10 hours to the CE
requirement is a positive change. I however, agree with the other proposals with the exception of doubling the ethics
requirement. There are already very firm guidelines and safety protocol for an ethical practice presently in place.
Revised CE Credit
Based on the information listed in your email, I would be opposed to the new rules. I go to a lot of seminars to keep up
®
on the latest trends in my industry. Very rarely do they qualify for CFP [certification] credit, and if they do, I get 1 or 2
hours for a 6 hour course or seminar. I don’t see how that makes any sense. I should be getting more credit for being
out among my colleagues discussing the current trends and issues with the business. So at the end of the renewal
period, I find myself trying to do the on-line courses to make up the required credits. In the past few years, on-line
companies have been reducing the amount of credit we get for each course so we have to take more to get our required
credit. If this trend continues, then you could be making it impossible for professionals that need to focus on business to
meet your requirements. It looks as though you have now doubled the price of the certification as it appears I will be
paying the $350 or so fee every year instead of every other year. I’m not sure where all of this is going, but I only see it
becoming more frustrating to keep this certification.
CE Changes
Yes, I am a big supporter of increasing/improving our CE requirements. Doing so would help put our profession into a
better public light and puts our profession more in line with the ongoing CE requirements of other trusted advisors such
as CPA's and Attorneys. Ongoing learning is so important in today's world, our clients should expect we follow tighter
requirements.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jeff White, CFP
Subject
®
RE: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Page 90 of 379
Comment
I find these changes abhorrent.
1. Most course work is WAY behind the times and what i need to learn I must learn on my own - and THEN take
additional CE to meet these requirements. To waste additional time on this requirment seems absurd to me.
®
2. Many good CFP [professionals] focus on one area - to limit their CE to no more than 50% seems particularly
unhelpful.
®
Jeffrey Scales, CFP ,
®
AIF
New CE requirements
proposed
Personally, I find that I have more than sufficient hours every two years to meet the 40 hour suggested minimum. In
fact, I often get frustrated by having 50, 60 or more hours. It would be appreciated if you are planning raise the limit that
excess hours be permitted as a carry over to the next cycle. For example, if I renew in July every two years, and from
April thru July get an additional 20 hours over my minimum, it seem so reasonable to let that get applied to future cycles.
As the years go on, I have other designations that also must be served with CE credits, as well as regulatory
requirements. It seems that we spend a great deal of time in training, compliance updates, due diligence meetings, etc.
I also don’t believe that the CE requirements will result in the outcome of more capable advisors – or more ethical
advisors.
By the way, as I age into my 60s, I don’t imagine attending as many conferences and having as much access to CE
credits. I do plan on continuing my practice with an exceptional staff including advisors that I have mentored over the
years. Wondering if there is a point where at age 62 or 65 one could have reduced CE credit requirements?
Thanks for taking in my comments, and I look forward to your feedback.
Jeffrey D. Angel, CFP
®
CFP Revisions to CE
®
30 - 40 hours is not necessary. I don't know of one CFP certificant that does not have to do CE for other licenses....I
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have securities CE and Life CE that does not count towards CFP [certification] - So I am staying on top of things in
other areas. Adding an additional 10 hours will not make me any smarter......
I dont feel increasing ethics from 2 -4 hours makes more people "ethical" keep it as it is.
Donald Simon, CFP
®
proposed CE changes
Is there consideration for reducing number of hours of CE required for being a CFP for over 25 years if age 65 or older
®
?......that would help...I became a CFP [certificant] in 1981 (CFP#004946) and am 65 years old....any consideration you
can give this matter would be most appreciated....
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jenny Lissner, CFP
Subject
®
increasing CE
Page 91 of 379
Comment
®
I work with professional designations and CE for the CFP [certification] within Wells Fargo Advisors. I hear a great deal
of feedback.
I do not agree with
1. Increasing the CE to 40 hours. I don’t think more hours is the answer. I agree that we are many changes, but I think
the 50% cap rule would help.
2. Increasing Ethics requirement. Knowing how to answer ethical questions has no correlation to how ethical someone
is. I bet Bernie Madoff passed all his ethics courses. It adds costs and takes away from valuable time without any true
benefit.
3. Eliminating CE for licenses and designations. I deal with these every day and most of my field people say the new
licenses and designations increase their knowledge and help them reach a more diverse clientele and understand other
aspects of their clients situations more deeply. What about limiting the ones you’ll give credit for?
I do agree with:
1. Implementing the 50% cap rule
2. Granting CE for practice management and pro bono activities
3. Expanding the professional activities that qualify for CE
Jeramy E. Genaway,
®
CFA, CFP
Comment on Proposed
Revisions to CE Program
Good morning,
I have an additional suggestion to the proposed revision to CE program - since increasing the amount required from 30
to 40 takes away time we could be spending with clients, I believe accepting credits for other professional certifications
®
towards the "CFP [certification]" required amount will cross-pollinate professional designations and improve efficiencies
of CE gathering. If I attend a 1 1/2 hour luncheon on an investment topic (which the CFA institute recognizes as CE) ®
why not also be awarded CE for the CFP [certification] program's "investment requirement"? From my perspective, I
think that would be a significant upgrade to the current approach between all designations and encourage more
professionals to obtain additional certifications.
Jerrod Summers, CFP
®
response to ce
The proposed changes under consideration are:
•
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations. The proposed increase in required hours is consistent with
recommendations from CFP Board’s 2007 and 2008 Education Task Forces.
COMMENT: OBJECT – SIMPLY ADDING HOURS WON’T LIKE ACCOMPLISH YOUR MISSION. SUGGESTION IS
TO MAINTAIN A RECONCILIATION OF PRIOR PERIOD’S CE COURSES TO ASSURE DUPLICATIONS OF SIMILAR
TOPICS DO NOT OCCUR – ADDING DIVERSITY. ALSO, DEPENDING ON CFP OR BUSINESS TENURE, REQUIRE
CE CLASSES MORE ADVANCED IN NATURE. IN MY EXPERIENCE, MANY DO NOT APPROACH CE AS
“OPPORTUNITY TO LEARN” BY CHOOSING MORE RIGOROUS CLASSES OR THOSE WHOSE TOPIC THEY HAVE
LIMITED EXPOSURE TO. RATHER, THEY’LL TEND TO CHOOSE CLASSES THEY CAN “TEST OUT OF” OR
EASILY PASS WITHOUT ACTUALLY COMMITTING A THOROUGH REVIEW OF THE MATERIAL.
•
Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total
combined) per renewal period.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 92 of 379
Comment
o
Practice management CE programs. Defined as programs focused on the planning, development and
®
management of a CFP professional’s business operations, office management, business model design, budgeting
processes and leadership.
o
Pro Bono (volunteer personal delivery of financial planning) services. These activities must be supervised by a
registered CE Sponsor organization and will be accepted for 1 hour CE credit per 4 hours pro bono service.
Rationale: Recognize the importance practice management plays in the delivery of competent and ethical professional
financial planning services to clients. Encourage pro bono service for the public benefit.
COMMENT: AGREE – GOOD IDEA
•
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Boardproduced Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved
programs on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.
COMMENT: DOES REQUIRING AN ADDITIONAL 2 HOURS IN 2 YEARS REALLY IMPACT CHANGE IN THE
UNETHICAL NATURE OF INDIVIDUALS? I THINK NOT. RATHER, CONSIDER STEPPING UP CONSEQUENCES
FOR THOSE WHO CHOOSE NOT TO EMPLOY ETHICIAL REQUIREMENTS. AN ADDITIONAL 2 HOURS MAY
REFLECT THE BOARD’S EFFORT TO TAKE STEPS TO IMPROVE ETHICAL BEHAVIOR, BUT WILL IT PROVIDE
ACTUAL RESULTS? IF A CFP KNOWS THAT THE BOARD WILL ENFORCE STANDARDS SWIFTLY AND WITH
RIGOR, GREATER RESULTS OR WARRANTED DEPARTURES ARE SURE TO OCCUR.
•
Expanding the professional activities that qualify for CE credit (currently accepted professional activities are
teaching and authorship) with the following:
o
Participation in Registered Program Financial Planning Development ("capstone") course grading panels.
These activities must be verified with documentation of active participation, written assessments and qualitative
feedback;
o
Study Group Activities that meet certain guidelines;
o
Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job
Task Domains and Principal Topics.
Rationale: Encourage body of knowledge expansion and no cost CE opportunities.
COMMENTS: EXCELLENT IDEA. THOSE ENGAGED IN SUCH ACTIVITIES ARE IN FACT THE “TIP OF THE
SPEAR” FOR KNOWLEDGE AND EXPERTISE IN THE FIELD. I AM A DIRECTOR AT USAA, LEADING OUR MOST
EXPERT GROUP OF CFPS, OUR “LEAD PLANNER” TEAM. THEIR EXPERTISE AND BREADTH OF KNOWLEDGE
CAN BE STOOD UP AGAINST ANYONE IN THE NATION. IN SETTING EXPECTATIONS FOR THEIR ROLE, THE
TEAM IS REGULARLY DEPENDED UPON TO INCREASE ADVISOR EFFECTIVENESS FOR THE ENTERPRISE
THROUGH THEIR TRAINING EFFORTS. KNOWING THE STANDARDS FOR PROFESSIONAL ACTIVITIES OF
TEACHING AND AUTHORSHIP, APPLYING THOSE STANDARDS FORTHCOMING IN FUTURE TRAININGS, WILL
ACCOMPLISH TWO GREAT THINGS: (1) ALLOW WARRANTED CE CREDIT AND (2) LIKELY INCREASE THE
DEGREE OF IMPACT AND QUALITY OF THE TRAINING EFFORTS.
•
Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to
50% of total required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are:
General Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 93 of 379
Comment
Communication, Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual
educational sessions, will not be subject to the "50% cap rule."
Rationale: Ensure diversity of learning experiences across breadth of planning topics.
COMMENTS: AGREED, AS NOTED IN FIRST COMMENT. WITH EXCEPTION TO ONE ITEM, I DON’T BELIEVE
THAT 40 HOURS IS NECESSARY. BY HAVING THIS EXPECTATION, OR, ADJUSTING TO NO MORE THAN 35%
TO ASSURE DIVERSITY DESIRED, WOULD BE BETTER. EMPHASIS ONCE MORE, THAT ENTRY-LEVEL
COURSE STUDY FOR CERTAIN “TENURED” CFPS ARE ALSO NOT QUALIFIED FOR CREDIT.
•
Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
COMMENTS: PARTIALLY DISAGREE. THE COURSE STUDY REQUIREMENTS OF OTHER DESIGNATIONS
SHOULD MOSTLY QUALIFY. IN FACT, AS LONG AS DESIGNATION AND CONTENT APPLY (AT A DEGREE OF
DIFFICULTY THAT WOULD SATISFY MY “TENURE” CONCEPT) TO DELIVERING PLANNING ADVICE TO CLIENTS,
THEN WE SHOULD ENCOURAGE OTHERS TO PURSUE THESE. “SCRUBBING” VARIOUS PROGRAMS FOR
COMPONENTS OF COURSE STUDY THAT MEET STANDARDS WOULD LIKE RESULT IN “PARTIAL CREDIT,” AND
ONLY COUNTED WHEN COMPLETION “TRIGGERS”, SUCH AS PASSING THE TEST, OCCUR.
•
Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or
universities as “live” CE programs, rather than “self study.”
Rationale: Recognize the quality control measures that regionally accredited institutions are required to incorporate in
the development and delivery of self-study courses offered for academic credit.
COMMENT: AGREED
•
Encouraging increased rigor and quality of all CE program delivery methods.
®
Rationale: Help ensure that CE programs available to CFP professionals contribute to their professional competency.
COMMENT: AGREED
Jerry Klosterboer, CFP
®
CE
CFP Board
®
This will add to the cost of CFP [certification]. I say NO.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Gerald H. Ballan, CFP
®
comments about possible
changes
Page 94 of 379
Comment
As one person that holds these letters and 3 additional letters, I believe the added proposed hours and others changes
add to the difficulty of our members to conduct their business of providing the best service and advise to their clients. I
assume most of us have insurance and other continuing education, new compliance regulations placed upon us, thus
additional testing, when I spend significant time studying and not getting a grade or tested a burden not needed.
It is similar to getting a new car inspected. We have rules for members that have violated the standards. If we work for
a firm then we have compliance guiding us and if we are independent we would hire someone to cover compliance.
We do not need to behave like Washington and push more regulation. Our Standards and Practices and current CE
have served us well. Additional burdens may make good reading but I doubt will serve the financial planning community
to be better. Some members have earn the letters and limit their practice. Others offer advise and sell no products.
The current system is well balanced for all planners.
Jessica Anderson,
®
CFP
James B. Cox, CFP
®
Comments
With regard to the increase in CE credits I believe that is fine. What is not OK is the reduced acceptance of credits from
organizations such as IMCA and Barron's conferences. It is currently a hugh financial burden just to pay for all the
credits to say nothing about needing to take time away from clients. I have 3 designations, all of which require 40 hours
of continueing education every two years so moving from 30 to 40 is not an issue. The issue is that the CFB board
should be significantly more open to accepting credits earned in a variety of venues.
CE Changes
I would like to voice my opinion against the proposed CE changes. Of course CE is very important to maintaining a
profession. However it feels like the board may be looking at this from inside a bubble. The reality is - that if you are a
practicing advisor, you CE requirements have gone up across the board for all lines of business. Here is a summary of
ours:
®
- CFP [certification] – 20 hrs every 2 yrs
- Ohio Dept. of Ins. – 24 hrs every 2 years
o +4 hrs of LTC training every 2 yrs.
- Firm element for our Broker dealer – 6 hrs/yr
- Series 7 Reg Elem – about 4 hrs every 2 yrs
- AIF designation – 6 hrs/yr
AVERAGE = 38 hrs/yr
All this on top of all the ongoing Compliance reporting, reports and forms takes us more and more away from doing what
we are supposed to be doing (helping our clients). If these changes are meant to increase the revenue to the board, I
would prefer the annual fee to go up rather than require me to be out of the office another day a year to comply with the
proposed changes.
FYI – My wife is an attorney in Ohio and only has 24 hrs CLE every 2 years.
Jim Titus, CFP
®
Ce requirements
1) overall have nothing against the greater requirement...
2) Ethics, the content for 2 hours is poor, having a four hour requirement seems unnecessary. I'm not sure what impact
it will have.
3) if you up the requirement you need to actively develop content and content providers. We see the same faces each
month in JFP and the annual conferences.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Jim Tremper, CFP
Comments
Page 95 of 379
Comment
®
The proposed CE changes are not a good idea. The changes seem to represent an effort to “window dress” the CFP
marks by giving the illusion that Certificants will be more qualified because of additional hours they now must spend not
working with clients or managing their practice.
I would expect that the majority of Certificants are licensed in areas that require annual CE and adding to the time one
spends not getting practical experience with clients is counterproductive.
Jim Uren, CFP
®
Comments on New CE
Proposal
I disagree with the increase ethics requirement from 2 to 4 hours and would like to see the current 2 hour requirement
held in place. If the CFP Board does have scientific research demonstrating that such an increase reduces ethics
violations or complaints, then I would support such an increase in ethics hours.
My concerns:
®
®
2 extra hours of CE is unlikely to turn an unethical CFP professional into an ethical CFP professional.
The information shared in the ethics courses is virtually the same informatoin year after year.
Joseph Radosti, CFP
®
CE requirements
I believe the 30 hours of credits is sufficient.
Additionally, the board should make it easier to obtain credits not more difficult. Online training is better than classroom
training as far as I'm concerned. Many times classroom training consists of nothing more than showing up and eating
dinner.
Don't make it more difficult for planners to get credits. Offer more opportunities not less, to obtain credits.
Don't add expensive training and an unnecessary burden upon planners. Much of what is taught is already repetitive,
adding more hours will only make it more so.
®
Joel D. Worsfold, CFP ,
®
®
CLU , ChFC
Feedback
I don’t like this idea!
We have enough CE we have to do as it is. Most major firms have a significant amount of mandatory internal
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requirement each year on top of CFP [certification]. This covers not only investments but planning and ethics.
I have several other designations and none of them have made changes like this.
It is very difficult to find CE that you truly come away with any new concepts or ideas. They cover mostly the facts which
don’t change much year to year so to require even more I’m not sure what the purpose is other than the CFP Board
again getting their name in the news for something they think will be newsworthy.
®
John Berzellini, CFP ,
CLU, CPA
ethics course requirement
One does not need a course to learn how to be ethical. so I believe the amount of CE devoted to this topic is just fine as
is.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 96 of 379
Comment
John C. Burroughs,
®
CFP
comment on changing the
CE requirements
I do not feel it is necessary to make any changes to the current requirements. Unless one attends the FPA conferences
it is difficult meet the current 30 hours requirement, and I don’t think we should be forced to either join the FPA nor
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attend their conferences. I have been a CFP [professional] since 1978 and I have never felt it was worth the money or
the time to attend the FPA activities.
John P. Campbell,
®
CFP
Comments
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
The CFP Code of Ethics has not sufficiently changed in the last several years, so I think this increase in training is not
needed. I assume the mandatory CFP Board- produced Ethics program would require purchase exclusively from the
Board. That appears to be another money grabbing plan by the Board to go along with the outrageous fee increase
imposed on the members. You're going to price yourselves out of the market if you are not careful. Client activity relative
to securities is declining because of a general distrust in the mechanics of the Market as well as employment concerns.
All of this cuts down on income for the practitioner making fee increases even more financially difficult.
John R. Clark, CFP
®
Stop the Insanity
In regards to the proposed changes to "continuing education" requirements, I make the following suggestions.
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1. Stop creating/expanding the Board's already oppressive rules and regulations...not just concerning CE's. Most CFP
[professionals] are also required to meet other parties continuing educations requirements, ie, FINRA, the SEC, and
various state mandates.
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2. Stop the continous, self-righteousness that CFP certificant's are somehow magically more ethical than noncertificants...there's plenty of evidence to the contrary! Adding more "ethics" CE requirements will not deter the "bad
actors" in our profession...stop pretending that it will.
3. Stop "creating" ridiculous "expose's" such as the latest "give us examples of elderly clients that were taken advantage
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of by non-CFP [professionals]"...it's shamelessly self-serving, and totally unprofessional.
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4. Stop hiring lawyers to staff the CFP [board] "headquarters" and start hiring actual CFP [professionals] who have
experience delivering financial planning advice to real clients. It's quite apparent to most of us that the "Board" is simply
a lobbyist organization, seeking to increase it's "footprint" and revenues by becoming a regulator...just what we don't
need.
In closing, the Board should collectively "look at yourself in the mirror" and decide to serve it's members by providing
useful tools and ideas for delivering ever better service and advice to financial planning clients. If you truly want to be
considered a professional organization, behave like one...and stop the pandering!
John Coyne Jr., CFP
®
John E. Kochlefl, CFP
®
Changes to CE
Requirements
I disagree with the proposed suggestions. The CE requirements should be left alone and remain the same.
changes
Quit trying to justify your existence by creating a need to change the rules. I have more than ample coverage for CE
with all my licenses and designations. In fact, I believe I should grandfather out of all future requirements. The time and
monies spent on CE are already excessive.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
®
John E. Klehfoth, CFP ,
CTFA
Page 97 of 379
Subject
Comment
Request for comment onf
Proposed Revisions to CFP
Continuing Education
Hours
I am against increasing the hours from 30 every two years to 40. If it is increased to 40 I will need to reassess whether
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to retain my CFP [certification] designation. In addition to the current 30 hour requirement I spend many times that
amount in estate planning, tax, investments, etc. education that is not eligible for your continuing education requirement
and never will be.
Two hours of ethics are enough. The courses on the subject are difficult to find. In addition many of the questions are
ridiculous by asking under what sub-paragraph a specific item can be found. Who cares? We can look it up if we need
to know. Making us memorize some of this makes no sense what so ever. The questions need to be made meaningful
and relevant.
Thank you for your consideration of my comments.
®
John L. Harris, CFP ,
Ph.D., RFC
Proposed CE Increase
I applaud the CFP Board efforts to improve the professional competency of certificates. From that perspective, the
proposed increase in CE hours is welcomed.
However, including up to 4 hours for practice management and pro bono activities is absurd. These activities in no way
increase certificant's knowledge to deliver fiduciary-based advice.
Accordingly, either require 40 hours of bonafide EDUCATION credits, or eliminate these non-educational activities and
reduce the proposed increase to 36 hours.
Please don't claim to upgrade fiduciary-based education requirements, and then allow non-education activities to qualify.
Thanks for the opportunity to comment.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
John W. Loyd, EA,
®
CFP
Subject
CE Comments
Page 98 of 379
Comment
Please see issues addressed after selected proposals:
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
I disagree with increasing the number of hours, especially with a 33% increase. Being candid here, most of my
knowledge comes OUTSIDE the classroom (meeting with clients, networking with other advisors, etc.). I also think there
is some "diminishing returns" that can come with extending the number of hours. 30 hours every 2 years certainly
seems sufficient.
Increasing the Ethics CE requirement from 2 hours to 4 hours
I firmly disagree with this increase. While many organizations want to to stand proud and show, "Look at us and how
much ethics we require!", I don't really see how taking a class makes an unethical person ethical. I especially don't see
increasing the number of hours from 2 to 4 having an impact.
Expanding the professional activities that qualify for CE credit
This is an excellent proposal.
Implementing a "50% cap rule
I disagree with this proposal. How is one to decide what "topic" a class falls under? Most classes I attend (if the
speaker is truly qualified) cover a broad variety of topics, even if the heading of the class is for example, on
"Retirement." The class will typically get into tax issues, estate planning concepts, perhaps investments, etc. I also
don't know too many folks that just sit through one type of course (to get all their CE), so I see this as a non-issue but
more of a headache for advisors trying to figure out more CE rules/restrictions.
Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities as
“live” CE programs, rather than “self study.”
I agree with this proposal.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
John M. Lugauer, CFP
Ethics concerns &
Suggestion
Page 99 of 379
Comment
In general I am fine with the proposed changes to increase the credits from 30 to 40 hours every two years, along with
the additional proposed ideas. My two primary concerns/comments are as follows:
1. If you increase to 40 hours every two years, it would be very helpful to provide some "carry-forward" ability for credit
overage. So if I have 45 hours of CE in the current period it makes sense to apply the additional 5 hours to the next
period. My reason is simply based on scheduling. Many times my CE can be bunched into a smaller period of time or
months. If we put in the time to receive the CE it only makes sense that those hours are applied to the current and/or
future requirements. It would be fine if the "carry-forward" only applied to CE earned in the last six months or some
reasonable time period. The "carry-forward" should be unlimited for ethics CE since that credit is hard to find. So if a
participant takes the time to complete an ethics CE event, that should clearly be applied to current of future
requirements.
2. Ethic CE: Going from 2 to 4 credits is fine except that the ethics CE is difficult to find. I would suggest the CFP
Board provide an online module that would satisfy this requirement for at least 2 credits during the two year period. Our
local chapter of Financial Services Professionals struggles with providing ethics CE every year. If you happen to miss
the CE event due to scheduling, then it is a burden to replace those 2 hours every year. If the CFP Board wants more
ethics CE, then it also needs to be part of the solution/provider of ethics CE beyond what it does currently or provide
access to a good third party option.
Thank you for these considerations,
®
RE: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I can appreciate your intent to ensure knowledge and compliance - but your proposal in my opinion is way overboard.
I am deluged with ethics and compliance requirements from my BD and other designations I carry. It seems every week
their is a required course, exam, webinar that I have to review. Going from 30 to 40 hours will not produce any more
knowledge. Secondly, going from 2 hours to 4 hours will not push the "compliant" needle. If someone is not operating
above board - additional hours will not change that person.
Please understand what we go through on a day to day basis. The regulatory and administrative burdens have gone too
far. As in any similar situation, new rules end up hurting the people you are trying to protect. These rules only make our
job more difficult.
Thank you for your time and consideration.
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Proposed revisionsContinuing Education
Please register my comments as being totally against increasing the continuing education burden for CFP practitioners
regardless of what other professions are doing. The only exception to my objection is that I am in favor of the 50% cap
rule. Practitioners who are planning on doing the right job for their clients have an innate desire to continue to educate
themselves and stay abreast of current developments. Those who do not plan to do that job are not going to become
better contributors to quality client experiences by the addition of a few extra hours of formal CE. In short, all this
accomplishes is more regulatory type burden on practitioners who are already buckling under the strain of the ridiculous
increased compliance burdens by state and federal regulators.
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Ten additional hours does not make enough of an enhancement to the knowledge required to be a qualified CFP
practitioner to justify the down time or expense to the practitioner, nor does it provide any sort of meaningful benefit to
the clients they serve.
John MacGregor, CFP
John McCuistion, CFP
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Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
John Mcdonough, CFP
®
Proposed changes to
continuing education
Page 100 of 379
Comment
I disagree with the all of the proposed changes to
the continuing education requirements.For example,
in Pennsylvania,i would need every two years,
40 hrs. CFP, 24 hrs. pa. insurance license, and
30 hrs. for the IRS for tax preparation.This is a total
of 94 hrs. every two years.If you assume an average
of $50.00 per credit hour, that is $4700.00 every two years.
It seems that we are helping to increase the size of
the continuing education industry.
John McElhenny, CFP
®
CE
You could require 40 hours of Ethics and you would not make anyone more ethical. If you are honest, you are honest,
if not, no course will make you honest. This is a bureacratic way to do something regardless of it's actual effect.
Keep adding more requirements and keep raising fees, at some point the value of the designation must be judged
against the hassle of compliance.
John Schnieders, CFP
®
No to increase in CE Hours
Thank you for requesting input to increasing the CE hours. I would vote "NO" to an increase in CE hours because
competency is increased by focus in core areas. CE hours often are often satisfied by himself by reading magazine
articles and getting credit. Most of these articles offer very little new, and do not go into much detail, but they do take
time away from my core business.
Thank you,
®
John Signorotti, CFP ,
CLU, ChFC
cfp ce requirements
Leave CE req. as is. When you consider the CA DOI requirements, FINRA req. and various annuity and individual
product company training, we are overwhelmed with CE req. The only overlap I get is that pretty much everything I do
for DOI and CFP carries over to PACE for the CLU and ChFC designations.
John P. Buechel Jr.,
®
®
CFP , ChFC
CE comments
I believe the standards are fine as currently required. Many of us have state insurance CE, state specific courses and at
my firm many hours of CD coursework. These are all good for Planners and non planners, but the workload has
become cumbersome in this industry that has overregulated the practitioner to make up for the sins of the larger
industry. If we could somehow easily get credit for the extras we do it would easily cover the proposed increases.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jim Gourlie, CFP
Page 101 of 379
Subject
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not acceptable
Comment
I do understand the 50% rule and increased ethics. But 40 credits? However, I am CE'ed to death. I am RIA and
registered representative with an insurance license.
I have to tax 5 examines every year for the "Firm Element" of my broker dealer. Once every 3 years I have to take a 2
hour compency test just to stay in brokerage business. Every two years the state of Ohio requires now 24 credits for
insurance which, again, include ethics of 4 hours. Most of these credits do not cross over to CFP credits, Add this up
with compliance regs that need to be taken care of and audits from both the state and broker/dealer that are required
and it all adds up to less time with the client. The very people we want serve at out best.
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I understand the boards stance to make the CFP [certification] designation the best there is. But over burdening the
designee with more credits is not the answer in my opinion.
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Thanks for all your time in what you do to make the CFP [certification] the outstanding designation that it is.
John R. Curran,
®
CFP ,CLU,ChFC,ADPA
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Jon A Theeke Jr, CFP ,
FIC
Continuing Education
I strongly disagree with eliminating courses tied to professional designations from continuing education. Especially if
those courses have college credit. granted through a University, ACE, or Ponzi. If the topics are relevant to Financial
Planning. I recently took the (ADPA) Accredited Domestic Partner Advisor program through the College For Financial
Planning. This course was a real eye opening of the unique problems couples who are not married have. I now am
better qualified to advise domestic partners. I would also like the course accepted by the Bar Association relevant to
financial planning to be accepted for C.E.. I would also like hours able to be carried over one reporting period.
CE proposed changes
I think the changes just continue to pile on redundancy, cost and add complexity for what should be a fairly straight
forward process. I would rather have you keep the amount of CE the same but adjust the class load to provide a greater
consistency to the CE hours being earned. 50% of the earned CE hours should be directed by the CFP board and be
consistent for all, with the balance being from any of your recommendations.
This would provide greater consistency to the learning, and knowledge of those holding out the CFP designation.
Like most regulation, more hours does not meanbetter training and I think you are creating an environment that can lead
to a dilution of the CFP brand by not maintaining a more regimented CE process. Fewer valuable courses would be a
better and stronger solution.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jon Wax, CFP
Subject
®
Comment on CE
requirement proposal
Page 102 of 379
Comment
I hope this email finds you well. I disagree with the need to increase the CE requirement and restrict the amount of
similar CEs allowed to complete said requirement. To my knowledge, there hasn’t been a pervasive problem with ill®
®
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informed CFP [professionals] damaging the CFP [certification] image. If the problem focuses on ‘the few’ CFP
[professionals] that violate the Code of Ethics or provide inaccurate advice, their actions should not necessitate a more
stringent CE requirement on the rest of us.
In a world where “the good” are constantly receiving higher levels of requirements from sanctioning bodies and
regulators due to the problems of “the few”, we should avoid sweeping changes to give the impression of diligence when
the proper course of action is to make the public more aware of how the CFP Board deals with those “few” who are
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actually tarnishing the CFP [certification] brand.
I hope this input helps the process continue to work favorably for the hard working practitioners who proudly support the
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positive image of the CFP mark.
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CE Proposal
I don’t agree with the proposal to change the continuing education requirement. Please keep it the way it is. My CFP #
is 62492.
Joseph Mandichak,
®
CFP
CE Requirements
I disagree with increasing the amount of hours and also not allowing online courses. You have to remember many of us
are also small business people whose plates are already pretty full.
Joe Radack, CLU,
®
ChFC, CFP
CE requirements increase
i would request that you decrease the amount of ce credits required rather than increase them...these requirements are
burdensome, time consuming, and costly and do not add to the quality of my work..let's go for less regulation rather than
more
Joe Larsen, CPA, CFP
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Joseph E. Tighe,
®
M.S.T., C.P.A., CFP
Comments on increased
CE for CFP's
Page 103 of 379
Comment
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I personally favor any increased standards as it is crucial to insure CFP [professionals] are continuously kept abreast of
current issues in our present economy. However, I do not believe that the present measurement method of requiring CE
credits is accomplishing what you are trying to insure.
My recommendation would be to require annual testing of current issues and new laws and having NO formal CE
requirement.
The reason for this recommendation is that I have very little faith in the CE process. I have heard and experienced
situations where CE credits are given by organizations which require you to pay for the CE program, lunch and sit
through their company advertisement only to be given all the answers to a CE test near the end of the presentation and
to quickly gain 8 or 12 CE Credits. Mirroring the worst Time-share experience you can think of.
I fear that the CE Requirements end up being a way for the educational people to capitalize on our needs and for the
Brokerage Houses and other investment firms to mandatorily funnel advertising at the CFP Board.
Personally, I get magazines and receive numerous e-mail subscriptions which I read consistently along with listening to
45 minutes of Bloomberg radio every morning on my drive to work. I get more knowledge from my daily activities than I
do from mandatory CE requirements.
I am sorry for the negative outlook but I pride myself on honesty and integrity and I have seen enough CE issues as a
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CFP professional and a CPA that I begin to lose faith in the process.
That said, believe me when I say it is clearly not every vendor of CE. I have attended many a formal CE presentation
that were well worth the time and cost of such a class.
My major concern is that there is no certainty without testing an individual.
John Smith can attend 600 hours of CE in his two year window and still not understand enough to properly assist his
clients. Just because you attended that 8 hour CE presentation at the Hilton on Roth Versus Traditional IRA's does not
necessarily guarantee you understand the difference.
In my opinion you should eliminate the CE requirement and and require a skills/knowledge test each year.
Thank you for listening, sorry if I bashed the CE vendors too much.
Joseph DeBonis , CFP
Joshua Slocum, CFP
®
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Proposed Changes
In my opinion , the fee was just increased to annually from once every two years. Before you make changes to any CE
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requirements , wait to assess if the increase fee generates more business /clients for CFP professionals in a few years
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before increasing CE requirements. Currently CFP [professionals] are being asked to give more but are not yet
receiving anything in return.
You got my approval!
Lets keep pushing to make it a true "Professional" designation! The financial industry needs this desperately.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Jeffrey M. Joy, CFP
®
Joe Saffer, CFP
®
Page 104 of 379
Comment
CFP Board Proposed
Revisions
The efforts of the CFP Board to raise standards is commendable. As I reviewed the proposed changes under
consideration, however, I found myself repeating the same question: "How much more is this going to cost me?" Being
an employee of a premier nationwide firm, I get little-- if any --reimbursement for continuing education expenses related
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to my CFP [certification] designation and state insurance license . To make matters worse, the more time I need to
spend satisfying additional CE requirements, the less time I have to meet with clients (less potential income) or spend
with my family (less happiness). In my opinion, the bulk of your proposed changes should be eliminated. They are an
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unfair burden on those who made the commitment of time and money to become CFP certificants in the first place. In
my opinion, I should be earning CE credit every time I encounter a unique client situation that requires me to research
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the matter extensively. Remarkably, I encounter these circumstances daily; I am a practicing CFP certificant.
Proposed CFP CE
Changes
Have you gone mad???
Most of us have real jobs and can't spend their work hours trying to figure out how to get 40 CE credits.
I am in New Jersey and my life and health license requires 12 credit hours of CE per year (and I believe most states are
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the same). CFP [certification] requires 15 CE credits per year, if you divide 30 by 2 years. My CFP [certification]
covers my NJ life and health requirement, with the proper paperwork filled out. How in the world do you think that it is a
good idea to increase that requirement by 33% (going from 15 to 20 credits required per year)??? For what professional
reason that would help us in the financial services industry increase our capabilities? (In my opinion, your reasons are
all lame and just BS.)
I am a Director of Planning (on salary) for Lincoln Financial Advisors. I create comprehensive financial plans for multimillionaires on a daily basis. We concentrate on investment, retirement, estate, and business succession planning. I
also have a small client base to service and no time to do it. (I am in the office right now on a Saturday writing this email
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to you.) I do not have the flexibility, or time, to traipse all over the tri-state area looking for pre-approved CFP
[certification] CE credits.
I get almost all of my CE credits from my Estate and Financial Planning Council of Central NJ (EFPCCNJ). We have 17
meetings per meeting year (Sept - Jun). That allows me to miss one or two meetings per year and still get my 15 per
year. I get my 2 ethics credits from a Lincoln Financial Advisors annual national meeting. It is a challenge to get all of
the credits needed right now. It will be unbelievably hard to get to 40!
In addition, most of the credits from the EFPCCNJ are retirement and estate planning credits. Now you want to limit that
to 50% of the required credits? What are you smoking? Why are retirement and estate planning grouped together?
That additional requirement (that the EFPCCNJ will fail to meet) will make it much more probable that I would fall further
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behind the 40 CE requirement. More than likely, I would fail to get all of the required CFP [certification] CE credits.
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Thinking about it right now, my best option might be to drop the EFPCCNJ and the CFP [certification] designation. That
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would save me almost $700 per year. I could always tell anyone that I was a CFP [certification] designee and why I
was forced to drop the designation. It would be much cheaper to just get the life and health 12 CE credits per year. My
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small client base will not leave me because I no longer hold the CFP [certification] designation.
This looks, sounds, and smells like some administrative IDIOTS are trying to make themselves feel important by
continuing to increase regulations that don't add value to anyone or anything. Thirty credits are not enough, really???
Are you working with the federal government to come up with this crap to regulate us to death? You reference
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 105 of 379
Comment
architecture and law, really???
The broker-dealer side has already gone mad with tons of administrative requirements. There are only more and more
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rules under the guise of "helping" the public. None of this follows common sense and helps the financial planner/CFP
[professionals].
We are being regulated to death. Could we please have someone look at this situation that has some common
sense??? It doesn't seem to me that you considered the time and expense required of all of us to get almost two CE
credits month in and month out with travel to and from with the cost of the meeting also added to the total expense.
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I am very disappointed in your direction for the CFP [certification] designation. I recommend that you drop this
additional requirement. Where are the studies that show exactly what the improvements to our performance in front of
our clients would be with a 33% increase in our administrative requirement?
Judy Perez, CFP
®
Additional CE Hours
®
I am completely opposed to adding hours to the already-ridiculous amount of CFP [certification] continuing education
®
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(CE). More continuing education does not ensure a better CFP [professional], it only ensures that your CFP
[professionals] will not be doing what they should being doing: helping their clients with financial planning.
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-While we CFP [professionals] are sitting at our desks completing open-book examinations for CE credits, we are not
answering our phones when our clients and potential clients call. Your desire to continually increase the CE credits
literally steals time from my clients.
- It costs us more money for more credit, yet doesn't ensure the public a better financial planner.
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-This is not the only license that most CFP [professionals] hold. We have other licenses that require 30 or more hours
of CE, again keeping us from doing what our clients have hired us to do.
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-This decision to increase the cost to do business as a CFP [professional] while reducing time available to service
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clients is the opposite of what the Board of Standards originally set out to do. I have been a CFP [professional] for
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twenty years and am incensed at the direction this current CFP [certification] management is taking: You are increasing
our costs while increasing the "busy work" we must all put up with to retain the license we worked so hard to get.
-We have already proven proficiency in the field of financial planning by passing the most grueling examination in the
industry and yet you continue to increase the CE hours and costs. In 2012, the costs of our CE doubled, and now you
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propose additional hours! Your decisions will lose you CFP [professionals] as they decide the hassle is not worth the
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advantage of being a CFP [professional]. You appear to not value us in any way.
-We are in the field working hard each and every day doing what is best for our clients. We do not need a group of
people sitting in some office somewhere thinking up things that will make this organization "look better" on paper. The
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CFP Board appears to be trying to justify its existence by wasting time, money and effort with additional hoops for CFP
[professionals] to jump through, instead of supporting its members.
I understand that the CFP Board wants to stand apart from people who call themselves financial planners, but ten more
hours of CE isn't the way to do it.
You want a true real-world solution? The CFP Board begins to accept CE from those of us who must take Series 7 CE,
etc, etc. Stop a minute and look at what we financial planners are putting up with: CE from all these separate
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organizations (brokerage firms, individual states and CFP [certification], for instance). We take all this CE, all separate
and not accepted by other organizations! Is Ethics for you different than Ethics when dealing under my Series 7 license
and my insurance license? Different for you than the state of California? At this moment, none of these hours are
transferable! You want to really service your members? Get this financial planning CE mess under control and let us
take a workable amount of CE and then do our jobs. Go to bat for your members and coordinate the financial planning
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 106 of 379
Comment
CE mess into a cohesive and shared instrument of annual education.
I am extremely unhappy with the direction the CFP board is taking and am more than willing to discuss the proper
direction (CLIENT SERVICE!) with you in person. I fear the CFP Board is completely unattached to the real world, the
world in which I'm trying to make a living by helping my clients.
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Judy K. Thomas, CFP
Cmments on Continuing Ed
Changes
Thank you for this opportunity. I am coming from the role as a good student. I keep up with my firm's education and
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compliance training and constantly look for opportunities to earn credit towards my required CFP [certification] hours. I
believe you are not taking into account the quality programs we have to take at our own firm ( I believe I will have spent
at least 30-40 hours on just the FINRA and continuing education my firm requires). Why can't more of those hours also
®
apply to CFP [certification]? I have an insurance license too, and sadly the ethics training required there does not spill
over to your ethics training requirement usually. They are not compatible. I don't believe adding 2 more hours of ethics
makes someone better ethically. You either are ethical or are not. It's not bad to have a reminder here and there but 2
more hours isn't going to change anything or anyone. Those who want to cheat can and always will find a way.
I believe you need to seriously take into account all of the additional FINRA training and classes firms offer and allow
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more of them to be counted towards CFP [certification] continuing ed. Thanks.l
®
Judy Bat, CFP
I totally disagree with the new CE guidelines. Most CE exercises are a waste of time and money - only done to fulfill the
requirements.
®
Karen Flynn, CFP ,
®
AIF
Proposed changes to CE
I have no problem with the proposed changes. Currently I engage in more than the 30 hours of CE because of multiple
designations. My only concern would be that there are sufficient online resources available from whatever sources are
deemed appropriate, especially for the 4 hour ethics requirement. It seems that I never have a chance to fulfill that one
at a conference or FPA meeting as there are other competing courses or time constraints, so I have had to complete
those online for the past two renewal sequences. Plus, I have to take ethics for insurance and fiduciary designation as
well.
Karen R. Palm, CPA,
®
CMA, CFP
Response to CE Proposed
continuing education
I do NOT agree with the 50% cap Rule – my 40 hours a year of income tax classes might be considered a single area
but we cover estate planning, retirement planning, investments under that topic. The additional administrative burden to
prove that a variety of topics have been covered would be overwhelming.
I do NOT agree with the increase in ethics to 4 hours. The 2 hours is plenty. For those who strive for ethical practices we
are always discussing and aware of the issues.
I do NOT agree with increase of hours from 30 to 40 hours as the professional reading time to keep current already
negatively impacts the time available to actually perform financial planning services. Additional class time does not
insure competency.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Alan J. Davino, CFP
Kathryn C. Diduch,
®
CFP
Subject
®
changes to CE
requirements
Page 107 of 379
Comment
As far as I can see, the proposed changes to increase the required CE credits only benefit vendors and organizations
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who offer these credits for a price. You are making it more and more ridiculously expensive to be in the CFP
[certification] club with your drastically increased annual membership fee and now this! Only the most naive individuals
in the world would actually believe increasing the required CE credits would make someone a better financial planner.
Planners who just want to maintain the title will pay the required money and take whatever shortcuts to get the credits --and, believe me, there are plenty of inane workshops and ways by which one can amass credits. Increasing the Ethics
requirement is a real joke. Those two credits right now are probably the most expensive ones to get, and the substance
covered in most ethics courses could be presented in less than five minutes. Financial Planners who are serious about
their profession (and I'm assuming most are) will do whatever research they need to keep abreast of changes in the
financial world and give themselves the edge they need to be successful and competent. Why should they have to fork
out so much money to prove to you folks in your "ivy tower" that they are capable and worthy?
Here's an idea ... offer free CE courses for all certificants --- enough to cover your new 40 hours and ethics
requirements. Yes, ensure they are better courses, more substantive courses. Upgrading the quality of the CE credits is
®
a very good idea. Requiring CFP certificants to throw more money at a perceived problem is the typical way out-oftouch bureaucracies deal with things.
I would like to submit my opinion for consideration. I think the increase from 30 hours to 40 every 2 years is reasonable
and anyone trying to increase their knowledge within the area would have no problem with this. I would like to submit
two suggestions:
-- I would like to have something for CE credit that is educating on new regulations affecting our business or application.
This should be available for CE credits. It would also help the professional.
-- Second. I would like to submit that you leave the ethics hours the same. Again, you do not regulate ethics. One is
ethical or they are not...it is not the knowledge above the current 2 hours that will make one more ethical...it is a value
system.
Unethical people will rationalize their practice to justify their actions within themselves. I have seen it in every industry.
Let's use the additional 2 hours to increase our knowledge and hopefully, those unethical persons will lose business or
get sanctioned.
Thanks so much for allowing me to express my ideas and suggestions.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Kathryn Ann Ray, CFP
®
Re: Comments on CFP
Continuing Ed changes
Page 108 of 379
Comment
I would like to give my thoughts in regards to the proposed changes that the CFP Board has brought to the practitioners
for their input. First, I would like to say that I agree in spirit as to the need for a fully comprehensive and robust
continuing education requirement. I routinely have over my required 30 hours each renewal period. However, I think
®
the board needs to be conscious of the other requirements that some CFP practitioners may have to fulfil to keep their
other credentials in good order.
®
As a personal example, besdies my CFP [certification] license, I also hold CLU and IRS Enrolled Agent designations. I
have 30 hours in each cycle to maintain the CLU (Pace hours) and I have a 72 hours minimum each 3 year cycle
(including 6 hours in ethics) to maintain my EA designation with the U.S. Treasury. Each designation also has separate
ethics continuing education requirements.
It is already somewhat burdensome to keep up with everything that has to get done now in the way of CE credits each
year. Because of the existing requirements for continuing education, I recently dropped my CSA designation when that
board instituted an additonal 6 hour ethics and 16 more hours of continuing education requirements per year. It is not
that I am not ethical. It is that I don't have the time to service my clients as well as I could if I have to attend a plethora of
continuing education seminars each year. Between classes offered through my broker-dealer and IRS seminars and
classes with the FPA, I am in school already for at least 12 days per year, sometimes 15 days. That's not counting
continued education in money laundering, and compliance (ethics) that FINRA requires. Are these new regulations
going to make me more ethical? No. By this time in my career, I am either ethical or not. Of course, I would say that I
am ethical and that when I take ethics based tests such as FINRA's 201 continuing education and compliance session,
or ethics sessions through the FPA, it is not hard to spot unethical behavior. It is not some subtle nuance. The types of
ethics programs that I have attended are so obvious, the inappropriate actions taught are so fundamentally wrong, they
jump right out at an honest person. People who are not ethical and are not commited to keeping at the top of their
profession are not going to suddenly become more ethical because the CFP board increases the required ethics hours.
Another factor of the increased continuing education is the cost of attending the programs. Some of them can be quite
high, particularily if you are traveling and must stay overnight to get to the sessions because of where one lives.
The 50% cap rule is unreasonable at least in regards to the tax topic. IRS sponsored clasess that I attend each year
address estate planning, investments, retirement planning tax law changes and and professional conduct all the time.
®
They are of a comprehensive nature. Many times they are taught by CFP certificants.
Lastly, in my opinion the elimination of the credit that I would get if I chose to complete my CHFC designation is, in my
mind, silly. Why would, for example, credits earned for taking an advanced insurance class through the American
®
College to meet CHFC requirements not be considered continued education to a CFP practitioner? It makes no sense.
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If the college is approved to offer the core course to new CFP [professional] applicants, why would their advanced
classes for the CHFC curriculum not be substantitive.
Thank you in advance for your consideration of my opinion.
Kathy Klein, CFP
®
CE requirement changes
All of the above adjustments to the CE requirements look both appropriate and positive. I continue to be frustrated with
the lack of public and professional respect for the designation. Anything that increases the rigor and quality of the
continuing education is welcome and needed. It is my hope that as the higher and more stringent standards are
implemented they are also advertised to the public.
®
Thank you for your dedication and work towards building a stronger CFP [certification] community and brand!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Deena Katz, CFP
Subject
®
®
Rose Kay Parker, CFP
Page 109 of 379
Comment
Proposed CE requirements
Bravo! I believe all these changes will greatly improve professionalism.
Comments on CE
requirements
My situation/fact pattern:
• CPA, certified in Texas. Recipient of the Top Ten Award in 1982 for high scores on the CPA exam
®
• Received CFP [certification] Designation in the 80s, as a result of passing a challenge exam
• I do not have a financial planning practice – I am a tax practitioner with entrepreneurial and high net worth clients.
• I am required to complete 40 hours of continuing education every year to maintain my CPA certification.
• Every 2 years, I have to take a 4 hours ethics course approved by the State Board of Public Accountancy in order to
maintain that certification.
My comments on CE proposals:
®
• The Ethics course I am mandated to take in Texas should count towards my ethics requirement for CFP [certification].
I currently have to take two ethics courses in order to maintain the certifications—but the content is very similar.
• The 50% cap rule does not work for me. I am a CPA with a tax practice – I do not actively perform financial planning,
but use financial planning principles/concepts in my tax practice. Almost all of my CPE is concentrated in Income Tax
and/or firm management activities (I am a shareholder in a firm of approximately 60 individuals). I have no interest in
General Principles, Insurance, Investments, Fiduciary Responsibility since these topics do not make me a better tax
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practitioner. I would have to consider giving up my CFP [certification] designation and pursuing the AICPA sponsored
CFS instead, if your CPE requirements change radically.
®
• Any CPE which qualifies towards my CPA credentials should be acceptable to the CFP [certification] board without
my having to pay a fee for you to review it (if a CPE sponsor is approved for CPA Continuing Education, the course
should be acceptable if it is on topic).
I am happy to speak with you to flesh out any of the above comments. Every year, I have to make a decision as to
®
whether or not I renew my CFP [certification]. Cost is not a factor, but the time commitment to take non-relevant
courses certainly would be an issue for me. Icommend the direction you are going with these recommendations, but
would request that you consider the impact these would have on other professionals who also choose to pursue the
®
CFP [certification] designation as a supplement to our primary designation/career path.
Thank you for your consideration.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Matthew R. Keenan,
®
CFP
CFP Request for Comment
Page 110 of 379
Comment
If I understand the proposed changes correctly, there would not be CE credit awarded for completion of other
designations such as the ChFC and CFA. As I am in the process of perusing these designations, and the work within
these designations directly relates to the furthering of my education in investment and insurance planning, I am
surprised these would no longer be counted as a part of continuing education. I understand the desire to go to a more
"live" versus "self-study" education program, however, it would be virtually impossible to complete the new 40 hour
requirement purely off of self-study. If I understand the objective of the below proposals, I greatly disagree with these
two points:
• Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
Rationale: Recognize the quality control measures that regionally accredited institutions are required to incorporate in
the development and delivery of self-study courses offered for academic credit
Keith Bonner, CFP
®
RE: Proposed changes to
CFPR Board's CE
requirement
®
®
We are proud to be CFP professionals. We understand the importance of maintaining the high standards for the CFP
[certification] profession. However, it is our opinion that the proposed changes to the CE requirements will not serve any
purpose, other than increasing the burden on certificants. We are already being smothered by a large number of
regulatory changes. Adding ten additional hours of CE (including 2 additional hours of Ethics) won’t change the
compentency or ethical behavior of the certificants. What it will do is increase the cost of running a firm. It will be an
additional requirement that removes us from serving our clients.
We would ask that you reconsider your proposal. Why not put your efforts into “simplifying” the CE options and making
it easier to get quality CE credit. Why not help us to be better planners. Why not provide resources that would provide
“best practices” for our industry.
Keith willerman, CFP
®
Comments about CE
Changes
Opposed to the following changes:
Granting CE for practice Management Classes – CE should be based on education that helps the public
Granting CE credit for Pro Bono work – no form of reward should be given for helping others on a pro bono basis
Increasing Code of Ethics CE requirement from 2 to 4 hours and mandating CFP Board of Ethics Program – the current
2 hour require is sufficient it covers all our guidelines and has rigor
Expanding CE for course grading, study group activities – CE should be based on educations that helps the public not
course grading or study group activities that cannot be properly monitored
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Kelly L. Higgins, CFP ,
CPA
Ken Bickel, CFP
®
Page 111 of 379
Comment
Thoughts. . .
I have no problem with 40 hours of CE from 30, however, not all CFP's, like myself, hold just one designation or license.
Between insurance continuing education, securities licenses, the broker-dealer internal required annual continuing
education with anti-money laundering and branch office security practices, etc. mandated by FINRA, compliance coming
into your offices on an annual basis, annual compliance CE requirement, 408(b)2 regulations, Dodd-Frank regulations
that you have to comply with--even though you already are compliant through the planning process--suitability forms, the
regulators make no distinction between those who practice financial planning and those who do not. We are drowning in
regulation. Having an independent RIA and all the changes that have taken place over the last 18 mos. here as well. In
the state of Michigan, attorneys are not required to have any ongoing continuing education--it certainly is a best practice.
®
If I could just have the CFP [certification] CE requirements to have to contend with, it would be a breeze. It's gotten to
a suffocating point of regulation/compliance, etc.! Be mindful that insurance CE requires ethics, CPA CE requires
ethics--shouldn't ethics transcend designations/licenses? You either conduct yourself in an ethical manner or you do
not. We are crowding out the ability to practice our craft because we spend all our time documenting compliance and
®
ongoing supposed "education" that is useful. I'm not saying CFP [certification] CE is not useful--it's what I want to
concentrate on, however the business model I am in demands much, much more from me as a business owner. The
reason why I have not given up my securities/insurance licenses and gone fee only is because I think eventually the
independent RIA will get roped back into what the rest of us are experiencing. So please be mindful of the other things
®
on our plates. I have met CFP [professionals] who describe themselves as anti-planners and yet they proudly display
their designation and certificate on everything.
Comments on changes to
CFP requirements
Thank you for the invitation to give my reactions to the proposed changes.
Please put me in the pile of responses marked “OPPOSED”
I think the Board is living in a silo forgetting that most of us have other licenses to maintain which require us to fulfill
continuing education as well. For me this this means state Life and Health license requirements 6 states in addition to
FINRA. There is almost no crossover for getting dual credits even though clearly almost anything I do for one of these
®
entities ought to be relevant to the CFP [certification].
I don’t see the point. If you want to do something helpful, help coordinate the CE requirements with other CE providers
so we can get out of our silos. I strongly object to another heavy-handed layering of requirements by the CFP Board.
®
Ken Dean, CPA, CFP ,
MST
Increase in CFP CE
I do not want to see the CE requirements changed.
Over the years, I believe the CFP Board is moving more toward the CFA designation in testing and leraning outcome
statements. As you may already be aware, the CFA designation does not require any CE credits. For the professionals
who have acquired such marks, we are constantly educating ourselves in our field. The additional cost and time over the
30-hour requirement I believe does not bring any additinal value.
Also, it would be helpful to provide your recent webinars with CE credit. If you are going through the trouble to make
such important topics available, why not have CE rewarded?
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Kenneth R. Solow,
®
CFP , Chief Investment
Officer
Ken Eidson, CFP
®
Kenneth R. Bakula,
®
CFP , CLU, ChFC
Page 112 of 379
Comment
®
Oppose
Please count this comment as a strong negative for increasing the continuing ED requirements for CFP [certification]. I
believe we have plenty of hours to support the contention that we are a professional organization. I am in favor of
getting credit for speaking and educational engagements, but not for community service time. I am very busy helping
my clients and the challenges I face have little to do with my expertise. In general, the issue is time. Please do not
make keeping my designation any more onerous.
New CE
I have been a CFP [professional] since 1989 and seen a lot of changes. Most seem to be benefiting the organization,
®
®
rather then the CFP [professionals] or the clients of CFP [professionals]. This just fits right in with what was once a
very good program.
CE
I would highly encourage that the CE requirements stay at 30 hours every two years. Every two years I have to
®
complete 30 hours for PACE through the American Society, 30 hours for state licensing, and 30 hours for CFP
[certification]. Sometimes these courses can count in all categories, but many times they do not. Ethics are required for
®
CFP [certification], State Insurance offices, and company affiliations. Many of the ethics courses do not overlap and
®
count for each other. I agree that continuing education is important in our industry, but through CFP [certification] the
®
overlap between other CE credits do not count toward CFP [certification] or have to be approved and additional fees
are assessed. It is getting too complicated to track and make sure which credits are applied to each area for different
organizations. It would be difficult for our local FPA to offer 40 hours of CE every two years, and this is where I pick up
®
my credits for my CFP certification. Thank you for your time in this matter.
®
®
I’m opposed to all of your changes. CE is getting expensive. You must assume none of your CFP [professionals] have
to do this with others. I have to meet CE for other designations as well as other licenses. There is a limit as to how
much a person can do, pay for, and has time for. I received my CMFC without any strings attached only to now be
®
required to pay to keep it. CFP [certification] now has annual certification dues that are higher than when it used to be
every other year and was less! Now you also want to put more requirements for more hours at more cost along with all
®
the other costs. My knowledge will be the same in the future even if I just give up my CFP [certification] and CMFC
designation and that is starting to look more like the direction I will be going if further bureaucratic edicts come down or
this goes through.
Kent E. Anthony, CIC,
®
CFP , CMFC, RFC
Respectfully submitted,
Kenneth Egerer, CFP
®
continuing ed.
®
My feeling is that 30 ceu's is enough. In addition to cpe for the CFP [certification], most certificants have to complete
ceu's for thier insurance licenses, securities licenses, and now with IRS if we prepare income tax returns. Please,
enough is enough.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Michael S. Kertes, CFP
Subject
®
My Feelings on proposed
issues
Page 113 of 379
Comment
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations. The proposed increase in required hours is consistent with
recommendations from CFP Board’s 2007 and 2008 Education Task Forces.
1. Makes Sense due to changing environment.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
o Practice management CE programs. Defined as programs focused on the planning, development and management of
®
a CFP professional’s business operations, office management, business model design, budgeting processes and
leadership.
o Pro Bono (volunteer personal delivery of financial planning) services. These activities must be supervised by a
registered CE Sponsor organization and will be accepted for 1 hour CE credit per 4 hours pro bono service.
Rationale: Recognize the importance practice management plays in the delivery of competent and ethical professional
financial planning services to clients. Encourage pro bono service for the public benefit.
• No for practice management; limit on pro bono. i.e. no more than 4 hours total, but only if requirement jumps to 40
hours. If stays at 30, then no credit.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.
1. YES
• Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following:
o Participation in Registered Program Financial Planning Development ("capstone") course grading panels. These
activities must be verified with documentation of active participation, written assessments and qualitative feedback;
o Study Group Activities that meet certain guidelines;
o Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
Rationale: Encourage body of knowledge expansion and no cost CE opportunities.
1. Yes on grading panels
2. Probably not on study group
3. Probably yes on research
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule."
Rationale: Ensure diversity of learning experiences across breadth of planning topics.
1. Definitely YES
• Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 114 of 379
Comment
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
1. Certain designations should be approved, but only a small number. Here would be my list: CFA exams, FINRA
series 6 or 7 only.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
Rationale: Recognize the quality control measures that regionally accredited institutions are required to incorporate in
the development and delivery of self-study courses offered for academic credit.
1. Don’t understand what the board is attempting to accomplish here. Needs a better explanation.
• Encouraging increased rigor and quality of all CE program delivery methods.
®
Rationale: Help ensure that CE programs available to CFP professionals contribute to their professional competency.
1. Yes.
®
Kevin P. Ellis, CFP ,
®
CPA
Kevin J. Smith, CFP
®
Kirk R. Peterson, CFP
®
Proposed rule changes
Respectfully, while increased CE requirements might be well-intended, doubling the ethics requirement will accomplish
®
very little in the way of increasing ethical awareness while merely adding cost and inconvenience to CFP professionals.
The reality is that advisors will either take their ethical duties seriously or not and such a requirement smells more like a
feel-good initiative rather than something that will actually have any incremental effect. It also seems analogous to the
overreaction of Bachus’ proposal on the SRO issue which appears to be a gross overreaction to the Madoff scandal and
others. I hope that wiser minds prevail on such a proposal.
Additional CE's for CFP
As a full time financial advisor and a CFP [professional] I believe 30 hours of continuing education with 2 hours of
®
ethics credit is adequate commitment to maintain the CFP [certification] designation. Although the financial planning
world has become far more complex there are a lot of educated people with all sorts of credentials that do not care one
bit about their clients. If you believe like the majority in political office that you can legislate lifestyles and attitudes by
®
requiring more hours of study I do not agree. I have been a CFP [professional] since 10/11/2004 and in those eight
®
years I have only been asked twice if I was a CFP [professional]. Instead of adding more to our plate the better
®
question I think to ask is why individual investors do not seek out CFP [professionals] over other advisors.
CE Requirement Proposal
Is there an actual problem with CFP [professionals] not being sufficiently competent and ethical, or requiring
disciplinary action? If not, what is the purpose of layering on even more regulatory burdens on we small business
people? Between the SEC/States, DOL, ERISA, Dodd-Frank, Sar-Box, Graham-Leach-Bliley, the IRS, etc., we spend
more time dealing with regulations than doing our jobs for our clients! If there is a problem, I’m not aware of it. My
suspicion is that the percentage of certificants who perform infractions to the Code, is extremely small. It seems that
every organization can’t control its desire to build empires, control others, and incessantly make rules.
®
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Kirt T. Kisselle, J.D.,
®
CPA, CFP
Page 115 of 379
Subject
CE proposal feedback
Comment
Please note my comments in red below.
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations. Ohio Bar only requires 24 hours of continuing legal education
every 2 years. Ohio law changes are frequent.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.Ohio Bar only requires 1 hour of
professionalism, 1 hour of ethics and 1/2 hour of substance abuse education every 2 years.
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule."
Rationale: Ensure diversity of learning experiences across breadth of planning topics.Accountancy Board of Ohio
approaches this much differently. They have a minimum continuing education requirement in the CPA's area of
practice.
• Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible. Accountancy
®
Board of Ohio gave 100 hours of continuing education for passing the CFP [certification].
Kathleen M Morris,
®
CFP
New Continuing Education
Requirements
®
I am opposed to changing the requirements for CFP [certification] continuing education credits. I am a tax and financial
planning consultant. Presently, I am required to take 15 credit hours per year for the Internal Revenue Service in order
®
to continue to prepare income taxes. If the CFP [certification] continuing education credits are increased, I see this as
®
a burden on me. Consequently, I will have to decide if having the CFP [certification] designation is worth the 40
continuing credits.
Thank you for your consideration.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Latimer B. Eddy, CFP
®
New Education
requirements
Page 116 of 379
Comment
I think that your new education requirements are too stringent.
®
You compare the CFP [certification] to other professions like archetecture and the law. However, these fields require
licenses in order work in them as a professional. Unfortunately, anyone can practice as a financial planner. No one
®
®
needs to be a CFP [certification]. I have been a CFP [professional] for almost twenty years, and cannot think of a
single instance where it helped me attract business.
®
®
More stringent rules means less CFP [professionals]. The focus should be on expanding the use of the CFP marks,
®
and making more financial planners want to be CFP [professionals]. That is how we raise the etical standards of those
practicing in the field.
The general public will never know, or care, that you hare tweeked your continuing education reles. They care about
being able to work with someone that they can trust.
®
®
Ray LaDieu, CFP ,
®
ChFC
CE Requirements
I am an 11 year CFP [professional] designee and, though I appreciate your thought process for increasing the biannual education requirements, I would not be in favor of any increase in the amount of CE necessary to retain my
designation. The Board has already made a substantial increase in dues and that is plenty enough. Thank you in
advance for your consideration.
Larry T Christiansen,
®
CFP
CE requiremetns
These are already too difficult and expensive. They should be reduced, and not expanded.
CE Requirements
Good Afternoon,
Larry Ennenga, CFP
®
Regarding the request for CE comments; I don't know that increases the quantity of CE is the only way to improve the
quality of services delivered by certificants. I have a few issues I would like to air. I thought the change made in dealing
with bankruptcies was a bad idea. While there are good reasons a person might have to file bankruptcy, it seems to me
our personal finances are a barometer of the practical use of our skill set. As such, bankruptcies should be looked at
closely. I bring this up because the premise of increased CE is to improve our skill set and the delivery of our services.
50% Cap Rule. I see the value of diversifying the CE exposure. I would only say that sometimes I use CE as a way to
learn and refine skills in an area that I need for some issue I am going to be working with. If a 50% cap is established,
then maybe we should allow a carry over of 10 or 15 hours from one certification period to the next. This would allow
credit for using CE as part of a specific research focus, but still require a broad total CE experience. For example, when
changes in long term care insurance and the state programs were made a few years ago. It would have been easy to
get 20 hours of CE in that general area. If a person could only use 15 hours, under the 50% max, 30 hour requirement,
why not allow the extra 5 hours to carry over to the next certification period. It would be easy to limit the carry over to
30% to 50% of the total CE requirement.
This carry over CE just generally makes sense to me. Also, because the timing of conferences and the posting of credit
can create a problem when the conference is too close to your renewal date to ensure the credit is posted for the current
period. My renewal date is 10/31. A number of conferences occur in September and October. In times past the credit
was slow in getting posted so i had to take courses online to ensure I met the requirements. Some of the time the
conference credit then did get posted on time, but was discarded because there was no carryover of credit. I think there
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 117 of 379
Comment
is some precedent for carry over of credit. My state of TN allows carryover for insurance CE. I have not researched other
professional designations, but it would be easy to do.
If I read the online course section of the document to read we can study online, but not test online, I think this is a bad
idea. As a busy business owner I need the flexibility of multiple venues for meeting the CE requirements. Online is an
important venue for me. An increase in CE would only make that more important. I am on vacation, and that is the
primary reason I am able to take this time to answer this type of request so quickly. My odd hours make flexibility in
accessing CE crucial.
I appreciate the consideration of my thoughts on this subject.
Larry Falzone, CFP
®
Lawrence P. Kennard,
®
CFP
Ce Requirements
If anything the CE hours should be REDUCED. There is not enough new material to justify an increase in CE hours. As
it is every two years the CE courses are redundant and waste precious time for those engaged in providing the best
service to their clients. The only ones who benefit from the CE courses and hours are the schools that provide these
courses. Once again, over regulation, over education, and profit motives rule the day. Let's get serious and start
®
reaffirming the purpose of CFP [certification]. We don't need more education, more advertising, or increased fees. What
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we need is a reinforcement of the numerous rules and regulations we already have and a DEFENDING of the CFP
®
[professionals'] educational standing and benefits of using a CFP [certification]. I am afraid we have lost our way, and
that is reflected in the sad but true statistic that the average age of a Financial Planner is 57 years old. If that isn't a
wake up call to the over regulation of this profession, then our demise is surely to happen sooner than later. We need to
stop this "Al truck" definition of Financial Planning and get back to reality before it's too late. We are headed towards a
1-800 number for financial services.
CE changes
I think the requirement of 20 hours every two years and 2 hours of ethics is ENOUGH!! This increase is unwarranted
and unnecessary, especially the increase in ethics.
®
How does 2 more hours of ethics traing make you more ethical?? It only proves to make the CFP [professional] more
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costly to maintain. This could cost you to lose more memebers rather than increase the quality of CFP [professionals]!
Larry McClanahan,
®
CFP , CASL
Proposed Revisions to CFP
Board's CE Requirement
®
Thank you for the opportunity to review and comment on proposed revisions to CE requirements for CFP certification.
As I read through the proposed revisions, I found myself neutral-to-supportive of all proposals except increasing required
ethics from 2 to 4 hours.
While one could argue that requiring 4 hours of ethics every 2 years is no significant hardship, I fear the CFP Board may
be falling into some misguided thinking. Ethical lapses are almost never due to lack of education. They are typically
behavioral in nature…deliberate, improper choices. No amount of increased education is going to prevent such lapses
with those individuals who are bent on making the wrong choices.
The new ethics proposal has the appearance that the CFP Board is taking a proactive approach to promoting ethical
behavior. But it will only place additional burden on those of us who have already committed to making the right choices.
I urge the Board to discard this misguided proposal.
Thank you for considering my comments.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Larry Morgan, CFP
Subject
®
Page 118 of 379
Comment
I believe that your existing requirements are tough enough without increasing the burden. I would suggest that you
consider making it harder to obtain the certification rather than making it tougher for those that already have it and our
trying to earn a living and need their time and money for their family rather than wasting time taking courses or attending
a meeting that they would not have attended.
Larry C. Klingensmith,
®
CFP
Proposed new CE
requirements
I feel the current requirements are more than sufficient especially in light of many companies requiring continuing
education on their products along with annual anti-money laundering training. The time and cost of continuing education
along with increasing licensing fees is becoming a nuisance. Please leave things as they are or grandfather those with
20 years experience without any complaints from more burdensome regulations.
proposed CE changes
I am an Enrolled Agent and Certified Financial Planner. The work I do is almost exclusively related to tax planning and
®
preparation. If the 50% rule is implemented I will very likely let my CFP [certification] lapse. While I highly value the
certification and designation I am not likely to spend time and resources learning about topics that are not relevant to my
individual practice. I do not do Comprehensive Financial Planning and do not represent myself as doing so.
Laurie A. Z. Bitter, CLU,
®
ChFC, CFP , CASL
CFP CE
I recently renewed my CFP [certification] license. For my state license and PACE, I usually have in the range of 50 to
®
60 hours of CE (twice what is needed in most cases). However, because the CE for CFP [certification] is limited to
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certain providers and delivery systems, most are not approved for CFP [certification] continuing education. I could see
increasing the hours of CE if you allow more of other CE to count toward the total. At my renewal this year, I was
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shocked to find I was 13 hours behind for CFP [certification] and be at over 40 hours for a state license that doesn’t
even renew for another year and requires 30 hours.
Lawrence P Hamilton,
®
CFP
Revisins to CE
Requirements
I am adamantly not in favor of increasing the CE requirement from 30 to 40 hours over a two year period. The other
proposals are those on which I have no opinion.
I am surprised the CFP Board thinks it necessary to heap more administrative burdens upon practitioners who are
having such burdens on them increase almost daily. Yes, the complexity of our discipline changes at an ever increasing
rate. This in itself requires more effort and time to keep ones self current. Now it has been decided that it's important to
make practitioners spend even more time away from their business, their clients and families just to keep their
certification...this is not necessary. Please don't bury us under more details which are being heaped on us by FINRA,
SEC and our own broker dealers. I am not a believer in big government and i am not a believer in over regulation. I am
an honest practitioner trying to do the best by my clients while making a decent living...more hours in the classroom will
not help me do even better.
Lauren Jarvi, EA, CFP
®
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Lea Smith Johnson
®
MBA, CFP , RFC, FIC
Dale Lehenbauer, CFP
Leisa Suchan, CFP
®
®
Page 119 of 379
Comment
Proposed CE revisions
Your proposed changes may make it less attractive designation than presently. Although you state your rules remained
unchanged for many years, this is incorrect. For ethics to be a high priority for the Board this overstatement in your
proposal should be emphasized rather than this subtle reminder here. In recent years you changed the requirement for
a college degree and this was applauded. Your present proposal is not.
®
Advisors who hold the CFP [certification] are continually required to take many classes already. Now, with
legal requirements like the Dodd Frank and industry changes, an advisor’s time can be completely wiped away from the
original goal to help those who seriously need financial planning professionals. More Board requirements are counter to
helping these people t who need professional planning as there is not time now for the detailed planning that can be
done. Support us using your designation and holding it above other designations. A better way for you to increase the
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CFP [certification] designation is to educate the populace about your and the importance in using trained planners,
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those with the CFP [certification] designation rather than taking our time away.
Respectfully submitted,
50% cap and Professional
Designation credit
In this CE period, I completed the CFA Level 2 and 3 exams. As it is, I will receive 28 hours credit for over 600 hours of
actual study. Under the proposed changes that would be capped at either 20 hours or not allowed at all. While some
professional designations may be in question, I firmly believe that I learned a lot from these courses. I think other
practitioners should be encouraged to undertake this course of study. Professional designations and their related
course of study should be reviewed on an individual basis.
proposals
Pertaining to continuing education, a person should be permitted to specialize in a specific area or areas of study as
desired by the person for the following reasons:
• Specialty is not a bad thing. When the old norm may not be as applicable in any given environment, why not allow a
person to focus on a specific area of study when so much change is occurring? Take for example, investment planning.
With the market as volatile as it is today, for one that specializes in investment planning day in and out, and the different
theories are abundant on what makes most sense, getting education in that area and allowing it to count should not be a
concern for the Board. It should be encouraged by the Board!
• Isn't there a rule that states if one does not have knowledge about a specific area the client must address, then the
client must be referred to one that can address the concern? So for example, if a person does not engage in investment
planning, why force that person to study that topic when he/she can refer the client to a specialist?
• There are numerous courses that are classified as being only one area of study. For example, Surgent McCoy offers a
Tax Camp course that qualifies for CE. Although that course is listed to be a "tax" course, from my experience, that
course covers estate planning, business planning, practice management, charitable giving and other gifting strategies,
types of trusts, retirement planning, strategies for retirement distributions and more. My point is tax hits many different
planning topics. I am certain that there are other courses that are similar, in that the classification is only one topic, but
content covers so much more.
• Finally, the CE providers will benefit the most, not the client, by creating this strict multi topic rule and by requiring
additional credits.
Thank you.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Page 120 of 379
Comment
Linda C. Mock, CFP ,
CRPC
Re: increased ce credit
hours
I think adding additional hours to the CE requirements is unnecessary and burdensome to all of us. Additional ethics
hours are redundant. Those of us
who are ethical will continue to remain ethical. If the ethical standards are so convoluted as to require additional hours
of study, then perhaps
the rules themselves should be rewritten to make them easier to understand.
®
®
Practice management is indeed important for CFP [professionals] and I wish that my CFP [certification] education
included that in 1996 when I took the exam.
Adding additional hours for this is also burdensome and the scope of allowable courses within the 30 hours should just
be broadened.
Those of us ( the majority of financial planners) who work for brokerage firms/wirehouses already have additional
continuing education
credits requirements by the annual Reged courses.
Enough is enough.
Please leave the 30 hours intact.
Thank you.
Linda L. Sutton, J.D.,
®
CFP
Consider allowing the
various State Bar
Associations' Continuing
Education to be used for
your continuing education...
Consider allowing the various State Bar Associations' Continuing Education to be used for your continuing education…
Comments on proposed
changes to CE
requirements
Please see comments in red below:
Linda Wong, CFP
®
The proposed changes under consideration are:
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours. Agree.
Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations. The proposed increase in required hours is consistent with
recommendations from CFP Board’s 2007 and 2008 Education Task Forces.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period. Agree
o Practice management CE programs. Defined as programs focused on the planning, development and management of
®
a CFP professional’s business operations, office management, business model design, budgeting processes and
leadership.
o Pro Bono (volunteer personal delivery of financial planning) services. These activities must be supervised by a
registered CE Sponsor organization and will be accepted for 1 hour CE credit per 4 hours pro bono service.
Rationale: Recognize the importance practice management plays in the delivery of competent and ethical professional
financial planning services to clients. Encourage pro bono service for the public benefit.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content. Disagree.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.
• Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 121 of 379
Comment
and authorship) with the following: Agree
o Participation in Registered Program Financial Planning Development ("capstone") course *Additional comments
below*
grading panels. These activities must be verified with
documentation of active participation, written assessments and qualitative feedback;
o Study Group Activities that meet certain guidelines;
o Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
Rationale: Encourage body of knowledge expansion and no cost CE opportunities.
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule." Agree.
Rationale: Ensure diversity of learning experiences across breadth of planning topics.
• Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.” Agree
Rationale: Recognize the quality control measures that regionally accredited institutions are required to incorporate in
the development and delivery of self-study courses offered for academic credit.
• Encouraging increased rigor and quality of all CE program delivery methods. Definitely Agree!!!!! I would suggest
“requiring” vs. “encouraging”. I think increasing the rigor and quality is even more important than increasing the required
hours. Too many presentations I’ve attended are really “motivational speakers” rather than quality education
experiences, or are so general that they are a waste of time. I’d like to see more programs that delve deep into
narrower areas of planning (e.g. social security, education planning, life insurance, P&C insurance). Not only the
academics, but real world application (e.g. how do you analyze the stability of a life insurance company?). I’d also like
to see more programs that concentrate on strategizing between the different areas of planning (e.g. coordinating estate
planning needs with cash flow needs).
®
Rationale: Help ensure that CE programs available to CFP professionals contribute to their professional competency.
If it’s not too late to make additional suggestions, I think it would be great if we could carryover at least a certain amount
of excess credits to the next reporting period . I am 8 months into my reporting period and have met almost all my CE
requirements. I try to find programs that offer “rigor and quality” and often times these can cost hundreds/thousands of
dollars. Should there be additional programs I feel would be useful for me during my current reporting period, I would
not likely attend if I had to pay and could not use the CEs. Allowing carryovers to the next reporting period would
provide practitioners flexibility in the programs they attend and in controlling costs.
Thank you!
®
LISA CHACON, CFP
Ethics
I agree with the recommendations except the extra Ethics course. It is overkill when we are already fiduciaries.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Anne G. London, CFP
Glen Lothary, CFP
®
Louis C. Fancher III,
®
CFP
®
Page 122 of 379
Comment
CE requirements
I am responding to your suggested CE requirement changes. Although I do recognize that maintaining our knowledge
base is important, I feel that increasing the required hours over 30% is a burden. I feel that the current hours plus hours
that I must maintain for other licenses that are involved in my practice takes away significant time from my client time. I
would vote against such a significant increase at this time. I also feel that increasing the ethics requirement should be
®
correlated to the ethics training that we must do related to insurance licensure, not specific to CFP [certification].
Treating clients ethically is certainly a primary emphasis in my practice, but what constitues ethical behavior is not
dependent upon CE credits tailored to one license. Any ethics that is sufficient for the insurance license should be
sufficient for any additional hours required should the rules change.
Also, additional restrictions on approved courses taken on line should not be approved. If we do the courses outside of
work hours, online courses allow us to do them at our convenience. They should be encouraged, not discouraged for at
least a portion of the requirements. Whether they are graded or not is inconsequential.
Changes to the CE
Requirements
Let’s face it this look like a revenue grab by a group that has been doing a lot of it. I have increased CE for FINRA,
®
CFP [certification], and other groups when I am actually going to have time to do my real job rather than just study for it.
I would like to know what kind of kick backs you are getting from the CE providers for increasing their revenues with
this?
Comments on CE changes
My main comment on the CE requirements is one of frustration with CE Credits that the board provides for accredited
schools. I am enrolled in the MSFS program through The American College in Bryn Mawr, PA. This is a Masters
Degree program and some of the coursework has been as challenging as any material that I have done in my
professional career. These programs are generally self study with proctored exams. It is not unusual that I will spend
40 hours or more reading and studying for each of these courses yet the CFP Board recognizes some of these courses
sometimes for 7 to 8 hours of CE Credit (please see attached CE Matrix). This is compared to the 30 hrs of PACE CE
Credits offered to CLU / ChFC designees.
It is hard to compare the 8 CE Credits I would receive by simply showing up and sitting in a hotel conference room
speech for the day to that of GS 815 Advanced Estate Planning (7.5 hours??) or GS 817 Personal Tax Planning (8
hours??). 8 hours?? For a graduate level course on Estate Planning or Personal Taxation?? The required reading for
each of these courses is mind numbing.
Thanks for your consideration.
Lucianna Molinari,
®
CFP
CFP Board requests
comments on proposed
revisions to the Continuing
Education requirement for
®
CFP certification.
Looks like more hours required and more hoops to jump through to get those hours. Not saying the proposals are bad,
just noting that it will be more difficult to complete requiments and members may more often find themselves "under the
gun" to complete.
Respectfully submitted,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Luther Engler, CFP
Subject
®
Page 123 of 379
Comment
Proposed changes to CE
requirements
I totally disagree with several of your proposed changes. Increasing the required hours from 30 to 40 is unnecessary
and would only serve to line the pockets of the companies offering the CE credits for fees. We have to spend our time
on our business, not scrambling for credits when the 2 year period is about expire. Many of us are one man offices that
have to close while atteding CE classes. Most of us take more than enough credits and take many related courses not
offering credits. We don't live in an ivory tower, we live in the real world and have to make a living.
Increasing the ethics requirement from 2 to 4 credits is ridiculous. You cannot teach ethics!!! You either have them or
you don't, and doubling the most boring part of of the CE requirement will make it twice as tedious. Have you ever
attended an ethics class? What did you learn from it? Speaking from experience, I have attended many through the
years and have yet to fine one interesting. People giving the classes love it because they make money. However,
those of us who have to suffer through them and come away with nothing would loath to see them doubled. I don't
believe that ethics courses contribute anything to our professional competency or make us better in any way.
I understand that you are trying to protect us from public criticism, but I believe that 30 credits, 2 of which have to be
ethics, does the job and increasing them as proposed would put an unnecessary hardship on those of us trying to make
an honest living in this profession
Proposed changes in CE
I am writing to respond to the proposed changes to our CE requirements. I do NOT think there is any valid reason to
increase the Ethics course requirement to 4 credit hours every two years. Those of us who are ethical individuals do not
need to be further regulated and those who are unethical cannot be reined in by taking courses. The fact that we are
required to take such tests is an insult in the first place, kind of like trying to get the horse back in the barn after the door
has been opened. The CFP Board of Standards and their rigorous reviews of potential offenders is enough of a
deterrent for those bad eggs in the bunch.
I believe that total for two years should be increased to 60 hours and the areas of study should definitely be broadened
to include marketing (this is where the unscrupulous can be set back on the right track, especially those who try to push
annuities on the elderly) and practice management (glad you saw the wisdom of this one!).
John A. Macon, CFP ,
SIMC
CE changes ridiculous
Increasing the already robust requirements for the CFP [certification] is unacceptable.
Most firms have in-house requirements that are demanding as well.
®
Even without the in-house requirements, the current CFP [certification] CE requirements
are difficult to complete on time. The regulatory red-tape and bureaucratic
idiocy from Washington is more than we can handle, so leave the current
requirements in place. Increasing the requirement does nothing to further
®
the standing of the CFP [certification] credential, so don not imply that this is a reason
in any further communication(s). Listen to us, we are the ones paying the
fees to sustain the organization.
Michael J. Mannarino,
®
CFP
Increased CE.
Could this possibly be motivate by a desire on your part to sell more CE courses?
Lynn S. Evans, CFP
®
®
Marc Adelman, CFP
®
Marc C. Hadley, CFP
®
®
You are charging more, and doing less. STOP making life more difficult for others. Your current requirements are more
than sufficient.
CE Requirement Change
I am all for maintaining competencies and keeping up to date, but 40 hours is way too many! How about 36 hours, a
20% increase? Keep in mind, you would be taking money from me in two ways: CE fees and lost time serving clients. I
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 124 of 379
Comment
do not support such a large increase.
Marc Genereux, CFP
®
®
My name is Marc Genereux and I am a CFP [certification] License holder.
I have several comments which I will endeavor to keep brief. Please contact me if you have any questions.
Comments by point.
1- I think the expansion to 40 hours is reasonable but somewhat difficult for smaller practitioners to accommodate. I
certainly would not go beyond 40 hours. Accepting appropriate CE hours from other professional organizations would
assist practitioners in meeting this and should be considered.
2- I agree with allowing credit for Practice management and Pro Bono services. I do not currently plan to use these
myself but believe there are many practitioners who would and the Pro Bono hours could help increase the stature of the
®
profession if more CFP [certification] do this.
3- I agree to the increase to 4 hours if the ethics requirement permitted and accepted ethics training classes from other
professional CE programs for other types of licenses.
4- I agree with expanding the other professional activities accepted.
5- I disagree with the 50% cap. There are, as myself for example, practitioners who focus and advise in a particular
area. Mine being taxes. The financial planning aspect I need to present to clients and to best assist them is mostly
related to this area. The middle class and "mass affluent" clients generally do not get or want a full financial plan but
need to pick as their needs and life stages change and their focus changes accordingly. Few people take the longer
term overall view we do encourage and try to plan for. The excuses are the usual. Not enough time, not enough
money, need to worry about the kids or mortgage first and I 'll do that next, etc..
6- I agree with this change
7- I agree the reviewing of course on line should get credit.
8- I agree philosophically with this but the details of HOW to increase and define "rigor" are needed for formulate a more
informed response.
Thanks you for reading and reviewing my comments,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Marc Potter, CFP
Subject
®
Proposed Changes sent
8/17/2012
Page 125 of 379
Comment
I strongly object to ALL BUT TWO of these changes. When I make reference to CFP Certificants throughout this reply, I
will only use the letters CFP or CFP’s.
1. Increasing total CE hours from 30 to 40 every 2 years. This is, in my opinion an unwarranted burden on my time and
no doubt an increased cost to me. This hourly increase is NOT going to make myself or any other CFP a better
professional. Furthermore, CE requirements for other professions you referred to: e.g.; architects, lawyers, etc., have
absolutely no bearing on what is APPROPRIATE for a CFP. If I were an attorney, architect, CPA, or physician, then I
would need to comply with THEIR STANDARDS; IN ADDITION TO THAT OF A CFP.
2. Granting CE credit for practice management and/or pro-bono activities. Practice management activities normally
involve a registration fee (usually paid to the sponsor/presenter, travel expenses, and time away from work. Why should
a sponsor be rewarded for CE credits as well as possible monetary compensation. Finally, pro-bono means “FREE”. I
applaud any CFP who does such work, but he/she/them need not be rewarded by the Board with extra CE credits.
3. Increasing the Ethics requirement from 2 to 4 hours. Ethics really don’t change, regardless of the profession. An
Ethics course within 1 year of certification, followed by a one-time follow-up 5 years later is more than adequate for NEW
certificants. I have been a CFP for going on 31 years. I have had no complaints during this time – check my file. I am
either ethical or not by this time. Passing one or more Ethics courses for you is NOT going to result in my being either
more or less ethical than I am now. I have never been in favor of this ONGOING requirement by the CFP Board as well
as my individual state ever since it was implemented. Doubling this requirement doubles my time, effort, and expense.
This has always been an additional source of income for someone other than myself. No CFP will be twice as ethical by
virtue of you doubling this requirement.
4. I have the exact same objections to this proposal as discussed in Item # 2 above.
5. “50% cap rule”. If the Board wants to ensure compliance re: diversity in this area, then the Board should be
responsible for dictating what courses are necessary for each and every CFP on an individual basis. If you do not trust
us to try and diversify our body of knowledge over the years, then you should be responsible for dictating to us
INDIVIDUALLY what courses should be taken. All CFP’s have to follow the 3-year rule and we all take pains to comply;
sometimes this can get complicated enough as it stands.
6. Eliminating CE credit for completion of professional licenses and designation exams. I am all for this one, 100%.
7. Reviewing on-line courses re: “live vs. self-study”. Again, I am in full agreement wit this one.
8. Increased vigor and quality of all CE delivery methods. I can’t seem to get my head around this one. The rationale
statement says this is to ensure that CE programs contribute to my ( and all CFP’s) professional competency. How can
the Board possible know which programs will contribute to my personal and professional competency unless you review
all our transcripts from day one? I don’t think you are capable or willing do this. If you don’t do so, how can you possibly
ensure increased rigor, quality, and ensure increased professional competency?? You can’t!
9. Increased dues and the big CFP Advertising push/promotion. I haven’t seen any ads in any format anywhere. This
virtual doubling of dues certainly hasn’t helped my business at all. Would you be kind enough to let me know where and
when these ads are running and by what medium?
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 126 of 379
Comment
10. Finally, General CE credits. Currently, I am working under the assumption that you still do not allow carryover credits
from one period to the next. My state allows UNLIMITED carryover of general credits. If a CFP goes to the time effort,
and personal expense that results in more than the required general hours, WHAT MAKES THE CFP BOARD SO
SPECIAL THAT CARRYOVER CREDITS ARE NOT ALLOWED??? I would really like an explanation on this matter.
11. You may publish this if you dare.
Thank you for the opportunity to reply to your poropsals.
Y
®
Marcus E. Darr, CFP ,
EA
Mark Bryant, CFP
®
Mark J. Darrell, CFP
®
®
Response
Most CFP [professionals] have ethics requirements for other credentials. I have state insurance ethics, Variable
annuity Course and Long Term Care training every 2 years and ethics for Enrolled Agent 2 CEs a year. I glad I am
®
retiring because it is clear from these new proposed requirements that CFP [professionals] are morally bankrupt.
CE
I believe the increase in CE will be good for the profession. I do think the lobbying effort of the FPA are poor in letting
congress knows the importance of veteran planners and the roll they need to play in society, maybe this will help?
BAD IDEA
As a practicing CFP [professional] for over 25 years, I am very much against the proposed changes to the CE
requirements.
®
®
It seems that the Board continues to get further and further out of touch with practicing CFP [professionals]. (Especially,
the successful ones!)
Whether the CE requirement is 30 hours, 40 hours, or 100 hours, it will have little effect on my “competency” or “ability to
serve” my clients.
®
CFP [professionals] advisors are already stressed with finding enough hours in the day to do their job. We all “learn as
we go”. We do this in the “real world”, not the vanilla “cookie cutter” world of Approved CE Courses. (Which in most
cases are just glorified “commercials” for the CE providers.) That is how we survive and grow.
I do not need a bureaucratic Board forcing me to sign up, pay for, and manage my continuing education to any further
degree. You talk about the importance of “practice management”, so we can run our businesses more efficiently ….
Here’s an idea … stop forcing me to spend more time learning things I already know just to satisfy your rules! Do you
really think that increasing the Ethics CE requirement is going to change the behavior of unethical advisors? And why
should ethical advisors be required to continue to take these ridiculous courses year after year?
I need to cool off!
Sorry for the rant. But this really upsets me. (If you can’t tell)
®
It’s all just another “tax” on my practice. At least I have the option to leave the CFP [certification] program and not pay
this tax.
Maybe that’s just what I will do!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Mark Engberg, CFP
®
Cont. Ed. - CFP
Page 127 of 379
Comment
I believe this is creating additional complexity. Too many moving parts, too many traps and pitfalls. Keep it simple.
What I would like to see is the CFP Board offer a mandatory 2 or 3 day refresher class every 2 year cycle. This would
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have to be offered regionally throughout the US and at a cost to the CFP [professional] designees. They would most
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likely incur transportation and lodging costs as well as the program cost. The class would take CFP professionals back
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through the fundamental CFP [certification] components and touch on new topics. We are all rusty after the
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preparation for CFP exam and need to stay on top of the materials. Use it or lose it. No one offers such a program.
You could create vendors around the US to facilitate this.
Thank you
®
Mark A. Gash, CFP ,
JD
®
Mark E Johnson, CFP ,
ChFC, FIC
Continuing Education
Requirement
The current continuing education requirement is, I believe, quite sufficient. The suggested changes to the requirement
places an unnecessary, additional burden on practitioners in terms of time, complexity and expense. We are already
overregulated and these proposed changes serve to make that situation worse. It would have been preferable, and
more appropriate, to canvass practitioners on this "issue" prior to drafting proposed changes, not after-the-fact.
Proposed CE changes
With respect to the board, following are my comments for consideration regarding the proposed CE rules changes.
a. I am a firm believer in education and staying on top of our rapidly changing world.
®
b. I will need to travel to find CFP [certification] CE credits in excess of the current requirement of 30. I served as
®
president of the local chapter of SFSP and remain active on the board. This is currently my sole provider of CFP
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[certification] CE credit. I attend all meetings, the programming is quite varied, but coming up with more than 30 CFP
[certification] approved credits every two years will be a challenge. I could join the local FPA chapter, however their
focus seems to be very much on asset management rather than running a well-balanced planning practice that includes
various insurances. Most organizations do offer weekends where additional CE can be obtained. This however requires
significant travel and expense. I question the value.
c. Perhaps the CFP board would consider “other” CE licensed individuals attain, such as firm element and state CE.
Please understand these other requirements also take us away from our time in the business, but do provide
educational value. These requirements are typically more regulatory in nature which is also something important for the
®
CFP professional to be well versed in.
d. I can respect the rule regarding the 50% cap. However, in today’s highly complex world, we cannot possibly know
everything. I would encourage the CFP board to promote specialization. For example, I specialize in Retirement
planning. I have little use for, or interest in college planning. I prefer to focus on doing what I do, doing it well, and
referring college planning needs to someone who specializes in that. Doing so elevates me as a professional.
e. Ethics: I think the two hours of ethics CE is a good idea, but isn’t executed well. I’m not opposed to 4 hours, but
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please encourage it to be relevant and meaningful content. It is very difficult to find CFP [certification] approved courses
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on ethics. The course I took this year was largely ineffective. It focused on CFP [certification] rules, which I understand
the importance of, but rather than being a practical view, I found the course to be very picky on words and definitions,
much like a high school exam where information is regurgitated after being memorized, and nothing practical is gained.
Again, I think this element is important, but has room for improvement.
f. Expanding to accept practice management courses as CE is HUGE! Thank you for that consideration.
g. Elimination of CE for designation exams? WHY? It’s those
courses that we’re building our education reputation on. I can’t understand why those same courses would fail to qualify
for CE.
h. Encouraging increased rigor of CE programs? We see where that methodology has gotten the Department of
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 128 of 379
Comment
Education. I learn the most when I am able to listen to a presentation from a well-qualified expert, then participating in
Q&A. The presentations I learn the most from are usually considerably “unstructured” allowing for a great deal of
participation during the presentation.
i. Allowing for On-line and “live” programs to qualify. Yes, thank you. But as for testing, see (h).
Thanks for reading.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Mark S. Wishka, CFP
Subject
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proposed CE requirements
Page 129 of 379
Comment
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After reviewing the proposed increase in CE requirements of the CFP [certification] designation, my initial reaction is:
This is NUTS!
To encapsulate what is being proposed: Increasing the amount of CE credits by 1/3, doubling the amount of ethics,
limiting the number of hours of specific study to ½ of the total requirement, eliminating the ability of applying course
material from another professional designation from consideration for CE credit, limiting self-study courses and
substituting “live” courses.
Though this should not be necessary to point out: Consider the amount of CE, FINRA and other various state
requirements which have increased exponentially over the past decade (not to mention the company requirements
which are over and above those). Tracking all of these requirements requires a part time staff person (this is not an
exaggeration)!
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The dramatic expanse of increased requirements you wish to implement will certainly impact the number of CFP
[certification] designates who wish to obtain the status and continue it. If you are looking for a way to limit the use of
your trade mark, I think you’ve put together a great proposal.
I have been committed to increasing my knowledge base throughout my 18 year career path by achieving additional
profession designations (I will have 6 by the end of this year). My company is specific on which are recognized, so my
focus has not been on the latest run of the mill set of letters behind my name, but those which are standards in the
industry, bring value to me and my clients. The ability of utilizing a self-study program as well as using the credits from
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those designations to fulfill my CE requirements for the CFP [certification] has been a key driver in my continued
education.
Requiring each course to only fulfill a maximum of 50% of the requirement ensures not only time to take an additional
course, but an added expense as well! Have you looked at what course cost though one of the on-line colleges lately?
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Check it out and then add a couple of those to the cost of renewing the CFP [certification] designation.
The proposal for a “live” class is for me, a deal killer. There is no way an individual can complete a presentation which
would convey the amount of information necessary in as brief a period as I can read and complete a course. My time
and attention are needed to provide excellent advice to my clients, not spent in a class room trying to stay awake or
watching a painfully slow webinar. Either option is an absolute waste of my time!
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Consider this in regard to the audience you are working with: You are aware that to achieve the CFP [certification] you
need not only years in the business, but complete the rigorous course material and comprehensive exam. Do you think
individuals of this caliber need an instructor to hold their hand though a CE course? These are people whose
experience allows them to adapt current knowledge to new concepts. Making connections is what we are trained to do
by necessity to remain viable in this ever changing business. AND you want to GRADE us?
I see no benefit to me personally by the increased requirements and feel them to be an onerous increase in the hoops to
jump through to maintain the designation.
Are there other advisors who have “scamming the system” and aren’t meeting the guidelines as you wish? Maybe. If
that is the case, look at tightening up the current process, not instituting draconian measures which alienate the
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professional advisors you wish to promote the concepts of a CFP [certification].
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 130 of 379
Subject
Mark C. Spooner, CFP
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Disapproved
Comment
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I have read the proposed increases in the CFP [certification] CE requirements. I do not agree with much of what is
being recommended.
I believe the board is overlooking the fact that there are only so many hours in the day and that in order to help as many
people as possible and put together detailed plans we cannot be diverted any more by the tedious CE requirements any
more than we are at this point.
Furthermore, it is beginning to be somewhat insulting with all this ethics courses. Now you want to increase them…as if
that is going to keep the foxes out of the hen house. The public would be better served by stronger sanctions against
those that violate the public trust.
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Finally, at close to $400 bi-annually plus the existing CFP [certification] CE requirements and now with the threatened
increase I am close to not continuing with it at all.
Mark D. Wickman,
®
CFP
Comments
I don’t think this is a good idea. We already spend a lot of money attending conferences, paying dues and most of it,
quite frankly, in my humble opinion, is so that we can say we are doing these things and look good to regulatory bodies
that are suspicious more than supportive of the efforts members put toward serving their clients and the general public.
Conferences provide good ideas. Many of the best ideas come from networking with colleagues. Why not make that a
requirement? So that I don’t get too narrow in my own little corner of the world, offer CE and require some CE hours be
dialoguing with colleagues.
Ethics courses, quite frankly, are some of the poorest classes I’ve attended. They are of a tone that we are the bad guys
and if we practice long enough we will all lose our certification. I don’t think that is the intent. A fundamental question
remains: Can ethics be “taught”? I’m not sure. Ethics must be lived. Sitting in on classes analyzing “where a certificant
went wrong” won’t help us live out ethics.
If our aim through CE is truly to render better service to our clients and the general public, train some certificants to do
peer reviews and then require some sort of membership in peer groups that review each others’ methodologies and
practices. This will enhance our skills and our ability to better serve.
Thank you for soliciting input.
Best Regards,
®
Mark H. Heller, CLU ,
®
CPC, CFP
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Under the "50% Cap rule" you list "Topics" to include "Retirement and Estate Planning"
If that is meant to be two separate topics, that would be fine. If however you are combining them as one topic, I would
take exception. I think they are two very separate topics and to have more than 10 hours of CE in each would NOT be
unlikely for my practice.
Thanks
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Marshall Sitarik, CFP
®
Proposed CE Changes
Page 131 of 379
Comment
I believe these proposed CE changes to be entirely misguided. The thought comes to mind of a bureaucrat in an office
who does not have the day-to-day challenges of running a financial planning practice in the toughest financial climate in
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the history of the United States saying to himself: "I know lets impose an additional CE burden on our CFP
[professionals] to justify our own jobs." What utter and absolute nonsense!
I believe that the Board’s proposed CE revisions are consistent with best practices with the following exceptions:
Gennaro A. Marsico,
®
®
CFP , CIMA
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule."
Rationale: Ensure diversity of learning experiences across breadth of planning topics.
I believe this is not a good change for the following reasons: (1) It would be an onerous task to try and find courses that
fit into the required subjects needed for CE. It is already difficult scheduling courses to fulfill the Ethic requirement, let
alone having to search out courses to meet each subject matter according to the appropriate percentage. (2) Many of
us certificants are also licensed in other professions or hold designations for which we need to complete CE. Placing
additional requirements on the courses we can take will place an undue burden on us to fulfill our requirements in a
timely manner. (3) Professions such a law, etc. allow the licensed individual to choose courses in the areas they
practice in or wish to gain knowledge. For example, legal CE would never require a tax attorney to take CE in criminal
law (even though they originally needed criminal law to pass the Bar exam and become licensed), so the planning
profession should respect the planner’s area of specialization and interest to take CE where they believe it will most
benefit their clients.
Respectfully Submitted,
Martin Knight, MBA,
®
CFP
®
Rick L. Martini, CFP ,
®
CRPC
The Ethic's portion
increased from 2 to 4 hours
Disagree that this is necessary. Each year I need to take ethics courses for my Life Insurance and Reg-ed. Each and
every course I have ever taken in this subject has been lame and totally irrelevant to my work. Increasing this
requirement might sound impressive but it does nothing to further the ethical conduct of our members!
CE Hours
I understand your desire to distinguish and build on the respect of the CFP mark but I think that requiring more hours of
CE credit will not create the desired result. Continue to promote the mark but don’t burden current holders with more
hours spent clicking a computer screen in order to earn the needed credits. I am currently accountable to the SEC,
FINRA, Insurance regulators, not to mention my own firm with ongoing CE requirements. When will the madness stop?
Shouldn’t I be spending this time with clients versus the same old study lessons?
Rick
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Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Marty A. Phillips,
®
CFP
Subject
Page 132 of 379
Comment
The proposed changes under consideration are: MY comments are in blue. Thanks!
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations. The proposed increase in required hours is consistent with
recommendations from CFP Board’s 2007 and 2008 Education Task Forces.
Ø AGREE
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
o Practice management CE programs. Defined as programs focused on the planning, development and management of
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a CFP professional’s business operations, office management, business model design, budgeting processes and
leadership.
o Pro Bono (volunteer personal delivery of financial planning) services. These activities must be supervised by a
registered CE Sponsor organization and will be accepted for 1 hour CE credit per 4 hours pro bono service.
Rationale: Recognize the importance practice management plays in the delivery of competent and ethical professional
financial planning services to clients. Encourage pro bono service for the public benefit.
Ø AGREE – This will be difficult to monitor and report properly, but I don’t see a downside.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.
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• DISAGREE – I feel that the CFP [certification] designation in itself shows a commitment to ethics and higher
betterment for the client. Maybe I’m shortsighted here, but I feel I’m practicing ethics each day with my work and
interaction with clients.
• Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following:
o Participation in Registered Program Financial Planning Development ("capstone") course grading panels. These
activities must be verified with documentation of active participation, written assessments and qualitative feedback;
o Study Group Activities that meet certain guidelines;
o Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
Rationale: Encourage body of knowledge expansion and no cost CE opportunities.
AGREE
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule."
Rationale: Ensure diversity of learning experiences across breadth of planning topics.
• AGREE
• Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 133 of 379
Comment
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
Rationale: Recognize the quality control measures that regionally accredited institutions are required to incorporate in
the development and delivery of self-study courses offered for academic credit.
• DISAGREE – not sure I fully understand this. However, I would stress that many of us have a practice that requires a
great deal of time and effort. I enjoy and strive to participate in “live” programs, but sometimes I complete CE on a self
study basis.
•
• Encouraging increased rigor and quality of all CE program delivery methods.
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Rationale: Help ensure that CE programs available to CFP professionals contribute to their professional competency.
• AGREE
Mary M. Hastings,
®
®
CFP , AAMS
Continuing Education
Requirement
Requiring additional credits is very acceptable to me, however, I also feel strongly that credits in excess of the
requirement should be allowed to be carried forward.
®
®
In addition, if one feels a CFP Certificant is not keeping current with their continuing education credits a verbal to CFP
should be adequate vs. putting it in writing with one's name. This in some situations can cause a certificant not to report
such knowledge due to known repercussions they would incur.
Thank you.
®
Mary S. Brock, CFP
Changes in CE
requirements
Please accept my comments about the proposed changes in the CE requirements.
As a RTRP (Registered Tax Return Preparer) I am currently required to complete 15 hours CE each year, 2 hr. of which
are Ethics -- that's 30 hours each two year period, including 4 hrs. Ethics. This is not recognized by the CFP board.
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Why? I have no idea. I checked all CE providers of the CFP [certification] and none would provide the needed credit for
my RTRP.
If the board goes ahead with the increased CE needed, it will mean that I and other tax preparers will be required to
have a total of 70 hours ever two years, including 8 hours Ethics (40 hours CFP, 30 hours RTRP, including 4 hours CFP
®
and 4 hours RTRP). So what should we do as CFP [professionals]? Give up our practices in order to produce the CE
credits?
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I also think the 50% rule should not be implimented. If a CFP [professional] spends most of its time in Estate Planning,
Tax Planning, etc. then why not emphasize those areas, as opposed to studying that which is unrelated to his or her
practice.
Mary S. LaMoreaux,
®
CFP
CPE requirement
Having the CPA license, I am required to take 80 hours of CPE per year, most of which are required to be in accounting
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and auditing. I am also required to take hours for my insurance licenses. These hours don't always apply to the CFP
[certification] license. Therefore I am currently taking about 120 hours of CPE every 2 years. Now you want to increase
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those hours for the CFP [certification]. I am also required to take ethics for each license so I am taking about 5
different ethics courses. In my opinion all these hours are more about getting more money from the licensee than about
teaching.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Matt Roper, CFP
Subject
®
Matt Veenker, CFP
®
Page 134 of 379
Comment
CE Comment
I really see no need or reason to make any changes to the CE requirement. Advisors are so busy to begin with, taking
additional CE courses just adds one more thing on an already heavy load. I really do not think adding additional credit
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hours and/or ethics will improve a CFP [professional's] knowledge or ethics. Also, self-study is much better than a live
course given the flexibility self-study offers. Also, I really don’t want to pay for any more CE credits given the costs to do
business already (securities license, certifications, B & O taxes, self-employment taxes, registrations, health insurance,
E&O insurance, etc.). Please do not make any changes to the CE courses.
CE proposal
I agree with the "more is better" philosophy, but I hope the CFP board can build flexibility into the system to accept
"Multiple CE" programs, where CE can be granted for multiple licenses or certifications.
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I am a CFA charterholder and CFP certficant with FINRA Series 7 and 66 licenses and Life and Health Insurance
licenses. There needs to be some sort of coordination so that when I take a CE for my insurance licenses, that can also
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be applied to my CFP [certification]. Or if I take a FINRA CE for my security licenses, it should also be applicable to
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the CFP [certification] or CFA CE.
Advisors absolutely need to be on top of changes in the industry. But when a topic is studied that applies to more than
one CE program, it needs to be credited to both. I don't think we are quite there yet as an industry.
Matthew Gelfand, CFP
®
Response to Request for
Comment: Proposed
Revisions to CFP Board's
Continuing Education
Requirement
The CFP Board's Continuing Education Requirements has been crying out for revision and update for a long time. At
®
present, it is a watered-down requirement that calls for relatively little educational advancement. Given that all CFP
certificants must have passed a rigorous exam to earn their certificates, have earned college degrees and fulfilled
experiential requirements, the level of activities that pass for "continuing education" is rather minimal in quality, but
appropriate in quantity. Attending seminars and taking multiple choice tests that cover self-study materials that are
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beneath the rigor of the CFP certification program itself hardly qualify as continuing "education" but rather represent
"refresher" information.
That said, if no rigor is added to the quality of educational requirements then there is no point in adding to the quantity of
hours required; doing so would just add to the "busy work" that practicing professionals must add to their very hectic
lives. And if that is all that is to change, I would be opposed to the new proposals.
In particular, the current two hour ethics requirement seems to be nothing more than a ritualistic recitation of standards
of practice, requiring certificants to sit in a room and listen to the same material repeated year-in and year-out. I have
been a certificant since 2005 and now have had to sit through three CFP-Board sanctioned 2-hour sessions, none of
which added any new information to my knowledge base. I could have read the identical material on my own in about
15 minutes, but needed to take a half day out of a busy schedule to travel to and attend these sessions. I am opposed
to retaining the mandatory attendance at these or similar on-line sessions and would favor eliminating them.
I would highly recommend that you review the the CFA Institute's continuing education program, which allows
charterholders to engage in self-study programs of their own choosing, metering the level of content based on what
would be challenging for each of them individually, including two hours annually of a wide variety of ethics materials that
genuinely add to previously acquired knowledge.
As for the specific points in the proposal, I comment on each below in turn.
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 135 of 379
Comment
Comment: Opposed (substituting quantity for quality. 15 hours per year / 30 hours per 2-year cycle is plenty.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
Comment: Agreed -- reasonably expands the variety of activities eligible for CE credits.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
Comment: Opposed to increasing the number of hours -- just adds quantity rather than quality. 15 hours per year / 30
hours per 2-year cycle is plenty.
Comment: In favor of allowing a wider variety of activities to meet the Ethics CE requirement, including allowing these
new activities to substitute for the mandatory 2-hour Ethics program, which as stated earlier is a mindless, recitation of
rules and requirements and a waste of time.
• Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship)...
Comment: In favor of expanding the variety of activities that meet CE requirements, so long as these activities are of
substance.
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours.
Comment: In favor of this reasonable "breadth" requirement.
• Eliminating CE credit for completing professional licenses and designation examinations.
Comment: In favor of this change; many other professional licenses and designations are beneath the quality and rigor
®
of the CFP [certification] credential. It's an alphabet soup out there.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
Comment: This proposal is unclear, so I cannot opine. Does the proposal imply that self-study programs would be
eliminated in favor of academic credit programs? If so, I am opposed to such a restrictive change. If the academic
credit courses are an expansion of eligible activities, then I am in favor, so long as the course subjects are relevant to
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the CFP [certification] program and go beyond the basic knowledge required in the program -- e.g. no CE credit for
repeating "101" level college courses.
.
• Encouraging increased rigor and quality of all CE program delivery methods.
Comment: Agreed about rigor and quality, but not about increasing quantity for its own sake.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 136 of 379
Subject
Maureen McKay, CFP
®
CPE problem
Comment
All the recommendations seem reasonable to me. However, I strongly encourage the following recommendation.
For the past 30 years I have been practicing as a CPA and during all those years have been required to obtain 40 hours
CPE each year.
®
®
For the past 10 years I have practiced as a CFP [professional]. For some reason it is difficult for CFP [certification] to
accept the income tax, estate planning and retirement planning hours earned thru popular providers of CPE to CPA’s –
such as AICPA, State Society of CPA’s and John Surgent & Associates. Can you please explain why??
2012 to date I have earned 70 hours in income tax, estate planning, retirement planning thru John Surgent & Associates
®
live webinars and I don’t think those hours will count toward my CFP [certification]. It’s almost encouraging me to drop
the designation.
®
Tommy McBride, CFP ,
CIMAR, CPWAR
Comments
I do not see a reason to increase the CE requirement from 30 hours to 40 hours just for the sake of doing it. Most
practioners have to stay current on issues to run their practice. Also, most practioners have to complete CE for more
than one designation or insurance license.
®
Along the same lines, there is no need to increase the Ethics requirement from 2 to 4 hours and create “CFP
[certification] Ethics”. People are ethical or they are not.
Practioners should have the time to serve their clients, not continue to increase the administrative burden.
®
Scott McDuffie, CFP ,
®
CPWA
CFP Board's CE
Requirement: My Vote is
"Yes"
I agree with and support the amended CE requirements as were summarized and recommended in your email dated
8/17/2012. Increasing from 30-40 CE hours is not that difficult to achieve and, in theory, the additional education should
provide a platform for increased knowledge and skill as a practitioner.
I do believe, however, it is worthwhile to integrate additional (outside / 3rd party) professional designations as qualifiers
®
for CE credits. In my humble opinion, we are fairly egocentric and ignorant if we believe that the CFP [certification]
designation is the end all / be all of financial planning. There are plenty of additional designations / programs worthy of
the Board’s consideration for allowing those programs, and the related content being taught, to qualify for Board CE
credits. Perhaps, the way to do so is to perform due diligence on the various programs to ensure competency and
qualification for the Board’s CE mandates.
®
To be sure, I am a very proud CFP practitioner! However, at the end of the day, from my perspective, we as
practitioners want to make sure that we are competent, up to date on current topics, qualified for the job at hand, highly
ethical and focused on providing the best experience to our clients that is possible. Partnering with other worthy
organizations does nothing but enhance practitioners and their skills on an individual basis and, as a result, enhances
the industry as a whole.
Please accept my vote of “Yes” on the proposed increase in mandatory CE hours and related structures / proposals. I
vote “No” on disallowing outside / 3rd designations to qualify as Board CE credits unless the content being taught is
proven to be unworthy of qualifying for said CE credits.
®
Have a great weekend and thank you for your continued work and promotion of the CFP mark.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Eugene M. McGuire, Jr.,
®
CFP
Please Contact Me
Page 137 of 379
Comment
®
It seems as if everyone always wants to raise the bar. I am overwhelmed in my job by CFP [certification] CE Credits,
Insurance CE credits, FINRA CE course hours, SEC Course hours, Bank Of America CE course hours, Managed
Futures CE hours, Series 7 CE review . Something has to give. This is overwhelming. I have no more time to run my
business and service my clients. The industry has to get together and narrow this down. I should be able to go to a
review class for 1 or worst case 2 days a year and accomplish all this. Has anyone ever added up all the hours of review
courses that need to be done for all these different organizations. Has anyone tried to allow for credit sharing.
®
Please call me so we can talk about this. I might have to drop my CFP [certification] designation because all the
different CE reviews requirements is overwhelming. The bad apples who ruin it for everyone keep doing bad things and
the good guys in our business keep paying the price! All the CE credits in the world are not going to change the behavior
of bad people doing bad things.
®
Duncan McRae, CFP ,
CDFA, AAMS, CMFC
Mel Severance, CFP
®
CE
In my opinion the hours that are currently required and the information that is accepted is fine the way it stands now.
Some of us have other desigtnations that require CE that is not acceptable to the CFP board and are already spending
more hours on education that gives us an even broader scope in helping clients.
Ce credits
This would appear to be a self serving revenue enhancement. Further, you are supporting colleges in the provision of
credits. I think the current system and requirements are fine
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Melody Bundschuh,
®
CFP
Subject
CE requirements
Page 138 of 379
Comment
I do not agree with increasing the total CE hours required. Our broker dealers require so much training, it is overload.
Between regular periodical reading, b/d training, due diligence meetings, wholesaler meetings, webinars…we are getting
educated from multiple sources.
For a similar reason, I do not agree with implementing a 50% cap rule as we get so much information and training in
multiple areas, is it really necessary to require our CE to be diversified? And our practices all vary in focus, so can we
be self disciplined to seek training in areas where we would benefit? Versus a variety of areas which may or may not
apply.
Also, I do not agree with increasing the ethics requirement. It is also delivered from our broker/dealers. Plus, is an
understanding we should all have.
®
Is it possible to have some of the other state and b/d training also credit for CFP [certification] CE?
Thanks so much,
Jeannine E. Merrill,
®
CFP
Increasing required CE
hours
®
The proposed increased in CE hours is not necessary. You will deter future CFP [certificant] candidates from acquiring
®
a CFP [certification] because of the arduous requirements. As you stated, “Personal financial planning knowledge and
practices are fast-changing, which requires ongoing learning to maintain competency”. We are working additional hours
because of the new requirements.
®
I personally feel that this is just too much to ask of CFP professionals especially when our industry is changing so
rapidly. We are facing many headwinds right now – fiscal cliff, Europe, etc. This decision is not timely.
Please reconsider.
Best Regards,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Michael Arnold, CFP ,
MBA
Revisions to CFP and CE
program
Page 139 of 379
Comment
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I urge the board to be careful how much you are changing the CFP [certification] program. I know of several other
®
CFP [certification] holders that are considering dropping their designation for several reasons:
1) Drastic fee increases.
®
2) Why would, we advisors, subject to ourselves to more oversight and possible suspension of our CFP [certification]
designation if an advisor were to have an issue with a client? Your designation is OPTIONAL, to myself and other
designation holders.
3) Your designation is valuable but it can reach a point of diminishing returns. Adding in extra CE hours and other
renewal requirements increases the amount of time advisors have to spend on renewal. Our time is already being
assaulted by endless new regulations. Your position should be to help advisors SAVE TIME and get the valuable
continuing education we need, not create more hourly requirements.
a. Additional CE requirements will also increase cost adding additional expense to point number 1.
I fully believe and practice doing the right thing for people.
®
But I think “credentialing up” with the CFP [certification] and other designations will not directly impact people hiring
®
experienced (without a CFP [certification]) financial advisors that have been around the block and who clients and
prospects feel they can trust with their money.
Respectfully submitted,
Michael Goldstein,
®
CFP
Comments on proposed
CE changes
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming
These two proposed changes will do nothing but increase the cost of maintaining a licenses. Most responsible
professionals do sufficient learning to keep up with the requirements of keeping their skills current. Large portion of this
learning comes from reading and other self study. Adding additional 10 hrs of “qualified” CE will just add additional cost
to each member, without doing anything substantive in improving skills. If ethics is such a concern and you think that just
doubling required hours will make members twice as ethical, why not increase it 10 times, so we all become 10 times as
ethical.
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours
Nonsense. We are supposed to be professionals and adults, what topics I take to help me stay current in my area of
work should be left up to my discretion.
• Encouraging increased rigor and quality of all CE program delivery methods
Are you saying that the current programs we take are not “good enough”. This sounds to me like a covert attempt to
restrict CE courses to only courses from “pre-approved” vendors. You already charging me extra money for courses that
are not electronically submitted to you. I guess more money is needed.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 140 of 379
Comment
If all these proposals are passed, I will seriously consider not renewing my membership.
Michael Johns, CFP
®
Michael L. Kalscheur,
®
CFP
RE: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Incresing the number of total and ethics hours is not the answer to this perceived problem.
CE Proposed Changes
make sense
Thank you for taking the time and effort to review the CE requirements. The proposed changes are both beneficial and
timely, and I appreciate the “rationale” explanations. Other changes could be made, but I have no objections to these
proposals.
Take care and God Bless,
Michael J. Vela CLU,
®
ChFC, CFP
Robert P. Pitner, CFP
®
®
Increasing CE requirement
hours
I can certainly understand the rationale behind the idea to increase CE hours for the CFP [certification] designation,
however, please consider the additional burden of CE requirements that many practicioners already have for other
government related regulatory bodies such as FINRA and Insurance Dept(s).
In my opinion, there is just too much regulation period. I am not in favor of the proposal.
CFP changes
If and when these changes are implemented, I will drop my membership. The “marks” are not worth the hassle.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Gordon J. Morris, CFP
Subject
®
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Page 141 of 379
Comment
I cannot believe that the Board, some of whom do not have to complete CE credits, want to increase the required
®
®
number of hours of CE credits. Not only do most CFP [professionals] have to fulfill the CFP [certification] CE credits
but also most are licensed by states in life insurance with their CE requirements and FINRA requirements in addition to
their BD continuing education. You are now asking me to spend a business week doing nothing more than CEs. All in
all as it is now stands I have to spend at least two weeks every year doing CEs.
Instead of increasing the number of hours, improve the quality of the education and areas it is needed. If it 10 hrs. of
ethics or 20 hrs. of estate planning so be it, but make it worth while, not more time but better time spent.
Dustin R. Granger,
®
CFP
Comments
I don't understand how increasing our fees and continuing education will help us. Just because you make what is
already tough to get into and maintain even tougher doesn't make what we have more valuable.
When will this end? I'm starting to question whether it matters to keep the designation. The fact is most people don't
know how valuable it is and don't care to hear a presentation on it. Why would they?
®
I will be okay with all of this if the CFP board will demonstrate how they will keep the CFP [certification] value growing.
Thanks,
Joe Starr, CFP
®
CFP Board Proposed
Revisions to CE
I read your rationale, but is this really necessary? Many like me in their 60’s have been following the rules and paying
®
our fees forever. If your objective (rationale) is to reduce the number of individuals using the CFP [certification]
designation—you will succeed. I work for a non-profit as do many other designees. The financial burden to maintain our
designation is becoming excessive. Especially note the Ethics requirement from 2 to 4 hours with “Board-produced”
program. 30 hours of CE is bad and 40 is now punitive. It appears the Board is justifying its existence and insistence to
increase funding with these additional requirements. This is not all that different from an administration increasing taxes
and regulations seeking more funding only to see tax revenues decrease. This is an dis-incentive for current designees
and future.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Michael D. Whitty, CFP
®
Fwd: Request for
Comment: Proposed
Revisions to CFP
Board'sContinuing
Education Requirement
Page 142 of 379
Comment
To the CFP Board,
I am in favor of all the proposed CE changes, with one possible exception. With regard to the Ethics proposal:
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.
... I strongly recommend that this proposal only be implemented if the specific, mandatory CFP Board-Produced Ethics
program is available online. It's not hard to get CE in general, but it can be hard to find the right CE Ethics course that's
a good fit by time, location, and subject matter. If the CFP Board will make one additional specific program mandatory,
there needs to be an online option. (Making the same program available for a live presentation at conferences would
provide additional options.)
I have one additional suggestion:
• Allowing CE credit earned in the final 30 days of a certificant's CE reporting period to be carried forward to the next
period if not needed for that period. Rationale: There is already a 30 day "grace period" after the reporting period; this
30 day "carry forward" period would be a mirror image of that. The "carry forward" period would reduce a current
disincentive that certificants face in signing up for an otherwise valuable CE program because it fell on the wrong side of
the reporting period deadline.
Thanks for the opportunity to comment,
Michael A. Binz, CFP
®
The requirements are stringent enough and consume considerable time and effort in my practice as is.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Michael Botwinick,
®
CFP
Subject
Increase of CE hours from
30-40 hrs
Page 143 of 379
Comment
®
I have read the proposals regarding the increase of hours required to maintain the CFP [certification] designation and
completely disagree.
®
As an independent financial advisor for over 30 years and a CFP [professional] since 1989 I believe this idea to be
detrimental to the furtherance of the designation. Advisors are in constant scrutiny by politically driven legistlation, rising
FINRA, SEC, CFP, and IRS fees and taxes. We already have an increased educational environment including antimoney Laudering, security protection, compliance 101, 201, additional training to sell REITS, alternative investments,
structured products, municipal securities, 529 plans, long term care, working with seniors, and many other required
training. What makes this even harder to digest is the fact that the CFP Board won't accept allot of these required
training exercises. They are good enough for state insurance departments, SEC, FINRA, and the broker dealer that
®
many advisors work for but not CFP [certification].
Most of advisors learnings are procured through on job experience, broker dealer conferences, and investment company
due diligence meetings, most of which don't provide CE credits. Many of the so called CE credit approved courses
provide very little educational or work related value and are taken just for the sake of meeting arbitrary CE hours
requirements.
Most advisors work very hard to earn a living and provide quality service to their clients and are not looking for a PhD in
the abstract formulas of standard deviation and logarithms of probability of reaching goals. Our clients want real answers
from advisors who break information down to a level they can easily understand.
I was recently asked in a survey about the successes and short comings of the FPA. My responses were the same as
®
above. Is it the desire of the board to serve a self centered purpose of raising the bar to keep new CFP [certificants]
out, justifing their own self centered academic superiority, or is it for the betterment of the public and the advisors who
serve them?
®
Rather than making the apperance to the politians that the CFP [certification] is elevating the requirements if its
advisors, focus on going to Washington and fighting for our rights as hard working, highly trained professionals.
Respectfully Submitted,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 144 of 379
Subject
®
Michael R. Smith, CFP
Proposed changes to CFP
continuing Education
Comment
I know that your time is valuable, so I will make my points brief.
®
1. After the outrageous 80% fee hike, the cost of the annual fee for carrying the CFP certification for me until retirement
is now $46,998.94. (Future value based on a modest 6% interest per year, working until age 70).
®
2. The new continuing education increase will bring my continuing Ed (just for the CFP certification) to 20 hours per
year. Assuming a very modest rate of $30/hour that I could have produced working for my firm and my clients, that lost
time opportunity cost is $600 this year. The future value of that time until retirement is $87,035.07. (Again, Future value
based on a modest figure of 6% interest, $30/hr, working until age 70. This is also assuming the classes are all free,
which they most certainly are not.)
I already complete dozens of hours of continuing education for my firm and various licenses and certifications each year.
®
None of this is counted toward my CFP certification requirement. Nearly 100% of the education overlaps. Not counting
perfectly acceptable continuing education components from legitimate organizations (Like Wells Fargo Advisors, and
FINRA) simply doesn’t make sense.
It seems like a second money grab to sell additional continuing education classes to a captive and inelastic consumer.
What can I learn in 4 hours of ethics CE that I couldn't learn in 2?
®
When I look at the true cost of carrying the CFP [certification] designation until retirement, $134,034.01, my demand
doesn't fee so inelastic. I am deeply disappointed in the CFP board's decisions. It is my sincere hope that they reverse
the proposed increase in continuing ed, then realize that it's members overwhelmingly do not care about a new 5 year
branding campaign, and reverse the unheard of 80% fee hike heaped onto the backs of its hard working members to
pay for it.
We are the branding. We uphold the ideals, learned well from the criteria, and are a credit to the brand. Stop trying to
drive us away from it.
$134,034.01. If the board doesn't reverse course, I will most likely be forced to drop my certification.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Mike DiMayo, CFP
Subject
®
comments - proposed
revisions to continuing
education requirements
Page 145 of 379
Comment
Long-time member, earned my CFP designation in the mid – to late 80’s. I rarely, if ever, take time out of my schedule
to respond to this type of request. However, I will make an exception in this case due to my strong feelings on the
matter.
The Council recommendations are, in my opinion, far overreaching and go well beyond any sensible interpretation of
reasonable. Putting together a Council on Education to review CE requirements is like asking a manufacturer of
hammers to conduct a study on nails are being used – everything will come out looking like a nail. With all due respect,
of course “members of board-registered programs and the academic community, and representatives from other
professional certification programs” will look for ways to increase compliance and CE requirements – that’s what they
do. Does anyone really think that the Council will come back with a recommendation to reduce or eliminate
requirements, or even a no-change position?
Increasing the Ethics requirement from 2 to 4 hours – are they serious? Implementing a 50% cap rule – really? So it’s
®
more beneficial for CFP [certification] members to have broad based additional training in areas they may not even
work with clients on, versus in-depth training in areas they can actually use? Is that helping our clients get better
advice? Encouraging increased rigor and quality? One would assume they are doing that on a continuous basis
already. Give us a break – your members may view this initiative as just additional, unnecessary busy work on the part
of the organization. At some point, the weight of ever-increasing organizational initiatives by the CFP Board could be
compared with the ever-increasing burden and cost of meeting governmental regulatory changes. The difference is, of
course, that we all have no choice in complying with governmental legislative and regulatory changes; while
membership does have the ability to exercise free will and drop out of the system.
Message – the proposed revisions should not be implemented and appear to go too far. You may feel free to contact
me directly and I would be willing to discuss my feelings on this matter in greater detail, as it is quite important.
Michael Gorman, CFP
®
CE Changes
As a member of NAPFA, we are required to complete 60 hours of CE every two years in a variety of disciplines.
I am in favor of all the proposed changes.
®
This will strengthen the CFP [certification] brand by improving the knowledge base of certificants.
®
Proposed revisions to CFP
CE
I vote against the proposed changes. In today’s world, where most of us possess numerous licenses and designations,
®
adding 10 more CFP [certification] CE hours might not sound like a lot but considering all of the hours we need to attain
for other designations it’s becoming overwhelming. I would also like to remind the board that we execute these
principles and practices on a daily basis within our profession. Our daily activities are the best form of CE.
Michael W. Ladd, CFP
Thanks,
®
Mike Nozzarella, CFP ,
CDFATM
Against increasing credit
hours...
I am against raising the number of CE hours required each renewal period (every two years). When you have multiple
designations, it’s getting to be a ridiculous number of hours one is taking a course, attending a seminar, etc. in the
®
pursuit of credits. I’m working on my CIMA, and currently hold the CFP [certification] and CDFA. All three have
significant CE requirements. There is a good amount of overlap with regard to the material, but it is already difficult
maintaining the two certifications I currently hold.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Michael Orf, CFP
Subject
®
Ethics Requirement is a
waste of time and
resources
Page 146 of 379
Comment
Sitting through 4 hrs of ethics does not translate into increased ethics awareness. The ethical requirement is currently a
®
waste of continuing education time and money. You either operate by the golden rule or you don't. Flogging CFP
®
[professionals] with more dry ethics droning does not add to the quality of advice that the CFP [certification] delivers. I
think the pro bono credit is probably the best idea of all of these proposed changes.
Thank you for considering my input,
Michael Rodney Ruff,
®
CFP
PROPOSED CE RULE
CHANGES
I am in a rural area. It is very expensive to travel to CE events. Please do not increase the number of hours required
unless the webinars are increased to accommodate the increase.
®
For example, Surgent McCoy basically dropped out of the CFP [certification] CE sector and now just does internet CPE
for CPAs.
I have been a CPA for 35 years. The 40 hour PER YEAR CPE requirement has been easy to meet because of the
numerous webinar offerings. That's right, 40 hours of CPE every year for CPAs. Please do not increase the hours
requirement without also seeing that the vendors increase the hours of CE available via the internet.
®
I do not think the increase in the CE requirement will "make" us better CFP [professionals]. I've been down that road for
35 years as a CPA and I am also a Certified Fraud Examiner - Based on my four decades of experience, the current
®
requirement is more than adequate for a CFP [certification].
®
Every financial professional (CPA, CFP [professional], etc.) that is sent to prison for fraud maintained their professional
license by attending CE or CPE courses and taking the ethics course. A crook is a crook whether they do 2 or 4 or 10
hours of ethics training. The increased hours requirement is an ivory tower approach that lacks a basis in reality. I can
give you names if you need them.
A. Michael Russo,
®
CFP , EA
CE Credits
I would like to offer my opinion on changing the CE requirements. I would leave them at 30 credits. I’m sure many
certificants hold many designations ( I personally have my EA and insurance license) and already need to fulfill many
CE requirements. Although there is some overlap, it seems that a 3rd of my year is already consumed by CE.
Thank you,
Michael J. Lantz, CFP
®
CE--comments
While I think tougher restrictions and educations requirements are a good thought, I respectfully disagree with moving
forward at this time. It appears to me that almost all avenues of licenses have now imposed additional hours and I find
myself with a number of licenses swimming in CE. Most of these are just done to impose additional fee revenue while
not offering any real value to the practitioner or investing public.
®
If there is a way to make CFP [certification] hours transfer across all avenues of CE--i.e. state insurance ce, finra, firm
elements, lt care, then I would support tougher CE but until that happens I think you will find practitioners spending
upwards of 10% of their time just completing and tracking CE.
Thank You
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Ronald W. Mitcherling
®
Jr, CFP
Page 147 of 379
Subject
Comment
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I’m writing in total disagreement of three of the proposed changes to the CFP [certification] continuing Education
Requirement. First, I feel the 30 hours of CE every two years is more than adequate and does not need to be increased
®
to 40 every two years. In addition to the CFP [certification] credits many of us have requirements for insurance and
other designations which do not always count toward one another. Second, I do not feel an additional 2 hours of ethics
will make a difference in the industry nor is necessary. If you are an ethical person you will act ethically. If you are not
an ethical person you will act accordingly and an extra two hours of classes/self study will not change that. The failure
of some to have ethics on Wall Street does not constitute additional ethics training on the rest of us. Third, I feel that if a
®
class is approved for a designation within the financial industry that the credits received should count toward CFP
[certification] CE.
®
I hope the CFP board takes our opinions into consideration.
Thanks,
Cyndy Montgomery,
®
CFP , CPA*
Changes in CE
requirements
Bob Moore
Joan M. Most, CFP
Good that you are reviewing them, but pls keep in mind that a lot of us have CPA, insurance, JD, etc. licenses with 40
hrs or less required CE per year. Make sure that any hours of CE required work for all licenses, don't be too restrictive
on type and number of hours. It is already a very time consuming thing to keep up with now. Thanks.
I think that the requirement for CE is sufficient at that current level.
®
CFP revisions
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
A question: We currently use a 2 hour Ethics presentation that has been ‘approved by the CFP Board’……what does
the plus ‘2 hours of ethics programming’ mean?? Pls offer an example of the ‘2 hours of Ethics programming’. By the
way, the CFP Ethics presentation that I saw most recently, with ‘the Shadow’ character, got old quickly. The CFP board
should have several ethics program offerings so that chapter members don’t have to sit through something they’ve
already seen. Certainly it shouldn’t be that hard to have a variety of ethics presentations available!
Otherwise the change in requirements makes sense.
®
We often get requests for programs on practice management from the newer CFP [professionals], and we rarely offer
practice management programs because there were no CE credits.
Melanie S. Hummer,
®
CFP
®
As a CPA and a CFP [professional], I have difficulty finding courses that simultaneously meet the continuing
professional education requirements for both credentials. As a consequence, I have almost double the CPE
®
requirements that most CFP [professionals] have. Please do not increase the difficulty by imposing more hours and
more rigidity and sublimits in the categories of acceptable credits. I have a hard enough time already.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 148 of 379
Comment
®
Wayne A. Muehler,
®
CFP
Revised continuing ed
requirements
As a holder of the CFP [certification] designation for over 24 years, I wish to express my objection to the proposed
®
increase for continuing education requirements from 30 to 40 hours every two years. Many of us who work as CFP
Practitioners already face similar requirements for securities, insurance, etc. It is my opinion that this proposal, if
enacted, would impose an unnecessary burden on our practices.
Edward B. Murphy,
®
CFP
Comments re: proposed
CFP CE revisions
In regards to the proposed increase from 30 to 40 hours of required CE every two years, I respectfully request that the
hours not be increased.
We are in a period of unprecedented increases in regulation and oversight in the financial industry, with all the attendant
CE and compliance that goes along with it. This includes not just Dodd-Frank mandates, but also SEC requirements,
insurance, LTC, and our own financial institution requirements. We are becoming increasingly overburdened with hours
upon hours of online classes, tests, and case studies, from all directions.
As an example, here are the items I’ve needed to attend to or been assigned in the past week, and the expected or
actual hours given to them.
1. Tuesday – Series 7 CE at Prometric – 4 hours, including travel time to Prometric in SF
2. Thursday – BofA/ML Annual Compliance meeting – 2 hours, including insipid 1.25 hour video
3. Due Sept 7 – BofA/ML Firm Element CE – 6 hours 15 minutes
a. Alternative Investments – 30 minutes
b. Key Policy Review – 1 hour 30 minutes
c. FINRA Rule 2111 – 30 minutes
d. Market-linked Investments – 30 minutes
e. MSRB Rules and Credit Risk – 30 minutes
f. Sales Practices – Annuities and Mutual Funds – 30 minutes
g. Curriculum Overview – 15 minutes
h. GWM Compliance Discussion and Enterprise AML assessment – 60 minutes
i. Preventing Discrimination and Harassment – 60 minutes
That adds up to over 12 hours in one month, taken away from actually helping clients and building my business.
Already this year, I’ve done another 9+ hours of other firm CE, 5 of which were, admittedly undertaken by me voluntarily
to be approved as a discretionary portfolio manager. Removing those 5 hours, I have been required to complete a total
of over 17 hours of BofA-assigned CE in 2012, and to judge from past years, there will be 4-8 additional hours assigned
before year-end.
®
Add to that 30 hours every two years for CFP [certification], 28 hours every two years for my CA insurance license, 8
hours for LTC insurance, and the list goes on…
I am effectively losing a full work-week every year to various Continuing Education and Compliance mandates. And that
number likely moves higher in coming years, even without the CFP board mandating a full 10 hours in addition.
We are overwhelmed, and overburdened by this, and the time available to devote to our clients and our business
®
continues to be reduced. I respectfully posit that CFP [certification] licensees are, as a whole, already more educated
and more committed to fiduciary standards and best practices than the bulk of our peers. An additional 10 hours of
required CE may look good for the press, but in reality will do little to augment that.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 149 of 379
Comment
Please do not increase our required CE from 30 to 40 hours.
Feel free to call me to discuss in greater detail.
Nancy Kaump, CFP
®
Comment on New
Certification Requirements
It certainly sounds like it is time to review the requirements.
My only comment would be that you consider increasing the hours from 30 to 35 for everyone for their next two-year
reporting period and then increase the hours from 35-40 over their subsequent two-year reporting period. People might
be more agreeable to a gradual increase than increasing the requirement by 1/3rd all at once.
Neta A. Jeffus, CFP
®
Comments on Change to
Continuing Education
My thought is the board is completely overlooking all the required courses a security licensed person must do. Ongoing
FINRA requirements certainly keep a professional up to date on changes. In addition, the firms we work for have
required learning courses. Most all of us have insurance licenses which required continuing education. I think you are
over thinking the continuing education requirements.
Would Bernie Madoff have learned more in four hours of Ethic Classes that he didn't learn in two? Requiring additional
hours of Ethic Classes is not going to
make anyone more ethical and I would propose will weaken the integrity of the Ethics Course.
Douglas J. Niosi,
®
®
®
CFP ,CLU , ChFC
Money
I completely understand that CE is important. But it once again comes down to time and cost. The Board has already
shaken the certificants down with additional renewal fees for which I have seen very little ROI. I think if they want us to
pay and invest more for CE, it should be a credit against our renewal fees. This is getting ridiculous.
Regards,
®
Larry W. Ohlen, CFP ,
ChFC, CLU
ce changes
I feel the 30 hours is adequate considering the ce my company has me do each yearand I want to keep
the online study program.
Thanks for all you do
Chris Osborne,
®
CFP
Proposed revisions
I was one of the first CFP [professionals] in the country (#358). When I first received my CFP [certification] there was
no continuing education requirements, and no expense to retain my designation. It was much like my college degree; I
earned it, it was mine. Then the college was purchased and everything changed.
®
®
You can never receive too much continuing education, but what is the point? You could increase it to 60 hours over 2
years and I it would still not be enough. Keep it at 30 hours and let each of us seek the education we feel we need to
run our practices.
Pierre E. Pajak, CLU,
®
ChFC, CFP
Proposed Changes
I oppose the proposed changes.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Pamela Stokes, CFP
Subject
®
Proposed CE changes
Page 150 of 379
Comment
®
I am adamantly against raising the CE requirements for CFP [professionals] for a variety of reasons. I am retired and
®
so am in a position to be honest, since I won't be affected much - and actually, I will probably drop my CFP
[certification] if these new rules are implemented, as it will be too burdensome to maintain my certification.
®
1. Very frankly, most CE is just a money grab by the providing companies (and that is particularly true of the "CFP
[certification] Ethics" providers, as they've got a "lock" on a captive audience.) All this does is enrich them at the
®
expense of CFP practitioners.
2. And also -- again very frankly -- a person can get however many hours of CE they need without listening to the
program or learning a single thing.
- A person can just pay the money to attend a class/tune into the program and do or think about something else the
whole time. That is what a great many professionals do. The good ones do it because they are already on top of
developments in their field, constantly read about their area, and actively stay current because they are dedicated to
their profession - the CE requirement is probably unnecessary for them in the first place. The bad ones do it just to go
through the motions necessary to keep their license - the required CE is a minor inconvenience to them and doesn't
change how they will behave in their practice.
- I'm not saying all CE is bad or that no one ever learns anything -- there are some excellent, valuable, and
interesting classes/seminars/programs that considerably add to one's knowledge, and "good" professionals often
accumulate far more than the minimum number of CE hours. But I am saying that mandatory CE has a limited
usefulness and its stated purposes are easily circumvented. As a result, increased requirements will not accomplish
much.
3. Frankly again, much of the CE provided is a joke, as there is little substance to it. (again, there are some excellent,
substantive, professional programs out there, BUT there are a lot of junk ones also -- and you will never be able to
differentiate them in an effective manner).
®
4. Increased CE requirements will put CFP [professionals] under an Over-regulation/burden compared to other
professionals (lawyers, accountants, etc.). CE costs money and time.
®
5. The fact is that good CFP [professionals] will keep up with pertinent education and keep abreast of changes in their
®
field of practice. Bad CFP [professionals] won't. By increasing the minimum hours of required CE, you wil be hurting
the good ones. but the bad ones will not improve.
6. Likewise, with regard to Ethics training, adding hours will not raise ethical behavior. Any increase in the number of
hours of required CE will just be an increased time and financial burden to practitioners (and windfall to the CE
providers). Any changes in the Ethics Policy can be effectively communicated and tested via the current 2-hour
requirement while still emphasizing important ethical considerations.
7. Trying to force x-number of hours in different areas of practice unnecessarily complicates the process and is difficult
to administer and follow. We used to have to report which "area" a particular course was in -- but it was pften difficult or
impossible to do on some, as a topic overlapped more than one "area", yet there was no way to delineate that, or to
effectively determine which column in which to report it. I assume that reporting was dropped for that very reason. Why
institute it again? It obviously was dropped before for a reason.....
8. Increasing requirements and adding complexity will necessitate more administrative staff and therefore more
expense, which will be passed on to practitioners in the form of higher dues, on top of the increased cost of CE. Is that
really what you want to do to your constituents?
In short, I think the proposal for increasing the minimum CE requirements is ill-conceived, will accomplish little, and puts
an unnecessary additional burden on CFP practitioners.
Thank you for the opportunity to respond.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Patrick Barry, CFP
Subject
®
Proposed revisions on
Continuing Education
Page 151 of 379
Comment
®
You have got to be kidding! As an industry, we are so over regulated right now. Not only do we (CFP [professionals])
comply with the Continuing Education you require, but we also have to comply with the Insurance CE requirements, as
®
well as our firm requirements. More CE will not make us better CFP [professionals]. We demonstrated the willingness
and discipline to tackle the course material and the exam. The more CE that is required, the less time we spend with
our clients doing what we are supposed to be doing. More ethics training won't make someone more ethical. You either
are ethical or you are not. Stop!
How are we benefiting from the doubling of our fee to you? Are there some hard statistics that show all of us CFP
[professionals] have benefited in some way??
®
These revisions to CE requirements should be shelved.
Patric Wallace, CFP
®
Proposed CE reg changes
I find the current ethics requirement insulting, doubling it even more so.
I have been taking the required course for the past 15 years and it is nothing more then regurgitation of the rules. I
think 20 plus years in the FP business with no complaints, should qualify one for a pass on this req.
If you think forcing someone to review regs will curtail poor business practices, you need to get out in the market place.
Awareness is one thing, forced education another.
Is the CE. Business an income generator for the College? It shouldn't be if it is.
Patrice Horner, CFP
®
Fwd: Request for
Comment: Proposed
Revisions to CFP Board's
Continuing Education
Requirement
I agree in pratice with the concept to fortify the CE program. However, I think doubling the ethics program to 4 CE is
®
acceptable INCLUSIVE of the CFP [certification] program. Second, I believe it would be preferrable to have the CE
credits spread amongst the topics in order to remain current.
Therefore, rather than a 50% cap by topic, a 10% minimum per topic.
On a related topic, I have been made aware of the ChFC designation which is being touted as advanced to the CFP
[certification].
It requires PACE credits. In any event, I think this is more of an insurance designation and should be publically
®
differentiated from the CFP [certification] an visa versa.
Patricia E. Gottier, CFP
®
Bureaucracy
®
I have no problem with raising the number of credits (I had over 50 last reporting period). BUT why does everything get
more and more complicated and bureaucratic (20 of this, 20 of that, 2 of this, 2 of that, no more than 50% of. . .)? Doing
business in the current climate and keeping up to date in a period of rapid change is difficult enough without having to
worry about which credits fall into your categories. In addition, if you are going to include practice management (skills
without which none of us would have a practice), then do something significant! Four hours out of 40?
What I see in my area is fewer young people entering our profession and at the same time more turning to alternative
credentials like degree courses (such as offered at NYU) or CIMA. This is not raising standards. It’s justifying your
existence.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Patrick Healey, MBA,
®
CFP
Subject
Proposed changes to CE
requirements
Page 152 of 379
Comment
®
I’m a recent CFP practitioner, and I’d like to submit comments regarding the recently proposed changes to the CE
requirements.
At a time when our industry is already facing increasing regulations from FINRA not just in terms of additional
compliance requirements, but also in terms of additional fees and expenses, I feel that it is counterproductive to be
®
introducing these proposed changes at this time. Most CFP [professionals] also must satisfy CE requirements as it
®
pertains to their respective insurance and securities licenses, and to be adding additional requirements for our CFP
[certification] designations, I feel, is excessive. There already has been a change to make the $325 membership fee due
annually as opposed to bi-annually, and moving towards additional CE requirements will only serve to further increase
the cost borne by practitioners in having to satisfy these additional requirements.
I don’t feel that these changes either provide more elite and/or exclusive membership, nor do I feel that they decrease
the likelihood of unethical behavior. If perhaps, we were given credit by FINRA for having satisfied CE requirements for
®
our CFP [certification] designations, thereby removing an additional time and financial burden of having to satisfy
separate securities CE credits, I may feel differently. Moreover, if the CFP Board were to provide these CE credit
opportunities at no additional cost to practitioners, I would be more open to additional requirements.
My presiding point is, at a time when people really need sound financial planning advice and will for many years into the
®
future, I don’t feel that we should be placing undue financial and compliance burdens on our CFP [professionals],
making it that much more costly and time consuming to operate our businesses effectively.
Patrick M. Adams,
®
CFP , ChFC
Increasing Continuing
Education requirements
I read the rational for increasing the requirements but found the summary to be incredibly vague. The summary the
®
CFP [certification] CE requirements "The proposed increase in required hours remains consistent with or below similar
requirements for established professions and comparable designations".
®
What other professions and designations were comparable to the practicing CFP [professional]? Please also keep in
®
mind, most practicing CFP [professionals] also need to complete the following CE's in order to stay compliant and
relevant in the field of financial services:
Insurance - This includes annuity sales
Long term care- Most states require separate CE for long term care
Securities - These are new continuing education requirements FINRE has imposed
Most firms require substantial compliance training, about 20 hours per year. Not to mention the following designations
or licenses:
Commodities, ChFC, CIMA
Please do not increase the need for more CE and please tell me what more CE would do?
Paul J. Podsiadlo CLU,
®
CFP
Proposed continuing
education
With all the proposed changes to the continiung education requirements I stongly oppose the proposed elimination of
CE credits ofr obtainment of additional financial designations. This concept makes absolutley no sense to me!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Paul Provost, CFP
®
Paul C. Verderese,
®
CFP
Page 153 of 379
Comment
®
Comments on your
proposal
I am a twenty five year industry veteran and 10+ year CFP [professional]. I do not support the increase to 40 hours
®
from 30 hours or the increase in ethics requirement. As a practicing CFP [professional], the base of my continuing
education is my practice, working day to day and week to week with real live clients on real live planning issues. I have
never taken even one continuing education class that was 50% as effective as actual client work.
regarding changes to the
continuing education
requirement
I vote to leave the requirements as they are.
Practitioners know best what topics they need to enhance their knowledge about. Please do not allocate requirements
to specific areas. Let the practitioner decide.
Thank you.
®
Paul Brooks, CFP ,
®
CIMA
Revisions to CE
Requirement
®
I would prefer the CE requirements remain unchanged. Increasing the CE requirements is not going to make the CFP
®
[professional] a better planner. The CFP Professional will seek the knowledge that is necessary to best serve his/her
clients. Increasing the Ethics requirement cannot make someone an honest person or make them go against how they
®
are incented. I take great pride in my CFP [certification] designation and believe most of us are honest professionals
who seek the knowledge we need on our own.
Thank-you for your consideration.
Paula Gómez, CFP
®
40 CEU ?
®
This burden (especially 50% limited to any one subject) will likely cause me to relinquish my CFP [certification].
Many years ago I found that taxation was my forte. I have annual obligations to the IRS and the state of CA of CE,
including ethics. New regulations for tax preparers are being required, including a national test which I must take by
12/31/13.
®
Relinquishing my CFP [certification] will allow me to save money with FINRA ($125 a year), CFP Board ($425 every 2
years) and all monies spent to purchase CE credits ($500 every 2 years?) The help I give my clients is practical and
®
requires only common sense. I do not deal with assets nor sell any products. I became a CFP [professional] because I
believed in the "initials." I was governed by the State board of registered nurses as an active RN for 26 years. I still hold
an inactive license as an RN. But I am 65 years old and not interested in increasing time spent taking courses.
I'd rather go sailing and spend time with grandchildren.
Respectfully,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Paula A. Heichel, CFP
®
Comments on proposed
CE credits
Page 154 of 379
Comment
Unlike those who work outside the securities industry, those of us who work for wire houses are required to take a
minimum of 30 CE annually. We must also take an additional 30 to maintain our insurance. LTC and annuity licenses.
Now we must certified and are required to take 30 hours of CE just to make mortgage referrals. In an average year I am
required to take no fewer than 60 and often 90 CE . It has become an increasing burden just to walk in the door every
day. With the proposed increase to 40 hours, as well as the limitations on self study, I have to begin to question whether
or not it is worth it to maintain my certification.
®
The wire houses are putting increased pressure on FAs to obtain their CFP certification. What percentage on new
®
CFP [professionals] are coming from the wire house? Why isn't the CFP Board working more closely with the industry
®
to have the in-house training provided count toward our CFP [certification] CE credits.
Perhaps the CFP Board should consider doing one day, weekend workshops around the country to help us fulfill our
requirements offering 10 or 15 credits at each session.
Margaret (Peg) Marie
®
Moore, CFP ,
®
®
CRC ,CPWA
comments on amending
the CE requirements CFP
certificants
In response to request for comment:
After reading through the proposed changes; the rationale for the increase from 30 to 40 hours of CE with topic specific
credits capped at 20 hours and the increase in from 2 to 4 hours of ethics – I whole heartedly agree with these proposed
changes. Our industry continues to need to lead by example and these are good changes overall J
Please feel free to contact me with further questions.
Peter A. Meeks, CFP
Peter J McGuinness,
®
CFP
®
More hours...
30 hours is plenty... As professionals in the field, we need to also have CE for insurance, commodities, securities, LTC,
etc... This is starting to sound like the Government Regulation Overkill that is presently destroying our industry! Enough
is enough. Crooks and lazy planner will continue to do what they no matter how many hours we take...
Proposed rule changes on
CE
I am opposed to any changes to the current CE rules. Changing the rules as proposed will cause significant burdens on
certificants. The Board has not supplied any "proof statement" that the proposed changes will enhance the delivery of
financial planning services to the public, other than conclusory statements. Finally, I am opposed to any changes in the
"self study" method. As a certificant who "challenged" the certification exam and entirely self-studied for certification
(without taking a single in person or on-line class), I see no reason why I should not be freely able to self-study for CE.
With regards,
PS: I should also add that under the continuing education rules in New York State for licensed ATTORNEYS, the
requirement is 24 hours (every two years). What is it about financial planning that requires the CE standards to be in
excess of that required for licensed attorneys?
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Peter Gennuso, CFP
®
Propoaed Changes to CFP
CE
Page 155 of 379
Comment
Several Questions.
1. Has there been a noticeable increase in the number of ethical violations among members? Increasing the number of
hours to go over ethical issues will not create a more ethical membership. People know the difference between ethical
and unethical conduct. The willingness to adhere to ethical conduct does not come from more hours of "ethics" CE. it
comes from within the person, a willingness to conduct themselves ethically. That's a matter of morals and will; not
education.
2. I am in favor of limiting the number of hours in any one subject to no more than 50% of a stated subject area.
3. I am opposed to increasing the number of hours. I am sure that I can find the time. Don't really know if the additional
®
time will make me a "better" CFP [professional]. I find that working on cases and doing the research to help my clients
is more valuable than any classroom-constructed case study.
4. How do you accredit "pro-bono" work in order for it to qualify? What's the intent and/or purpose? If offering our
expertise to those who need it and can't afford it is the goal, I can see it. Doing something for free is not necessarily
done with the intention of giving back to community. Sometimes it's done for business development purposes. Should
this type of marketing effort be rewarded with CE credit?
I'd be willing to discuss in more detail via telephone if that would be helpful. Thank you.
Peter T. Palion, CFP
®
Tow Whom It May Concern:
I think that Mr. Gluck raises some valid points in his commentary on the proposed changes. Instead of copying his
points, here's the link to the
article:
http://advisors4advisors.com/index.php?option=com_content&Itemid=316&task=view&id=16163
Phil Kirshman, CFP
®
Proposed changes to CE
I'd like to register my opposition to many of these proposed changes. It seems that the proposals are designed to make
ongoing maintenance of the FRP more difficult.
®
Personally, I think 30 hours is already plenty of CE for the CFP [certification]. I also have CE for my insurance licenses,
and for my brokerage licenses. All of it is getting to be quite onerous and your proposed changes appear in some cases
to make obtaining the CE more expensive.
Another point is that while you certainly have the right to protect your brand any way you see fit, I find it to be somewhat
of a "bait and switch" to drastically change the CE requirements after I've already gone through the trouble of acquiring
the designation.
Thank you for your consideration,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
C. PHILLIP PIGOTT,
®
CFP
Comments on CE
Page 156 of 379
Comment
I believe that your requirements are sufficiently stringent.
With my multiple designations AIF, CLU, ChFC, CFP, MSFS, AEP plus Insurance Licenses plus the FINRA
Broker/Dealer firm element requirements --- I typically obtain over 90 to 100 hours of CE credit for the various
designations.
That’s enough time spent on education.
Philip Overton, CFP
®
CE Comments
I feel that 15 hours of continuing education is more than adequate to keep pace with the changes taking
place in our field. Keep in mind that we hold multiple licenses, in most cases, that require us to do much
more continuing education that what is called for by the CFP Board. 20 hours just to satisfy the Board
is definitely over kill and not necessary.
I would also say that 2 hours of CFP Board approved ethics is adequate as well for the same reason as
above. We are required to do ethics studies for our insurance licenses as well, and are required
by our individual companies to do company based ethics studies. 2 hours of ethics studies off of the
"Code" is enough.
I would recommend that you keep the CE requirements as is.
Thank you for your consideration.
Ryan Philyaw, CFP
®
Proposed Changes to CFP
CE requirements
(1) Practice Management CE Programs (examples: office management, business operations) DO NOT contribute to
the body of knowledge that will help clients. I feel that courses on these activities should not be allowed for credit.
(2) Similarly, while I applaud pro bono work, it does not contribute to the goal of continuing education.
(3) Has there been an uptick in ethics violations? I don’t see the point in increasing the ethics CE requirement, as 2
hours seems to cover the topic adequately.
Thank you.
Patrice M Konarik,
®
CFP
Extended CE Credit
Proposal
®
I have had my CFP [certification] designation since 1990. Once during that time I put it on a "dormant" status and then
made up the CE hours to become current. I am not actually "in the business" of financial planning but do the majority of
®
my training in the retirement plan areas and mostly use my CFP marks as credentials. The 50% subject limit would put
a big burden on me and force me to waste my CE time in areas I don't use. Also, with the additional 2 hours of ethics
and a total of 10 hours extra of CE credit requirements, I will probably just let my designation go and not re-certify at the
end of my term. I hope you decide to keep the CE requirement the same as it is now.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Patrick Hoffman, CFP
®
CE proposal
Comments/Feedback
Page 157 of 379
Comment
Thank you for bringing forth the proposed changes to our CE requirements. I have never given feedback before, but is is
an area of such importance, I felt I had to comment.
When ever there is a recommended change, I always ask, "why?".
I understand the rationale of our industry being ever changing, but to raise the mandatory requirements by 33%? We will
take the required 30 hours to 40 hours. My first question is, has there been so many cases of negligence brought forth
against practioners that we need this increase of CE? If not, my feeling is that it is the Responsibiulity of the practioner
to reamian current in their field of expertise.
One example I give, in our own industry, the fact that CFAs do not have any CE program. We have a Very good
program in place, and now, because the industry is changing, we feel we have to increase our CE?
If the Board decides to put this change into effect, I ask that the change only occurs for the CFP members who put
themselves out as Financial Planners. I have my designation and when you look at my practice, I check off that I provide
no financial planning in my practice. I am more on the investment side, as I am a Sales Director for Legg Mason, and
use NO Financial Planning, Estate Planning, Insurance Planning or Retirement Planning in my curerent practice. I am
investments only - as indicated. Therefore, for professionals such as myself, who have no need for increased CEs,
please keep our CE requirement the same.
If I ever choose to get back into the Financial Planning practice, then (if it is voted to increase CE requirements), I will
comply with the increase.
As far as raising the ethics to four hours. I have no problem, as long as the over-all CE *Additional comments below*
requirement remains at 30 hours.
Thank you again for your contacting and if there are any questions, pls call my cell at 610 733 7977.
Ralph Stroffolino, EA,
®
CFP
James R Martin, CFP
®
CE Comments
Increased CE requirements, not necessary. Present requirements should be strictly enforced and monitored - but not
increased. All other suggestions are reasonable.
Revised CE CFP
Standards
I enthusiastically endorse this change. Any way that the Board can position the professionalism and competence for
CFP designees is good for the designees and good for the public.
Thank you for your continued work.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Randy Pople, CFP
Subject
®
W. Ray Sagner, CFP
®
Page 158 of 379
Comment
Continuing Education
Requirements
I am concerned with the current proposal to increase the requirement to 40 hours. I have enjoyed the lack of
bureaucratic leanings within the CFP Board and am disturbed to see our organization following the lead of our federal
government which through its increased regulatory burden and done more to impede than to encourage business
activity. The 40 hour requirement is arbitrary and using another professional discipline as a guideline gives me little
comfort for a sound basis of determination.
®
Please remember that a practicing CFP [professional] is trying to make a living and our focus is on our client. Please
don't get in the way of our main purpose with this recommendation which will be expensive both in time and money. This
coupled with the recent increase in renewal fees smacks of an undue bureaucratic burden.
Thank you for your consideration,
CE
I can understand the motivation to increase the total number of hours to be more in line with other professions and the
rational for most of the other changes. It will be a boon for program vendors and the associations. A 33% increase in
revenue is pretty good these days.
I don’t agree with the perceived need or rational for doubling the Ethics requirement. It is a stretch in logic to make the
correlation that because the examination and curriculum increase ethics knowledge that doubling ongoing course work
naturally follows. If a practitioner doesn’t get ‘it’ while going through the program and having a 2hr reminder every two
years, adding more requirements will not produce more ethical Advisors.
If I may ethics are moral principles that govern a person’s behavior or the conducting of an activity, and a principle is a
fundamental truth or proposition that serves as the foundation for a system of belief or behavior or for a chain of
reasoning. I find it difficult to believe that another 2 hours of studying scenarios will create a fundamental difference in
ones belief.
Robert M. Bauer, CFP
®
Increased CE
Requirements
®
I've been a CFP practictioner for over a decade, and it has cost me many thousands of dollars over that time to get the
designation, pay high renewal fees and for CE credits. In all that time I have received ONE phone call from a client
®
looking for a CFP [certification] in my area. ONCE. ANd they NEVER showed up for their appointment. So in about 11
®
years I have made NOTHING by becoming a CFP [professional]. I make all my business income as an Enrolled Agent
handling tax matters. I don't need any more Continuing Education. It is excessive already, and the CFP board refuses to
®
accept Ethics classes I take at IRS forum's towards my CFP [certification] CE requirements, meaning I have to pay for
ethics CE twice every year. If these proposals are implemented, I will have to very seriously consider abandoning this
designation. The cost is not worth keeping it and I already spent a great deal of time every year taking CE courses and
definitely do not need to be taking even more, especially when there is no benefit to it for me.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
RC Froistad, CFP , EA
CE requirements
Page 159 of 379
Comment
I am commenting on the various new proposals for CE credits. The major one that I disagree with is having the credits
®
limited to 50% cap rule. I believe CFP professionals though well trained in various categories specialize in a certain
category which they receive most of their CE credits from. I personally have most of mine in the tax area due to my
expertise. I do attend quarterly meetings for my broker dealer (I am a licensed repwith Genworth Financial) which I
®
would believe that I should receive credits for but they are not registered with CFP [certification CE]. The process that
you have to go thru from an individual side of things to get nonregistered provider CE credits okayed should not have to
be costly and burdensome.
I also believe the 2 CE credits on Ethics every two years is the correct amount. 4 would be overkill.
Thanks
Reginald W. Burroughs,
®
CFP
CE Standards
Looks good.
®
I’m in favor of continuing to increase the level of knowledge of CFP practitioners.
Looks logical, reasonable and doable.
Thanks!
Reginald Jensen, CFP
®
CE requirements
Most organizations stop the CE requirement at either age or number of years. Age 75 or X number of years should be
included.
There really aren't any changes in investment philosophy, only changes in the number of scams. Contract language
might change, but the language changes to cover up new scam. Either an investment produces a return or it doesn't. A
Fortune 500 company has a life expectancy of 45 years, a NYSE company has a life expectancy of 21 years. A
NASDAQ company has a life expectancy of 10.5 years. And the rest average between 1 and 3 years. Some private
companies have long life expectancies, but they need to merge into a public company (if the private company has more
than modest value) prior to death of the principal owners and thus become one of the crowd.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Tracy Reich-Smith,
Robert W. Baird & Co.
Incorporated
Subject
Feedback on Proposed
CFP CE Requirements
Page 160 of 379
Comment
®
I am currently the primary sponsor for our firm and am responsible for requesting CFP [certification] CE for programs
that may qualify and filing on behalf of our associates that participate. I wanted to provide a few comments from my
®
point of view on the proposed changes to CFP [certification] CE policy.
• Increased hours from 30 to 40 every 2 years:
o From my perspective, I’m indifferent on how many hours are required. However, if you do increase the number of
hours, then you need to be more flexible on what is approved for credit.
§ Example: We provide development for associates internally that may be based around our Financial Planning
software, but is 95% more on Financial Planning concepts versus any point-and-click in the system. Yet, this continues
to not qualify under your guidelines.
• Practice Management Inclusion:
o I think this is important and am glad to see it being discussed. I think it should be included, and I think you should
extend it to things like Financial Planning software. Again, very little is actually trained on in regards to software itself…
It’s all about the concepts, how to handle one scenario versus another, etc. Very little about the tool itself.
• 50% Cap Rule:
o I don’t know that I feel strongly on this, but can say that if I as a sponsor filing on behalf of my associates needs to
know this for each of them, then it’s going to limit my ability to file anymore. If I can file and the program can figure it out
itself, that is fine.
®
Overall, I think the proposed changes are fine and I know that those individuals that hold the CFP [certification] will
have much more to say on it. I do, however, think you need to simplify what you can. Making it more
complex/complicated to maintain the designation will result in many deciding it’s not worth maintaining when you have
competitive designations out there than may have more hours required, but not nearly as confusing to maintain.
Please contact me if you have any questions.
Thank you,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Jon A. Reinhardt, CFP
®
CFP CE Requirements
Page 161 of 379
Comment
Unfortunately, most of your CE proposals seem pretty unrealistic, time-consuming, and fairly costly to comply with on an
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annual or bi-annual basis. It appears to me that your goal is to have every CFP [professional] fit a "cookie cutter" mold.
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This is not only unrealistic, but I believe it greatly deters from the CFP [certification] designation.
®
In my own case, I earned the CFP [certification], designation over 25 years ago, but I have never practiced as a
®
financial planner, nor held myself out to the public as a CFP [professional]. I work for the federal government and the
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only reason I have kept my CFP [certification] license in force, is because of the possiblity that I may want to practice
®
as a CFP [certification] after I retire from the government in a few years.
®
It has been very costly and difficult to maintain my CFP [certification], thanks to your expensive dues and over
burdensome CE requirements. I am sure that I have spent at least $10,000 over the years with no direct benefit. I think
I spent almost $500 last year towards this end. My employer offers numerous tax law CE courses through outside
professional CE providers, but any other CE on other topics would have to be paid for by myself. Unfortunately, the CE
providers that my employer uses are not entirely recognized by the CFP Board, since apparently they do not have
enough test questions. Furthermore, most of the online CE hours that I took were only accepted at 50 percent of the
couses stated hours. This has made it very difficult and costly for me to comply with your current bi-annual CE
requirements. So your proposals would only compound my problems.
It should be noted that I have also held the CPA designation for many years, but I do not practice as a CPA nor do I hold
myself out to the public as a CPA. The CPA Board employs common sense and wisdom by recognizing that its
members function in various professional capacities and should not all be treated the same. Since, I am not a practicing
CPA, I am generally exempt from the annual CE requirements and my annual dues amount to only a nominal amount
rather than the full dues owed by practicing CPA's.
It would be nice if the CFP Board could learn from other professional boards and make its licensing and CE guidelines
practical and flexible to meet the various needs of its members. I would think that it would be beneficial for the CFP
organization to have its members represented in many industries and capacities. But it appears that you are headed in
the opposite direction and want a membership of only persons working in financial planning practices.
Additionally, it appears that you have concluded that the professionalism and quality of your members is somehow tied
to how much CE they take. I personally think there is very little correlation. I have taken many hundreds of hours of CE
®
over my career, but I believe most of it was not very beneficial. I think what makes a good "CFP [professional]" is a
person who has stong personal and professional ethics, willingness to fairly and impartially serve his client's financial
planning needs, and fundamental knowledge and experience with financial planning concepts.
®
Renee Griffiths, CFP ,
CLU, ChFC
While I understand the intent behind the CFP board wanting to increase CE requirements from 30 to 40, I do not agree
®
with the proposed increase. If the only designation I maintained was the CFP [certification] designation, the increased
hours would not be that difficult. However, for advisors who have multiple designations, life insurance licenses and are
securities registered, having 10 additional hours CE requirements simply takes time away from helping our clients.
I do agree with the 50% cap rule as diversification in our continuing education is important. Thank you for reading.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Richard C. Brief, CFP
®
Changes to the CE
requirements
Page 162 of 379
Comment
My comments regarding the proposed changes to the CE requirments:
My suggestion is to keep the current CE requirements as they are for those practicing only one area of planning - such
as insurance sales.
®
There are many CFP [professionals] like myself who only practice one area of the financial planning spectrum. I have
been specializing in Long-Term Insurance sales for the past 12 years. 30 credits every two years seems to be fine for
a person who is not engaged in a full financial planning
practice.
If the CFP board was to make the requirements much more burdensome I would not continue with my CFP
[certification] designation.
®
®
Please realize that there are CFP [professional] designees who only practice one of the financial planning disciplines
(such as insurance sales) and 30 CE credits seems to be quite sufficient.
Richard T. Holden,
®
CFP
RICHARD Dee, CFP
®
Document1
Attached are some comments regarding recently discussed changes to CE requirements. For those which I have not
commented I do not have a strong opinion either way.
Thank you
Proposal to change total CE hours required to 40 every 2 years.
Response: That is a lot of hours of CE. If you are considering requirements of CPA’s as a comparison, remember
that CPA’s allow carryover of hours similar to what my state (VA) does for Insurance hours. This would be acceptable
to me if some carryover was allowed, say, up to half of the total two year requirement.
2. CE credit for completing professional designations and licenses.
Response: Do not concur. The coursework for new licenses ( 24, 51, etc) is outstanding education and totally relevant
to our profession. It is the very epitome of education and should be counted and awarded CE. I agree that exam prep
or review courses should provide no credit as they are essentially memorize an answer courses.
3. Increasing the Ethics CE requirement.
Response: You cannot teach ethics, and all of us know what it is and what it is not. Some choose to live by it, some
choose to ignore it. Ethics CE is absolutely awful in general. Perhaps an additional 2 hours specifically on case law
and penalties imposed on specific individuals, what they did, and what their punishment was might do a better job of
reminding us all of right and wrong.
Revisions to CE
requirement
If it were a vote, I would vote "no". Our time is already short. We get education by working and serving clients daily.
®
The focus is in the wrong place. I would force all aspiring CFP [professionals] to have a degree in Personal Financial
Planning in the future. I would also make the exam much more comprehensive and difficult, adding in business
planning, succession planning, more advanced estate planning, and more advanced income taxation.
Is there any empirical evidence that shows that the ethics CE is actually making planners more ethical? I have seen
plenty of planners I consider unethical that must have passed their ethics requirement......
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Richard G. Barnes, Jr.,
®
CLU, ChFC, CFP
®
Richard Horn, CFP
Page 163 of 379
Comment
Increased CE requirements
I am opposed to all of the proposed changes. In the real world, as opposed to the academic world, there is little to be
gained from these increased requirements, and there is an increased cost to be borne by certificants at a time of
economic pressure on all businesses and professions.
Comments on CE
proposed changes
1 I have no problem with raising the requirement to 40 hours. I generally exceed that number just getting the required
hours from other associated licenses. What I do have a problem with is the Board making in more difficult to accept
hours from other licensing authorities. I have been a licensed planner since 1984 and in the beginning it was much
easier for me apply required CE from Tax and insurance license requirements. If we raise the hours, I hope that you will
consider being able to more readily apply the other associated disciplines that most of us are also required to maintain.
The board does not accept hours that have been accepted for CE by other authorities unless they specifically go
through the motions to get the boards approval. I can understand that not all insurance agents, tax accountants, or
®
brokers are also CFP [professionals] so often they don’t bother to jump through that hoop. The result is often times it
®
®
requires us to double up on hours because say insurance hours don’t count for CFP [certification] nor do CFP
[certification] hours count for insurance.
2 I applaud the pro bono proposal but I am confused as how it would work. The CE sponsor has to supervise the pro
bono service? Does this mean only educational pro bono services like to schools would qualify?
®
3 The ethics issue is similar to item #1. I am required to get ethics in everything yet, CFP [certification] does not accept
other ethics hours. Requiring me to double up. I also question the intrinsic value of trying to teach ethics. While it is
important to focus on this, I don’t really think we can teach any one to be ethical. Ethics is something we should live not
learn.
4 If you going to cap specific areas of the financial planning, I thought it was already required that the hours be
diversified into various subject areas.
5 Are you planning to eliminate all on line “self study” coursework and only approve those by accredited colleges and
universities? I would not like to see this. Many planners are not located in metro areas were there is easy access to live
programs and their schedules do coincide live events. My own example it that for some reason local conferences
always seem to come in March and April that is just not possible for me to attend. I could not get off from work during
this time (I am salaried not self employed). I also don’t make a lot money to travel to distant locations and send lots of
money. The online option is essential for me. I am also concerned that by moving to only accredited colleges and
universities to cost will increase.
While I understand the board’s desire to maintain the quality of the profession please never lose sight that not all CFP
®
[professionals] make six figure incomes. Don’t loss sight of serving CFP [professionals] as well.
Rich Morris, J.D., CFP
®
proposed CPE changes
®
Change is always an important exercise in responding to the changing demands placed upon financial planners. All of
your proposed changes seem to be very well conceived. Still, I want to comment on the “cap” issue. My practice largely
focuses on tax planning & tax preparation, so I am taking CPE to satisfy three licenses. It is obvious to me that most
financial planners have only a rudimentary grasp of the tax regulations. I find that my detailed understanding of the tax
regulations provides an exceptionally strong foundation for all of my financial planning activities. I believe there should
be not a cap, but a minimum of 20 hours CPE in income tax. Obviously, those who are not fluid in IRC/Treas Regs also
would not have a taste for so many tax CPE’s. Let’s look for a balance and move the cap to 30 or 35 hours to recognize
the need for financial planners to keep abreast of the intense changes that are occurring in each area of focus. We really
cannot be a jack-of-all-trades; and we are trained to be quick to bring in other experts to handle areas outside of our own
expertise!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Richard J. Rogers,
®
CFP , CPA, PFS
Comments
Page 164 of 379
Comment
I am strongly against increasing the ethics CE requirement to 4 hours. I have been attending required ethics training for
over a decade, and I have never learned anything new. Doubling the amount of this recurring, redundant training would
be nothing more than 2 more hours of torture every year.
Please feel free to call me if you would like to discuss this further.
Richard Saint-Laurent,
®
CFP
Proposed changes to CE
requirement
You people have too little to do. Stop tinkering with us and with our practice of financial planning. We, in the “field”,
have enough on our plate, trying to make a living while staying within the law, and those multiplying and increasingly
burdensome regulations. Most of us complete our CE requirement with great difficulty, and at times, we do so, to a
degree of near neglect to our practice, because we may be unavailable when clients require our help. We must travel to
venues to attend sessions. We may be away for one day, but some take us away from our practices for several days.
And doubling the ethics requirement is overkill. As it is, the two hour requirement is ludicrous. Completing a two hour
class on “Ethics” will not prevent anyone from behaving “unethically”. A fervent religious practitioner may still do evil
things.
I am an independent registered investment advisor, and I have been a financial planning practitioner since 1980. I
began my career with a broker/dealer, but I abandoned all B/D affiliation years ago, when it became clear that any
financial planner could not ethically represent the best interest of clients while affiliated with a broker/dealer, or in the
employment of a wire house brokerage. But the CFP Board has no problem with that. The CFP board continues to
grant the mark to people who work for an investment company. When is that change coming along?
Rick Ochterbeck, CFP
®
Re: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I'm responding to your request for feedback on the proposed changes to the continuing education requirements. I would
suggest we leave the current requirements as is and not change and or increase. As an industry, we have never had
more compliance and continued education increases as we have now. Whether this is to maintain our licenses, FINRA
and firm element needs. Those alone should be enough for the additional 10 hours you're proposing. Also, you'll never
regulate someone's ethics. They either have ethics or they don't. Additional required hours for ethics won't change the
unethical person. There is a point in time when all the time commitments for hours will hit the wall. When that time is, or
the number of all the required hours are, I don't know but advisors will make a decision on which hours they don't need
anymore. I don't want us to be the hours they recapture to gain a week of time back to their business or life. My
®
practice is not going to grow because I spent 10 more hours to keep my CFP [certification] designation.
Thanks for your time,
Theodore Richard
®
Waechter, CFP
Richard Vega, CFP
®
increased CE requirement
If you adopt this new rule, I hope you will promote the availability of multiple options to satisfy the requirement – and
preferably options that are not expensive. I primarily use Quest, via Vanguard’s website. It is high-quality and free, and
offers a wide range of topics. However, 40 hours every two years will require a large amount of content. I urge you to
promote development of such content, and to help us find such content.
Propose CE Changes
I have read your proposed changes, and must admit that I am surprised at the proposed changes. The requirement is
already tough enough to meet considering all the activities a certificant participates with. If you are asking for my
opinion, I say nay.
Thank you,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Robert C. McMaster,
®
CFP
Contiuning Education
Page 165 of 379
Comment
In my opinion, increasing the amount of required credits from 30 to 40 is unnecessary. Obtaining additional credits in my
view, does not provide any further knowledge, product or otherwise.
Furthermore, I can't even get an answer from CFP board, which I've emailed and called several times, on whether or not
current continuing education credits can carry over to the next renewal period. For an organization that puts so much
effort into the qualifications and maintenance of their designation, I have found that there is no support for those that
carry their letters.
Thank you,
James Robert Little,
®
CFP
Ronnie Robbins, CFP
Comments
I am not in favor of increasing the continuing education requirement from 30 hours to 40 hours. Bad choice.
®
Continuing Education
I think the current requirement is sufficient
®
New proposed CE
requirements
Looks like a waste of time and a reason to enhance the CFP [certification] reason for being and Typical of DC..more
bureaucratic b.s.
Robert R. Zyblut, CFP
®
®
CFP professionals have enough on our plates as it is without adding these undue and in necessary additional burdens.
The majority of us do not have the luxury of a salary like those on the CFP Board.
Sorry folks, not in favor
Robert Braun, CFP
®
Robert L. Gorman,
®
CFP
Robert Kreitler, CFP
®
Increased CE
Requirements
I am not in favor of increased CE requirements. All other facets of the financial industry have increased their CE
requirements which in my view is becoming excessive. We are now in a period of over regulation and the pendulum has
swung too far.
CE Proposed Changes
I don't see anything in the proposed changes which really adds to CFP [certification] credibility. I don't think we need
more CEs. However overall cost is becoming an issue for value received by membership.
Continuing education
requirement changes
I am already overloaded with continuing education requirements. I have firm credits, security, and insurance. There are
also money laundering and things like this. Additionally I write for professional journals and get no credit for this.
®
We don’t need more. The burden is already too heavy.
Robert L. Miller, Jr.,
®
CFP
CE credits
While I fully understand the value of CE, I find it hard enough to do 30 hours
because of my busy work schedule.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Robert J. Standish, JD,
®
CFP
Subject
Comments on increase in
CE hours
Page 166 of 379
Comment
After reviewing the proposal regarding the increase in required CEs from 30 to 40 hours per bi-annual period, I question
the utility of such a change. I certainly concur that our profession, and factors impacting our practice, are fast-changing.
®
However, I do not believe an additional 5 hours per year will ameliorate any CFP practitioner’s deficiency in planning
knowledge.
As a recreational triathlete, I am aware that we should focus on quality over volume when it comes to training. I believe
the same principles should apply in this case. Rather than simply increasing the volume, I would encourage the CFP
Board to improve the quality of CE courses. If you honestly assess the courses for which we can earn CEs, you will
likely agree that there is quite a bit of fluff (i.e., “crap”) that does nothing to advance my knowledge of topical planning
areas.
As a member of the Pennsylvania Bar, I am required to earn 12 CLE hours per year. There are fewer courses from
which I can choose, but the quality of the education continued in those programs seems to be more valuable than most
®
courses I take for my CFP [certification] CEs. I can certainly find worthwhile courses from which to choose to meet my
®
CE requirements; however, as most CFP practitioners will admit, if I need a few at the end of a period to simply meet a
quota, I can find very poor quality that will meet the CE hour quota. I would rather have fewer CE hour requirements so
that when we take time from our busy schedules, we can identify quality programs that will enhance my planning
acumen.
Robert Vance, CPA,
®
ABV, CFF, CVA, CFP
Comments
®
I have held the CFP [certification] designation since 1990, but as you see below, I have several other credential that
require CE. I greatly disagree with the proposal to increase the hours from 30 to 40 unless you loosen the
crossover/reciprocity capabilities for person with multiple designations. The organization has such a clamp on the
reporting requirements in terms of allowing CFPs to report CE obtained for other purposes that we as professionals
®
®
should be allowed to designated as applicable for CFP [certification] CE as well. If CFP [professionals] are the be
“trusted” to operate ethically and legally with financial planning clients, why can’t we be trusted and allowed to selfdetermine if a CE obtained for say, a CPA license, is also applicable to a financial planning topic without having to pay
you to determine that answer?
®
I use the CFP [certification] designation as a support to my CPA expert witness practice in divorce, but I will drop the
designation if you make the renewal more difficult and expensive. Thank you for asking for comments.
Robert P. Senkarik,
®
CFP
Robert P. Tomasulo,
®
CFP
CFP rules revisions
When would the proposed rule changes (40 hours of CE) go into affect, and what plans for extensions would be made
for those whose requirements would be due at the time of the increase?
With all due respect, I believe that I already spend more than enough time keeping current. I already spend a minimum
of 10 hours a week (most weeks it is more than that) reading all of the material that is necessary to keep me informed
for my practice. I find most CE courses are a waste of time. The research and updates that I do as a normal part of my
®
everyday reading are far more informative and relevant than any CE course that I am forced to buy to meet my CFP
[certification] requirements. As far as the Ethics courses are concerned…I would love to find one that contains some
fresh insights. Between the Ethics courses that my firm requires me to complete, and all the other mandatory courses
that I take every year, I believe that most of these courses are nothing more than a rehash of ground that has already
been covered year after year. I would not be in favor of having to take any more time away from the more productive
reading that I am already doing.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 167 of 379
Subject
Robert Yeh, MBA, CFP
®
Comment to CE
Requirement
Comment
I am an advisor with Ameriprise Financial Services.
There is a training requirement by FINRA (5 hours each year) that has not been eligible for CFP Board inclusion.
Topics such as client data privacy, practice management, money laundering, etc
seem to fall into the broader list of acceptable material. I feel that a concern for this kind of CE has been that
the training is too firm specific. Because this training has been continually improved over the last few years,
approved by FINRA and is at a level of detail that actually helps me work in better compliance with
company and FINRA regs and CFP Board principles, could these hours be eligible for CFP Board inclusion?
The total number of agency provided hours would still limit/control possible undue company influence on
the training process.
Thank you for your consideration.
Ronald N. Lazzaro,
®
MBA, CPA/PFS, CFP
Ronald J. Backe, CFP
®
Comment on CE
As a highly ethical advisor, I am insulted by the idea that we go from 2 to 4 ethics credits. I’m disappointed that the CFP
board has joined the politically driven need to create the appearance that we are “protecting the public” by layering yet
more useless requirements on advisors. Between insurance and securities compliance and regulatory requirements
that include computer based training on ethical issues, not to mention the ethics CE requirements of most professions
®
(CPA, etc.), we are spending too much time in the wrong areas. As a CFP [professional], I am bound by the ethical
®
standards that are a condition of holding myself out as a CFP practitioner. I don’t need to take a test every two years to
act responsibly and ethically. Let’s get back to the spirit of what CE was meant to be…education and thought provoking
practice issues that make us current in our profession and better advisors.
Proposed changes to CFP
CE requirements
I am opposed to the proposed changes to CFP [certification] CE requirements.
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Ron R. Blasdell,
®
CFP ,CLU,ChFC
Comments on Proposed
Changes to CE
Requirements
Page 168 of 379
Comment
®
I have read the proposed changes to the Continuing Education requirements for CFP [professionals] and in general I
am in agreement with them. I think the increase in hours is warranted and most of the other changes make good sense
as well.
The only change I have an issue with is the "50% cap rule," which proposes to limit CE credit for any single topic area
or professional activity to 50% of total required CE hours. In my experience, many CE courses span more than one
topic, yet for classification purposes they must be classified as one thing or another. For example, a course on the use
of Immediate Annuities might legitimately fall under Insurance (as these are typically insurance products) but would also
be relevant to Retirement Planning and possibly also Investments (if variable products were considered). I think this
makes enforcement arbitrary at best. And given that conferences comprised of individual educational sessions will not
be subject to the requirement, I don’t see why online, live or self-study courses should be subject to it either. I don’t
disagree with the goal in principle, I simply believe the enforcement of it would almost certainly be unfair in practice.
®
Gary C. Rooth, CFP ,
®
AWMA
I oppose CFP Continuing
Education rules changes
With all due respect, these proposals appear to not increase professionalism and will directly increase the time
®
commitment and financial cost of the CFP professionals. The only beneficiaries of these CE rules changes will the
professional staff at CFP [board] and course providers. Less time will be available for clients. Again, neither
professionalism nor client service will improve. Registered Reps already have a heavy CE regulator burden that is
redundant in ethics and other study areas.
As a person who loves education, I participate in every educational forum possible to upgrade my skills and work to
provide the best service possible to our clients. I do NOT oppose education! I oppose mandates that I do not belief will
increase the professionalism of our profession.
Please note, I commit approximately one month every year to continuing education both CE related and non CE related!
I am sorry if I have repeated myself to make my point.
Rose Greene, CFP
®
CE feedback
This is offensive!
I think these changes are way over the top. I don’t think it will improve the quality of the profession but, it will certainly
®
generate more money to you. I’ve been a CFP [professional] since 1986. Do you really think that between all my
®
CFP [certification] ce’s and all the other licenses and designations ce’s that I currently must complete will make me
more ethical than I have been for the last 26 years.
Find other ways to improve the profession without adding to our current burden.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Blake Rose, CFP
Subject
®
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Page 169 of 379
Comment
®
Please do not increase the CE requirements for the CFP [certification]. FINRA, the SEC, and the California
Department of Insurance are all constantly increasing the training requirements as well as paperwork for our industry.
Please do not add to the workload and complexity of this industry. I have a limited amount of time and money I want to
spend on CE and I am doing plenty already.
Also, please do not add hours to the CE Ethics requirement. Again, with all the agencies involved in our industry we are
doing plenty of CE, much of which is already redundant.
Do allow for practice management programs and/or pro bono activities to count for CE credit. This helps the efficiency of
our CE program.
®
Please look to simplify, lower the cost, and make more efficient the CE requirements for the CFP [certification]. Do not
add to our already excessive training requirements in this industry.
Thank you.
Ross F. Mongiardo,
®
CFP
CE
Enough already !
®
In addition to CFP [certification], I have CE requirements for my NY State Insurance license, CLU, ChFc, and my
broker-dealer’s firm element.
With all of these combined, I am making a serious commitment to continuing education. Please don’t add more.
Thank you,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Leon Rousso, CFP
®
Page 170 of 379
Subject
Comment
RE: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I’m always happy when CFP professionals are engaged regarding changes that affect us personally and the industry at
large.
®
I have only a few comments which I will leave brief and am available if anyone wishes to discuss in more detail. Please
assume if no comment on a change then I am in agreement .
1. Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
I strongly suggest this not be implemented
Because of the ever increasing regulatory requirements coming from all directions I do not believe increasing our CE
requirement will be in the best interest of practitioners. Thirty hours is plenty considering many of us also have additional
time requirements for other licenses, registrations and from our broker dealers.
2. Granting CE credit for practice management programs
This is an excellent idea and also works as an incentive for Pro Bono & Practice management work
3. Increasing the Ethics CE requirement from 2 hours to 4 hours
In my opinion, ethics cannot be taught. I suggest we DO NOT increase this area of our CE requirements.
The planner either has them or he doesn’t. From my experience there is plenty of ethics missing however giving the
unethical more education is like telling a thief not to steel twice as much. We need more enforcement , not more words
on ethics.
4. Reviewing online courses for academic credit monitoring of unethical behavior and practices
Excellent idea
Thank you
Rick Petrucci, CFP
®
Fw: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Please consider allowing a roll-over of excess CE credits from one year to the next.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Rubén M. Rodríguez,
®
CFP
Subject
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Page 171 of 379
Comment
Thanks for letting us comment on this important issue. I agree with structure and increase in CE requirements but
suggest to create two different levels according to responsibilities conducted by the professional.
®
Like some other professional accreditations, I suggest having two different type of CFP [certification] continuing
®
education requirements. For example, for those CFP professional not directly involved in financial consultant or direct
client's advise, it will be preferable to have a fewer amount of CE hours requirement or at least keep same level of
®
requirement of 30 hrs. For those CFP professional directly involved in advising responsibilities, the new 40 hrs
requirement should apply.
®
Changes in employment status due to economic or demographic situation may cause the CFP professional to change
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functions which do not require direct contact with clients and financial planning advise. In this case the CFP
[professional] may not be performing financial planning functions per se but is willing to keep up to date and renew his
(her) license. In that respect, we have a professional not actually performing financial planing functions but capable and
willing to keep his (her) license. Whenever times come and professional activities change, full requirement should apply
and be required to take additional credited CE hours to renew under full practitioner license.
Hope this brief statement might be considered.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Russell Tschida, CFP
Subject
®
Comments on CE credit
change proposal.
Page 172 of 379
Comment
Below are some comments regarding the current proposal on the acceptance of CE credits.
Regarding the increase in total CE hours from 30 to 40 hours:
Even though it is assumed that greater number of hours equate into greater knowledge of a specific topic this isn’t
necessarily the case. A professional gains knowledge not only from formal studies but also and most importantly from
real world experiences.
Regarding the ethics requirement:
Ethics can only be taught in so much doses. Ethics is much like a religion which is an “understanding” or a “feeling”
which is to be practiced and not so much like other subjects which rely on more technical atributes.
Requiring a greater amount of ethics in order to obtain credit is being onerous on the subject. Either a professional does
or doesn’t have the common sense to examine a potentially situtation which relies on common sense.
Regarding the 50% cap rule.
Capping credit on topics wil prevent professionals from continuing their specialization in their chosen area of
®
concentration. Even in the Rules tit states that if CFP [professional] to not possess a area of knowledge to seek out
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other professionals who do. How can a CFP [professional] become specialized if the 50% rule forces them to become
®
more well rounded? Also, a CFP [professional's] specific field may not even cover the area of study which the 50% rule
mandates they cover.
Regarding the elimination of professional license for CE credit.
Professional licenses require a much greater education and knowledge requirement than a CE vendor could offer. For
example, the Series 65 (and related exams) require such an extensive knowledge of securities that a typical CE course
®
could not cover due to it being more of a overview. Eliminating these types of credits wil not only force CFP
[professionals] to spend more time and money on other accepted courses but these changes are not recognizing the
value of professional license education requirements.
Please take my comments into consideration when drafting the final changes.
RUSSELL TURNER,
®
CFP
Increased CE
I disagree with your statement that 20 hours per year is "standard" in other professional fields. My Federal tax license
(Enrolled Agent) works out to 17/year and for my real estate Broker's license (which I agree isn't necessarily considered
professional) much less. The other professional organizations I belong to require 30 for membership (NAEA, CSEA,
etc.) but the licensing entities are more often around 15.
I do agree that FP entails a much wider field of knowledge, certainly than real estate, but not so with US income tax
law. By the time you add in entities taxation and audit representation the field is huge.
Allowing practice management credits, which is VERY common with real estate, is a good idea, however, and might
improve the general field. Doubling the ethics requirement is problematic since the FPA doesn't necessarily offer
consistent opportunities there. I'm already required to take 2 hours each year for my EA. (I believe it is 4 hours every 4
years for real estate, and look where that got us.)
Maybe you could require the stock brokers and insurance agents to take 10 hours of ethics a year and keep it at two
for the rest of us. (just, you know, to improve the public's perception of the certification) Enjoy!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Ryan Hobbs, CFP
®
CE Proposed Change
Feedback
Page 173 of 379
Comment
1) I believe the current 30 hour requirement is more than sufficient in terms of quantity. What is lacking is the quality of
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curriculum. Each year I go through the monotonous task of collecting CE credits for insurance and CFP [certification]
requirements, most of which is so BASIC my 6th grader could do it. There are few if any applicable practice situations
discussed in the CE. Online classes offered through Reged, WebCE and others are nothing more than a read and
repeat formant and offer little if any lasting value.
®
2) Increasing the ethics hours is an attempt to legislate morality. If any CFP practitioner does not know and chooses not
to adhere to basic ethics - which is what 99% of ethics classes teach - taking double, or triple, or 100x the hours of
ethics will not increase adherence to an ethical standard. No matter how many additional hours of ethics a Madoff took
each year would not have prevented a cheat and a liar.
3) Cap rule & quality - These are the real issues. If quality is do be increased, a real practitioner needs to be involved
with course development with close attention paid to application. My recommendation would be a curriculum designed
by CFP Board that is progressive in its learning objectives. I agree that some repetition of material is important for
maintaining learning objectives, but the typical courses I've taken over the past 10 years take an hour to teach 10
minutes of useable material. I view this as nothing more than a waste of 50 minutes!
Sam Attalla, CPA,
®
CFP , Cr.FA(R)
Proposed Changes
First of all, thank you very much for sharing with us your proposed changes and asking us for comments.
®
As you are aware, several CFP [professionals], including myself, are holding other designations such as a CPA and
CFA. Changing the required CE from 30 hours to 40 and the ethics from 2 hours to 4 will be a great burden on us to
keep up with the continuing education needed; nevertheless, the associated costs we have to pay each year. I strongly
advocate the current CE hours of 30 and the ethics hours of 2 every two years.
Thank you and best wishes,
®
Melinda Sander, CFP ,
®
CRPC
increasing CE hour
requirment
My questions would be on the timing. Will there be a phase in for the change or will the increase become effective
immediately?
Sandra L. Hay
®
Magdaleno, CFP
Comment on CFP Board
proposed CE requirements
Many online courses are comprehensive and good. They are affordable and can be done on off work hours. I would be
disappointed to loose online self study courses.
CE proposals
I am against the proposed changes. As a practitioner with several licenses, I spend a great deal of time and money on
various CE requirements. Increasing CE is not going to help the unethical practitioners. It will, however, benefit the
providers that offer the courses. Enough, already. You are not the only organization with CE requirements. Spend your
time and money enforcing the guidelines on the unethical practitioners. That will benefit the public far more than extra
classes!
CFP CE Comments
I believe that eliminating CE credits for the completion of other designations would be wrong. These courses are
generally rigorous and build professional knowledge as well as, if not better, than most CE classes I have attended.
®
Additionally, we would be asking CFP professionals to then “double up” those hours in today’s environment where
one’s time is exceedingly valuable.
Sandy Bell, CFP
®
Don Schamay, CFP
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
R. Scott Curtis, CFP
Subject
®
Proposed CE increase
Page 174 of 379
Comment
I am against the proposed increase in CE hours required. I work for a large firm, and I feel "CE'd" to death. The time I
spend on regulatory and compliance issues is burdensome and getting worse year by year. Here are a few:
FINRA firm element
FINRA regulatory element
State life/health CE
CE to sell long term care insurance
CE to sell annuities (California)
CE to sell annuities in other states (no one recognizes California's CE)
Anti money laundering CE
CE to sell to old people
CE to treat people ethically (this should be part of your character)
The list goes on.
®
As a CFP [professional] I pride myself on staying up to date on my own regarding changes to tax laws, estate planning,
investments, etc. Usually, I am more knowledgeable than the test--yet I have to spend the time proving myself--time I
could be spending seeing customers.
The CFP board cannot act like they are in a bubble. They must take into account all the requirements we face day to
day just to conduct business.
Scott Holman III, CFP
®
CE Comments
The proposed changes under consideration are:
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations. The proposed increase in required hours is consistent with
recommendations from CFP Board’s 2007 and 2008 Education Task Forces.
30 hours are plenty, when you consider the amount of time this takes from earning a living. 40 Hours amount to one
entire work week! Any more than this is simply punitive. Many of us have other designation that require different
®
courses. I possess the following: CLU, ChFC, RHU, CFS, CFP [certification], GRI, CIPS, CRB, MRE. I also have CE
for my insurance licenses, Real estate licenses in multi-states, police license, etc. When added up, my CE requirements
can take 2 ½ months per year out of my ability to earn a living. Most courses already take twice as much time to
complete as the credit they allege to provide. PLEASE DO NOT INCREASE THIS ANY MORE. We are already subject
to the same classroom hours a full time student in college must take every year! (15 hours)
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
o Practice management CE programs. Defined as programs focused on the planning, development and management of
®
a CFP professional’s business operations, office management, business model design, budgeting processes and
leadership.
o Pro Bono (volunteer personal delivery of financial planning) services. These activities must be supervised by a
registered CE Sponsor organization and will be accepted for 1 hour CE credit per 4 hours pro bono service.
Agree.
Rationale: Recognize the importance practice management plays in the delivery of competent and ethical professional
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 175 of 379
Comment
financial planning services to clients. Encourage pro bono service for the public benefit.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.
Everyone know the ethics by heart by now. There is no reason to increase this, since we cover it every 2 years in depth,
plus the 2 hours class takes 4 hours to complete anyway.
• Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following:
o Participation in Registered Program Financial Planning Development ("capstone") course grading panels. These
activities must be verified with documentation of active participation, written assessments and qualitative feedback;
o Study Group Activities that meet certain guidelines;
o Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
Rationale: Encourage body of knowledge expansion and no cost CE opportunities.
Agree
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule."
Rationale: Ensure diversity of learning experiences across breadth of planning topics.
Agree.
• Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
Rationale: Recognize the quality control measures that regionally accredited institutions are required to incorporate in
the development and delivery of self-study courses offered for academic credit.
Agree, if this is in addition to and not replacing existing methods.
• Encouraging increased rigor and quality of all CE program delivery methods.
®
Rationale: Help ensure that CE programs available to CFP professionals contribute to their professional competency.
Disagree. There is nothing wrong with the systems of quality control as they currently exist. Continually adding this sort
of requirement is just a way to justify someone’s oversight occupation. There is no need to get carried away, when the
current system is working fine. Let the politicians in Washington add needless overregulation, not the CFP Board.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Scott J. LeClaire, CFP ,
ChFC
increasing continuing
education
Page 176 of 379
Comment
®
I would like to express my thoughts regarding proposed increases to the CFP [certification] Continuing Education
requirements.
As a financial advisor, I have significant continuing education requirements which are already imposed. In addition to
®
CFP [certification], I have continuing education requirements to maintain my ChFC. As a registered representative, I
must complete the Regulatory Element of Continuing Education, the Firm Element, Anti Money Laundering and Product
Specific requirements. Also the various state insurance department requirements for each state in which I am licensed.
When totaling the hours required for all of the above referenced requirements, one can see that the current total
required hours are not insignificant.
As we all know, there is only so much time available and my schedule is painfully stretched as it is.
In summary, I would request that you maintain the continuing education requirements in their present format.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Scott Illingsworth, CFP
Comment for Proposed
Revisions to CFP Board's
Continuing Education
Requirement
Page 177 of 379
Comment
I oppose the following proposed revisions to the Continuing Education Requirements:
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
• Eliminating CE credit for completing professional licenses and designation examinations.
• Reviewing on-line courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
While I am in favor these suggested revisions:
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
• Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship)
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours.
• Encouraging increased rigor and quality of all CE program delivery methods.
Essentially my view is summarized as follows:
I am a self employed financial planner/investment advisor. I spend a great deal of time not only servicing my
clients needs & questions, but also managing & operating my practice. I'm completely in favor with granting credit for
®
equivalent work/volunteer experience, as well as making sure that a CFP [certification] is engaging in high quality, well
rounded CE courses to enable them to maintain a high level of understanding of the strategies/regulations/and laws
effecting our industry. However, I am opposed not only to increasing the hours of course work required, but also
changing the criteria and delivery systems to which courses are currently offered.
As a sole practitioner my time is my most valuable resource. To maintain the high level of service my clients have
come to expect, I need as much flexibility as possible to address all items not directly related to client facing issues,
including CE course work. These rule changes that I oppose not only increase the time/demands to complete CE's but
®
also reduce/eliminate flexibility related to how/when CE's can be acquired. As with many of my fellow CFP
®
[professionals], the CFP [certification] designation is one of several licenses and designations that I've acquired over
my career. And it's not the only one that must be maintained requiring annual/biannual CEs. As a result, there are
times I feel the administrative burden and CE requirements of all that I'm subject to just maintain my
designations/licenses, can be overwhelming and taxing. I feel the current CE structure strikes a sufficient balance
between maintaining a reasonable education level and the flexibility of how/when courses are offered.
Thank you for the opportunity to submit my response to the proposals.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 178 of 379
Subject
Shawn P. Connolly,
®
MBA, CFP
CE Credits
Comment
I have reviewed the proposed CE credit and I am in favor of the proposed changes.
I feel the changes are very well thought out. They will be a welcome change to any
®
advisor that takes their CFP [certification] oath seriously and believes that ongoing education is
®
important. I strongly feel that all CFP [professionals] need to stay updated on the various changes
within our field. The CE requirement is an excellent way to ensure that we are
all educated to the highest level needed. It is my opinion that the increases and changes
®
presented are fair, reasonable, and provide each CFP [certification] with a balanced continuing Ed criteria
every 2 years.
A HUGE thank you to the people involved in drafting this proposal.
Mary S Shrode, CFA,
®
CFP
Sid Lorio, CFP
®
®
Continuing Education
I am against any additional load created by CFP [certification] continuing education requirements. It is already too high.
Comments
I believe the current requirement of 30 (2 hours ethics) is adequate for practicing CFP [professionals]. I do not need
additional coursework to describe changes in rules that affect my practice. With increasing regs from FINRA, state
insurance departments and my broker dealer, there is enough information for me to stay current.
®
Leave the current CE requirements at 30 hours.
Ron K Smith, CFP
®
Sonja Koppenwallner,
®
CFP
CE requirements
Please Do Not increase the required CE for renewal. This will not enhance the ability of the Financial Planner in my
opinion.
It simply makes for more paperwork and difficulty. The current 30 hour requirement should be sufficient.
Thank You
proposed changes
I am in favor of keeping the current CE requirements as is.
Seems like the proposed changes are requiring drastic changes.
Considering how much time we spend in the industry overall just getting our CE's, this seems to be a change that would
not be in our favor.
Please reconsider.
thank you
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 179 of 379
Subject
John T. Souther, CFA,
®
CFP
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Comment
®
I think being both a CFA designation holder & CFP certificant provides a unique viewpoint on this topic. The CFA
Institute does not have any required CE or PD (professional development as they call it) requirement. However, being
that the CFA designation is considered the “gold standard” of designations in the investment industry, many designees
take the on-going educational improvement of themselves quite seriously – you cannot stay competitive in the
investment world if you don’t increase your knowledge base. The difficult part of increase the CE requirement is that
®
most CFP certificants also are licensed or registered with other regulatory bodies (insurance, CPA, FINRA, SEC, etc.)
and most of these bodies have CE requirements and they for the most part don’t apply across entities.
My opinion is that increasing the requirements is not going to increase the ethical nature or the professional knowledge
®
base of CFP certificants from its current level. It is just going to provide an increased revenue stream to CE providers
®
& CFP Board as there is a filing fee for courses (I believe). The hurdle is already there in order to obtain the CFP
[certification] designation, increasing CE requirements are not going to weed out unethical or uninformed people.
Leave the requirements as they are.
Steven Louis Payne,
®
CFP
Terrible Idea
First you almost double the fees. Now you want to increase our burden with more CE requirements. What is going on
®
back there. Are you so out of touch with the average CFP [professional] that you have no idea.
Here is the current situation:
1) Bad economy, money is tight
2) Expenses for everything are going up
3) Heavy regulatory burdens for every aspect of the business
Now you want to compound this.
®
I'm actually in disbelief. Aren't you people supposed to be representing the CFP [professionals]? Why are you so
®
antagonistic against the average CFP [professional]. What did we do to you?
Stacy E. Phillips, CFP
®
First nearly a doubling of cost for renewal and now going to 40 hours. I am ready to non-renew my license. I actually
have to work for a living and you do little for my career at large cost to me over the year. I am going to start advising
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other professionals I know in this as well. I would think twice before taking time and effort to get my CFP [certification]
®
designation. If I had known how this would develop over the years not sure I would have ever bothered getting my CFP
[certification] designation. Really. Sorry but you drive people to think this. I use to be so proud to have accomplished
something and proud to show the designation below but you have driven me to where I am on the fence and don’t care
anymore. Negative in mind any more.
Well thanks for listening to my rant but sure it will fall on death ears as usual.
Take care
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Myron D. Stayman,
®
CFP
CE Proposals.
Page 180 of 379
Comment
®
I have held a CFP [certification] license for almost 16 years. You are correct that financial planning and management is
more complicated than ever before. As I work at a large firm, there are multiple opportunities to accumulate ce credits so
the 1/3rd increase in necessary hours does not bother me. Sorry to say that many of those credits are repetitive and in
some cases not very useful. Take taxes. I am inundated from many places with news, speculation and other inputs
about what is and what will be. Sitting in a room listening to information I am already familiar with is not a productive use
of time. I am also a CPA but since I am non practicing, do not have to deal with their requirements. I do have the CIMA
designation and their requirements often duplicate yours.
My real problem is Ethics. I have yet to participate in a single meaningful program on this subject. On occasion, there is
an entertaining speaker that can liven up a dry subject, but the usual format of reading cases and results doesn’t teach
me anything. So doubling the requirement to four hours strikes me as unnecessary and burdensome.
Thank you for reading this, my very first submission on any proposal.
®
Stefan Garcia, CFP ,
MBA
CE Proposals
I do not believe that increasing total number of CE hours required will result in better advice to clients. The CFP Board
must recognize that practitioners maintain a number of other licenses (insurance, securities etc.) that also require CE
and recertification testing and the burden simply continues to grow with new requirements in all of those areas. As a
single practitioner/owner of my own RIA and financial advisory firm, the ever-expanding amount of regulatory, CE, and
certification requirements, and costs associated with them, are a real burden and should give pause to you and to our
regulators when reviewing further expansions of requirements. I do not believe that an additional 10 hours of CE
requirement will have a material effect on the quality of service and advice to the public and, will in fact, hinder smaller,
independent firms from starting and growing their practices. I have no problem expanding the ethics requirement or any
of the other proposals, my only issue is with the total hours requirement. Thank you.
Deanne Stegeman,
®
agent, CFP , CPA
Proposed Ethics CE
expansion
As a licensed insurance agent I have to take 3 hours of classroom ethics CE every 2 years in addition to my required
®
ethics CE for my CFP [certification]
I submit my opinion that more CE in Ethics does not make me more ethical. Requiring more CE in this area won't
prevent unethical behaviors in my opinion, it just adds more cost to the certificant's practice and provides a revenue
stream for those providing the CE courses.
I propose that if you do increase the required hours for Ethics CE courses, that you allow the Ethics required CE for
other licensing apply to this requirement.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Stephanie L Mccarty,
®
CFP , FIC
CE for CFP
Page 181 of 379
Comment
®
I can see how this is a difficult task when there are so many financial professions who hold the CFP [certification]
®
®
designation. For us “newer” CFP certificants who have recently obtained the CFP [certification] designation I believe
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CE credits should be different than perhaps “old veteran’s” who have been given CFP [certification] designation 15-20
years ago & haven’t had to go through the rigorous study & exams that us newer certificants have.
®
Perhaps a “tiered” level would be appropriate based on years of holding the CFP [certification]. In my career I run into
®
many older CFP [professionals] who were “grandfathered” in or did not have to sit through the 10 hour exams I can tell
you that they appear to me to not be as astute with overall financial planning & suitability as those of us who have taken
the exams in recent years.
I know with my firm I already have to take Firm Element CE’s, Annual Compliance CE’s as well as State Insurance CE’s
®
– so I feel that if there is overlap that some of those should count toward the CFP [certification] CE’s.
Thank you for seeking feedback!
Stephen Barkhuff, CFP
®
Comment on proposed
revisions to CE
requirement
My comment is specific to the proposed increase in CE hours related to ethics. I support the increase in hours, but
would like to see the Board take steps manage the cost of those hours.
Certificants are a captive audience for ethics programming, and providers take unfair advantage of the situation by
pricing the programs much higher than other CE programs. I would like to see the Board take steps to directly provide
low-cost ethics programming, and to impose a maximum allowable cost per hour on other providers to ensure they don't
unfairly price their offerings.
I would be opposed to increasing the ethics hours without a pIan to manage costs. If nothing is done, the cost of ethics
hours will simply double from current levels. Certification costs have increased dramatically in recent years, and could
become a real burden to certificants with modest incomes unless the Board actively manages additional cost increases
moving forward.
Thank you.
Stephen Connolly,
®
CFP
CE credit
I recommend that the Board provide for reciprocity between practices when counting CE credits. If an individual is a
CPA and has CE requirements or an Insurance professional with CE requirements, or
®
Attorney with CE requirements, couldn't some of those hours be credited to the CFP [certification] CE? It seems that
®
those CE hours would address the same topic areas of CFP [certification] CE. The purpose is to provide
a well rounded education yes, however continuing to add rules, regulations and requirements smacks of the same things
we complain about from Washington. Quantity does not improve, Quality does.
concentrate on content.
STEPHEN HOURIGAN,
®
CFP
New CE Requirements
I believe the current CER should be left just as it has been. If we are are actively working in the industry we are
continually learning and studying.
Thanks for hearing me out on this subject, and please leave what is not broken just as it is now.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Stephen M Toner, CFP
®
Proposed CE changes
Page 182 of 379
Comment
The following are my views and not of my Employer.
®
The proposed changes will increase the costs dramatically for retaining the CFP [certification] designation. To be
truthful I may not be able to afford to maintain my designation as the costs would be paid out of pocket. Would it be at
all possible to have online CE (even at least for the new 4 hour Ethics portion that are available to take on the CFP
Board's website for free to help offset the increased CE hours expense?
Stephen P. Donella,
®
CFP
Steven Elwell, CFP
®
®
Steve TeSelle, CFP
Steve Gilbertson, CFP
®
CE Credits
Sure! Make it more challenging. The credential will increase in stature.
comments
Eliminating CE credit for other designations is not an idea I support. We should be encouraging our membership to
continue their education and other designations is a valid way of doing that.
Proposed Continuing
Education Requirements
I am writing to express my opposition to the proposed increase in continuing education requirements. I agree with the
CFP Board's statement that on-going changes in the profession require on-going learning, but I disagree that increasing
the hours for the continuing education requirement promotes that goal in any way. As it is, the current required hours
are more of an annoying checklist than a spur to on-going learning. In fact, the CFP Board might take note of the
Chartered Financial Analyst Program, which does not have a continuing education requirement at all. Rather, the CFA
Institute offers a voluntary program that is easy to use and for which there is no cost. In my opinion, the quality and
®
breadth of the learning materials is far better than what I've found in the CFP [certification] Program. We all need to
®
embrace life-long learning, but increasing the continuing education requirement for the CFP [certification] designation is
not a good way to promote that.
Proposal Regarding CE
I like the proposal for increasing the CE requirement. Specifically, I really like the eligibility of Pro Bono work for a few
credits of CE. I think there is a lot of value to doing this type of work in terms of continued development. Additionally, I
think it will make a positive impact in encourage more and more planners to participate in these types of valuable
initiatives. Thanks much.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Steven A. Boorstein,
®
CFP
Proposed changes to CE
requirements
Page 183 of 379
Comment
I do not necessarily agree with the boards proposed increase in CE requirements.
1. Other professions do not necessarily have more CE requirements. According to the CFP Board, the proposed
requirements are less than or the same as most other professions? Which professions are these? Most professions that
I know have the same or less requirements for CE requirements.
®
2. Most CFP [professionals] are also insurance licensed and also have securities licenses, which provide for
®
educational components that are similar to many CFP [certification] educational topics... however, many of these
®
®
courses are not CFP [certification] "approved" by providers for CFP [certification] credit. So this requirements
potentially means that many advisors will need approximately 10 SEC related courses, 24 insurance related credits (per
®
two years) plus 40 CFP [certification] related credits every two years. This seem excessive, unless the board institutes
the following point number 3, below...
3. If the Board decides to require this then they should automatically approve the courses that advisors must take that
are related to financial planning topics by their broker dealers as part of their yearly SEC requirements, as well as, those
that are required by state insurance licensing boards. So, for example in New Jersey, an advisor must take 12 insurance
credit CE's per year and must also take required CE to meet yearly compliance requirements with FINRA/SEC. These
®
should be able to be deducted from the 20 credit CFP [certification] requirement. The CFP Board should recognize that
a large proportion of practitioners often get the additional educational requirements that the CFP Board is proposing
through related licensing requirements in insurance and securities industries. Not doing so creates a huge burden on
®
these CFP practitioners who spend many, many hours per year fulfilling these similar requirements... but under your
proposed changes do no receive any credit for these educational activities.
®
4. Alternately, create a requirement that requires SEC/FINRA and insurance licensed individuals who hold the CFP
®
[certification] to obtain a smaller number of credit hours to renew their CFP certification than those who who hold no
®
licenses. This would properly ensure that CFP certificants who have no other annual educational requirements by other
related organizations get the proper education, while those who meet these annual educational requirements through
other means get recognition for these credits.
Steven Hollis, CPA,
®
CFP
Steven J. Coker, CFP
®
increase in CE hours
I disagree with an increase in the number of CE hours required. I have been in the industry for close to 30 years. We
already have increased compliance from the insurance and securities industries and we do not need to have over
®
compliance from the CFP [certification] as well.
Re: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I would like to ask that, if the Board is going to increase the number of continuing education hours we are required to
®
take, you not simulaneously provide a disincentive to course providers in providing credit to CFP practioners. For
example, the following course, by a most reputable provider (they are considered the premier tax information provider
here in California) provides CE credit to attorneys, Enrolled Agents, and tax preparers. It does NOT provide credit for
®
®
CFP [certification], because Spidell Publishing felt it was not cost effective to pay the fee required to register for CFP
[certification] credit. (The told me this over the phone today, when I asked why no CFP credit was offered.)
True, its their choice to pay the fee or not. Still, its a disincentive, and contrary to the goals you've stated to justify some
of the changes to the CE requirements.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Steven J. Coker, CFP
Subject
®
Comment on proposed
revision to CE
requirements
Page 184 of 379
Comment
I have reviewed the proposed changes, and would like to comment on each one.
#1) Increasing total CE hours from 30 to 40.
I agree. Many of us already take that many hours, either voluntarily or to maintain other licenses. The current
requirement is lower than many other license requirements.
#2) Grant CE credit for CE provider supervised pro bono activities.
I oppose. Providing such services does nothing to ensure competence, and while it would encourage such services,
meeting that goal should have nothing to do with CE requirements. It also favors one type of pro-bone service over
another.
#3) Increasing Ethics from 2 to 4 hours.
Unsure, because I don't know what "Ethics Programming" is. Personally, I already take 4 hours of non-CFP Ethics
eveny 2 years to maintain my federal tax preparation license . You should allow such "non-CFP" Ethics to be counted in
®
any increase in CFP [certification] Ethics requirements.
#4) Expand the activities that qualify for CE credit.
Unsure. It would seem like a logistical nightmare for the Board to handle.
#5) 50% cap rule.
Strongly opposed, more than any other provision. It completely ignores a practioners practice, experience, weaknesses,
and changes that are occuring within an individual field of study. We need flexibility in meeting our education needs,
and this runs completely counter to that.
#6) Eliminate CE credit for licenses/exams.
®
Opposed. How on earth can you administer the CFP Examination program, and yet say that other Examination
programs do not serve an educational purpose? It seems the ultimate in hypocracy.
#7) Reviewing online courses by accredited colleges/universities as "live" rather than "self study".
Agree.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 185 of 379
Comment
#8) Encouraging increased rigor.
Unsure. Description is vague.
I would also like to make some general comments. First, some of us have disabilities, which make running around town
difficult. The advent of online courses has been a godsend, and I hope you will do nothing to discourage their use per
your stated goal of "increased rigor".
Second, many of us have many licenses that we maintain. Personally, I have three different licenses. Each has a
different time period for meeting CE requirments.
(One's Jan-Dec., one's Nov.-Oct., and the third is May-April.) Some of us have new examinations to take. (I have the
®
RTRP exam pending.) While strengthing the CFP [certification] CE requirements seems a worthwhile goal, please
don't ignore the fact that many of use are already overwhelmed with complexity in meeting the needs we maintain those
®
licenses, and properly service our clients. Due to my month of birth, I'm already required to meeting my CFP
[certification] CE requirements by April 30, while also maintaining a practice that does a significant amount of tax
preparation work. If you're going to add complexity to CE requirements, will you at least give us an option to meet them
on a calendar year basis, or better yet chose the 2 year time period, rather than have it assigned to us?
Thank you for the opportunity to submit these comments.
Steven Reents, CFP
®
Suellen Savant
®
Hawking, MBA, CFP
CE Changes
I agree with all but one of the proposed changes. I think the number of hours should remain at 30 every two years.
My Comments
You cannot legislate Ethics. Most CFP [professionals] currently have to also take it for Insurance licenses etc. and firm
element training which often is not acceptable to you as CE. No problem with increasing to 4 if you will accept my other
ethics CE’s
2. I teach at a local community college. My class changes all the time to be current with tax and investment changes but
you will not allow me to use these hours as the name of the class doesn’t change.
3. I recently took a required insurance annuity 4 hr online course to satisfy my Illinois license requirements. I had to pay
Kaplan $20 to send me the certificate which they say is approved by you. I am still unclear whether I may need to pay
®
you another 25 to approve it. I pay enough to maintain my CFP [certification]. I would understand if the CE’s were
from a fly by night outfit, but you are making it increasingly more difficult for us to report CE’s for other requirements and
®
have them count toward CFP [certification]. Again this is specifically firm element and insurance CE’s.
4. How would you evaluate pro bono. Every year I participate in a local presentation through FPA for the public. Are we
on our honor for the time?
®
®
I usually have no problem with having enough CE’s to renew my CFP [certification]. This year in particular, however,
because there have been changes in requirements from the Illinois Dept of Insurance to take more CE’s, I have felt that
in addition to my increased dues (for public awareness) you are also trying to extract additional fees from me just to
report what I feel are very legitimate CE’s.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Susan Easthope, CFP
®
CE revision comments
Page 186 of 379
Comment
Dear CFP Board:
I believe you need to keep in mind the quality of the CE programs NOT the quantity. Many of us are also investment
advisors who have the FINRA compliance CE requirements that we must follow. I am spending a great deal of my time
in CE programs and I don’t feel I can devote many more hours to CE.
Thank you for your consideration.
Susan D Smith, CFP
®
Proposed changes: CFP
Board’s Continuing
Education (CE)
requirement
®
I understand the importance of maintaining high standards of education, ethics and competency in the CFP
®
[certification] profession. I am very proud to be a CFP professional. However, it's my opinion that the proposed
changes are only going to increase the burden on certificants. There are already innumerable changes in the regulatory
landscape. Adding ten additional hours of CE including 2 additional hours of Ethics won't change competency or ethical
behavior. It will increase the expense of practicing, again.
Your proposals for pro bono activities and research are confusing and out of touch for the small firms with limited staff
®
and resources. Many CFP practitioners specialize in specific areas, why cap CE credit in a single topic during one
renewal period? A practicing professional will cover almost all areas of financial planning during the year working with
clients.
I utilize the online self study CE exams offered by the current registered CE providers. I learn from these programs, they
are also convenient and low cost. Smaller firms and professionals are being forced out of the industry because of
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regulations and expenses. The CFP certification fees have doubled. SRO fees have increased. Compliance fees
have increased. Has fraud or unethical behavior declined, has competency improved? NO.
Michael A. Bell, CFP
®
Comments
Thank-you very much for everyone's long, hard, and well-thought-out work. You are to commended on your very
professional approach and dedication.
Below are my personal comments:
The proposed changes under consideration are:
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations. The proposed increase in required hours is consistent with
recommendations from CFP Board’s 2007 and 2008 Education Task Forces.
• Additional CE hours are not necessary for maintaining competency. 30 hours are plenty for accomplishing this
objective. Ascertaining "quality", rather than "quantity" should be the goal. The additional hours could also prove
burdensome.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
o Practice management CE programs. Defined as programs focused on the planning, development and management of
®
a CFP professional’s business operations, office management, business model design, budgeting processes and
leadership.
o Pro Bono (volunteer personal delivery of financial planning) services. These activities must be supervised by a
registered CE Sponsor organization and will be accepted for 1 hour CE credit per 4 hours pro bono service.
Rationale: Recognize the importance practice management plays in the delivery of competent and ethical professional
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 187 of 379
Comment
financial planning services to clients. Encourage pro bono service for the public benefit. Good idea to recognize such
admirable service. However, not if it is used to justify an increase in required CE hours. These should be recognized
based on their own merit.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge. I do not agree that an increase from 2 to
4 hours is the most effective means for creating an increased emphasis on ethics knowledge. That 2-hour course covers
an enormous amount of ethics material. Again, efforts should be made to review "quality" , rather than "quantity".
• Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following:
o Participation in Registered Program Financial Planning Development ("capstone") course grading panels. These
activities must be verified with documentation of active participation, written assessments and qualitative feedback;
o Study Group Activities that meet certain guidelines;
o Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
Rationale: Encourage body of knowledge expansion and no cost CE opportunities. Agreed.
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule."
Rationale: Ensure diversity of learning experiences across breadth of planning topics. Agreed.
• Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible. Disagree.
Why not give credit? Doesn't it meet our strict qualifications?
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
Rationale: Recognize the quality control measures that regionally accredited institutions are required to incorporate in
the development and delivery of self-study courses offered for academic credit. This needs some more clarification.
What does this mean? I thought that such courses are already regularly reviewed in order to ascertain compliance with
®
CFP [certification] course requirements.
• Encouraging increased rigor and quality of all CE program delivery methods.
®
Rationale: Help ensure that CE programs available to CFP professionals contribute to their professional competency.
This is unclear and too general in description. What does this mean? This is a very broad statement that requires
greater clarity, including examples nd specifics.
In general, I am suspicious of attempts to increase the number of required CE hours, but then attempting to allay those
suspicions by qualifying more areas for such CE work. The number of hours is plenty to serve the purpose. I think time
would be better spent ensuring the quality of online CE courses.
Thank-you for all your work.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Tamara E Williams,
®
CFP
Subject
CFP proposed changes to
CE
Page 188 of 379
Comment
I am not in agreement with the proposed changes to the CE requirements.
Being a CPA, I would like to see a universal acceptance of CE credit that is CPA approved. It is much more confusing
than it needs to be obtaining the appropriate CE for all licenses. The purpose here is to obtain quality continuing ed, not
to force the licensee to juggle between CPE sponsors.
Also, maybe you should considered lessening the CE requirements for CPAs due to their strict CPE requirements and
®
enforcement. Having the CPA certificate only gives creditability to the CFP [certification] title. But, the CFP board is
®
making it increasingly more difficult on the professional CPA to be both. You supposedly want the CFP [certification]
®
title to have creditability. However, due to increasingly harder CE burdens, you are forcing your CFP [certificants] with
®
other professional designations to consider dropping their CFP [certification] title. This would in fact lessen the
®
creditability of the CFP [certification] title if you lose all of those licensees with other professional designations.
Also, I do not think the 50% in one area rule would serve the public. Some areas of practice have a lot of current law
changes requiring much more study time and updating in that area. Other do not have law changes, and a course in
them would be mostly a review of correct mehtods and theory. How would lessening the concentration in areas that
have frequent law changes serve the public better?
I do not know how increasing the ethics CE would actually help serve and protect the public. It seems to me that this
®
would just serve to force the CFP [professionals] to juggle hours around.
®
Tedd Bell, CFP
Feedback on CE
requirements
First you double the fees we pay, now you are increasing the CE requirements. I believe you are exercising overkill for
®
the CFP [certification] designation. The 30 credits, including the ethics course, are a good balance of industry
knowledge and reminders of our responsibilities. Leave the CE program alone.
Terrie Zitzelsberger,
®
CFP
Comments on Continuing
Ed
While I think it is good to review the continuing ed requirements, I think making them too restrictive, such as not allowing
for self-study, is not good. Remember, practitioners have businesses to run as well, and most of us also have
continuing ed for other designations/licenses--for example insurance. I think insurance credits should be recognized
®
®
under CFP [certification] credits--also 30 hours every 2 years plus ethics is good. 2 hours of CFP [certification] ethics
should cover what is needed--if someone is going to be dishonest forcing them to take 2 more hours of ethics for CFP is
NOT going to change that! I also have 2 more hours of ethics I have to complete for my insurance license, can these
count towards the 4 hours?
Increasing it to 44 hours (40 plus 4 ethics) requires more than a FULL work week to complete---this is excessive. Most
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CFP [professionals] keep up on what is going on out there without having to necessarily take courses to comply with
the credit hours---we read many different trade magazines, etc. that do not "qualify" as continuing ed hours, but serve
the same purpose.
Funny, attorneys are rarely required to do continuing ed.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Terry Kilgore, CFP
Subject
®
Ce Comments
Page 189 of 379
Comment
I make the following comments on the two issues below:
1.
Eliminating CE credit for completing professional licenses and designation examinations. Rationale: Inconsistent
with professional certification program best practices. Program content or coursework may be eligible if consistent with
CE topic and other requirements. Exam prep or review courses remain ineligible.
•
I support this change but want to emphasize that the above retain “program content or coursework may be eligible
if consistent with CE topic and other requirements.”
2.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Boardproduced Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved
programs on CFP Board's Standards of Professional Conduct and general ethics-related content. Rationale: Results
®
from CFP Boards 2009 Job Analysis Study, which is the basis for CFR Boards CFR Examination and Education
curriculum, reflect an increased emphasis on ethics knowledge.
•
I do not support this change, and I do not believe the rational given is sufficient for change. How much is enough?
I understand the need for the profession to know what is ethical and adhere ethically in all its practices; however, I don’t
believe that an additional two hours of ethical knowledge will have a significant impact on ethical behavior. I believe it
adds additional financial and time burden that is not justified.
Thank you,
C. Theodore Hicks II,
®
CFP
Comments on CE changes
Increasing CE requirements is no different. It is simply another component of regulation. ... And I'm tired of it!
While ultimately, I agree with the sentiment that the world we are operating in is ever changing and the serious
practitioner needs to stay abreast of them, I can not support further regulations to mandate practitioners to "learn" more.
Serious practitioners are going to stay abreast of the changing environment whether you want them to or not. That is
certainly the case with me and my practice. However, when I learn something helpful, it is rarely a result of a CE
course.
To think the current CE requirements are actually helping practitioners sharpen their sword is a bit misguided as it is. I
am so busy filling out compliance forms due to Over-regulation/burden, that I have little time to do anything else. If I
were to estimate it, I'd estimate that 90% of all the CE classes I've ever taken have been a complete and utter waste of
my time and money. Quality "continuing education" is rare. While the world is ever changing, CE courses being offered
is not. And even if they were changing, there is such a dearth of quality classes out there that I'd still be stuck
attending/paying for classes that teach me that 1 + 1 = 2.
As for the proposed change to allow CE credits for practice management courses, that makes sense to me. I would be
supportive of allowing CE credits for these types of courses and learning opportunities. I have found these types of
classes far more valuable than the typical CE course.
Finally, while I have your attention, I would be remiss if I didn't say that I'm disappointed that I am not seeing the CFP
Board more out-in-front when it comes to some of the issues on the national stage. The fact that we have such a huge
fiscal problem in this nation is a great opportunity to let the nation know that there are trained professionals that
understand these fiscal issues. Ultimately, as practitioners we know that an entity can not spend more money than they
bring in and expect to avoid bankruptcy. This nation is on the verge of bankruptcy and I have seen little efforts from the
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 190 of 379
Subject
Comment
CFP Board to influence this fiscal conversation. I pray that the CFP Board will become more of an outspoken voice in
the coming months.
®
Thomas Lampert, CFP
CE proposed requirement
®
To the body proposing CE changes to the CFP practitioners,
I want to thank you for the tireless effort you put forth into keeping those of us with the designation practicing at a higher
standard and holding up the marks with a greater reverence.
One comment I would have would be in relation to CE credits for ProBono work is how would it work for example, if I
volunteer for a National Organization, Love INC, and give budgeting help or lead a class on budgeting and personal
financial planning, but they are not a “CE Sponsor Organization”, or even if they were, how would the “supervision”
actually be carried out in practical terms? Or on a different note, I am a Dave Ramsey Certified Counselor as well and
often do “pro bono” work. How would I know if they are CE sponsored, or how would they even “supervise” any pro
bono work in terms of financial planning ideas that I give? I don’t directly report to Dave Ramsey’s organization but I am
an independent counselor for people who want to meet to discuss various strategies on cash flow planning and planning
for other goals for the future. Please advise as to how this would work on a “supervised” level as there is no one who
“supervises” me on this.
Thomas Meachum,
®
CFP
New CE proposed rules
Below are my comments regarding the proposed CE rules:
I am not in favor of increasing the CE requirements to 40 hours. I object to the large increase in particular, moving from
30 hours to 40 is a 33% increase, which seems extreme. I would support a more moderate increase from 30 to 33
hours and perhaps phasing the increased CE requirements in over a multi year period. This would also place a greater
financial burden on many practioners, some of who might not be able to meet the increased cost of training.
I also feel the 50% cap by subject matter area is unfair. Many practioners are weak in particular subject areas and might
need to elevate their skills during particular renewal periods. This cap might hinder their progress towards obtaining the
needed training. Certain practioners may also concentrate in particular areas, like insurance or investments and,
therefore, might not need or use a great deal of the subject matter they would be required to learn just to obtain a CE.
This could prove to be quite costly and expensive for certain practioners.
®
I would also reconsider the practice management CE issue. Many CFP [professionals] are employed by broker dealers
and similar arrangements where most of the practice management processes and procedures are provided by other
personnel. Therefore, being granted credit for continuing education only serves a few and seems to address special
®
interests and not the larger body of CFP [professionals]. I favor only granting CE's for the discipline of the financial
practice only, which is the core of all of our businesses.
Thank you for your thoughtful consideration.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Thomas Noble, CFP
®
Page 191 of 379
Subject
Comment
RE: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I am opposed to the proposed changes. As someone who makes his living primarily as a family law attorney, I find it
®
consistently difficult to get my CE hours for my CFP [certification] license. Maybe I just don't know where they are, but I
find few live courses in my physical location that are acceptable to the CFP Board. I usually get my hours via estate
planning courses, and I always have to pay for approval, which I find absurd. The cap would prevent that. If the new
changes are implemented, I will probably drop my license.
In my opinion, the CFP Board should spend its time trying to figure out how to best offer more courses, instead of just
raising the bar.
I see no rationale for increasing the hours or the 50% cap. How is that going to improve the profession?
Thomas J. Stimler,
®
CFP
Proposed CE requirement
changes
I do not think the hours need to be increased. 30 every 2 years is enough.
You should award hours for practice management, even now.
Do not increase ethics to 4 hours. If you are ethical, 1 minute is enough. If you are unethical, 1,000 hours is not
enough. Get it?
You should allow professional activities to count, even now.
Do not limit with a 50% cap rule by topic. Why are you trying to make this so confusing and difficult?
You should not limit CE for anything.
Do not waste your time reviewing courses.
The rigor does not need to be increased.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 192 of 379
Subject
Thomas Sutton, CFP
®
Nothing to do?
Comment
What are you thinking? If you do change the CE requirements then you need to allow carryover CEs from the previous
two years.
What I’m required of now?
1) I’m required to have CEs for my insurance licenses (They allow carryovers).
2) CEs for my securities licenses under FINRA Regulatory Requirements.
3) CEs for my broker dealer for the firm’s element requirement.
®
4) CEs for my CFP [certification] and code of ethics. By the way your rules and regulations are getting way out of
control.
®
Now you want to add more rules and regulations for my CFP [certification] CEs?
This isn’t a contest about who can have the most complex CEs so you can justify
®
®
your job…”Look at me I made it harder for CFP [professionals] to be CFP [professionals] with more burdensome and
complex regulation for taking CEs.”
I’ve also spent the summer trying to get into compliance under the Dodd-Frank Act.
Plus if Mitt wins in November the Republicans are going to throw out Dodd-Frank and have no regulations at all.
Then all the CEs will change again because the Republicans have to justify doing something-just like what you’re doing
now.
These new requirements cost me money. Do you think about the money I have to pay for all these CEs?
DO I HAVE ANYTIME TO DO MY JOB?
I say NO to your self-serving new CE requirements!!!!!
Tom Taggart, CFP
®
proposed changes to CE
I do not agree with increasing the total CE hours from 30 to 40 every two years.
I am in agreement with the other proposed changes.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Thomas Dufresne,
®
CFP
James Thomas, CFP
Tim Callan, CFP
Page 193 of 379
®
Timothy A. Knotts,
®
CFP
®
Comment
Change to CE
requirements
The increases in required credits is a joke. Increasing CE credit requirements from 30 to 40 hrs and thinking that will
®
make a difference is not going to make me more profesional - do you really think any CFP [professional] can stay
current and competitive by spending 40 hrs every two years on proffessional development? Do you think anyone will be
more ethical because you raise the CE ethics credit requirement from 2 to 4? While increasing CE requirements may
make the Board feel better, as a practical matter it only creates business for the Companies who offer CE credits and
gives us and you more credit hours to track. We have enough of this nonsense with state insurance depts - do you have
to make it worse?
CE Comments
I think the 4 hours of ethics is excessive. The two hour courses were extremely boring and it was difficult for instructors
to fill the time. Most had to resort to role playing, which was in most cases was a waste of time. Unlike the other subjects
where changes take place and it is important to stay current, ethics doesn’t change. You hear the same thing over and
over. More hours will not make people more honest.
ce requirements
I would like to see more focus on high net worth individuals ($5mm+) for the CE. If you are going to increase the
requirements, more focus on issues pertaining to these individuals would be helpful. I.e., more advanced estate
planning, insurance, and tax minimization techniques. I find that much of the focus is on lower net worth issues which is
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not an area that most CFP [professionals] participants focus on in our respective practices.
CE Requirement Proposed
Changes
I agree with all the proposals with the exception to the one below:
1. Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming - DISAGREE
®
I don’t believe subjecting CFP certificants to more hours of ehtics education will make those that are already trying to
comply with all of the regulatory and certificant requirements any more ethical than they already are.
Tim Lewinski, CFP
®
CE Changes
®
After reviewing the proposed changes for the CFP [certificants] CE Program, I wanted to share a brief comment
regarding the proposal to increase the required CE hours from 30 to 40 hours. The stated rationale for the change was
the fast changing personal financial planning knowledge and practice resulting a greater need for CE. I agree with the
rationale but do not think an increase in CE hours is the solution.
We work in a competitive industry and the complexity of the market and client needs are increasing. The winners and
losers in our profession will be dictated on our ability to deliver exceptional advice and services at a reasonable cost.
Pressures from client and prospects (the market) will encourage us to pursue the knowledge and skill needed to be
successful, not a 30% increase in CE credit hours.
I encourage you to maintain the 30 hour requirement.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Timothy M. Montague,
®
CPAÒ, MT, CFP
Feedback
Page 194 of 379
Comment
I agree with most proposed changes to the CE requirements, except for the proposed change to 4 hours (from 2) for the
ethics course. This seems excessive with little benefit to be gained. Otherwise, the other changes seem reasonable.
Sincerely,
To Whom It May Concern:
I agree with most proposed changes to the CE requirements, except for the proposed change to 4 hours (from 2) for the
ethics course. This seems excessive with little benefit to be gained. Otherwise, the other changes seem reasonable.
Tim Voegele, CFA,
®
CFP
®
Tim Wilcox, CLU ,
®
®
ChFC , CFP
Proposed CE requirements
Current CE requirements are more than sufficient. There is no need to change them.
Proposed changes to
Continuing Education
Requirements
I feel that these changes are unwarranted—especially in this time of massive legislative changes going on in our
®
industry now. I would suggest that this be tabled for 2 years for more research and study. In addition to all of the CFP
[certification] CE, I must manage a significant amount of time related to my Firm Requirement for FINRA, individual state
requirements related to insurance licenses, and a significant amount of time related to our company’s mandate for
Compliance Meetings, required CE for my Financial Advisor practice, and assessments related to my company’s and
other companies’ required testing for various products and services.
My personal opinion is that the good people on the CFP Board do not fully understand the time commitment required by
professionals actively in practice in our industry.
My “vote” is NO, ABSOLUTELY NOT; this is a “SOLUTION IN SEARCH OF A PROBLEM”!
®
Timothy (Tim) Shank,
®
CFP
Due to the fact I have to spend so some much time and money on compliance and CE for CFP [certification], state
®
insurance licensing, firm element, etc. I am seriously considering dropping my CFP [certification]. These new changes
will make the decision easy for me.
Terrence J. Moran,
®
CFP
I am OPPOSED to the proposal to increase the required CE hour requirement. I would rethink my commitment to the
organization if any such increase took place and would likely consider giving up my certification that I have had since
1989.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Tom Nardozzi, CFP
®
Comments regarding
proposed CE requirement
changes
Page 195 of 379
Comment
Just a general comment…
I’d like to see the CFP Board be more cognizant of free continuing education opportunities. There are so many free
publications / events / etc. where we are clearly gaining knowledge and continuing our professional designation. I don’t
think anyone would have a problem doing 40 hours of continuing education over a 2 year period. Most of us do that
every few months if we want to stay relevant. I do, however, have a problem with the unstated requirement that some
CE has to be non-free. This can be witnessed in the board’s own publications for their free webinars. It makes no
sense that we’d sit through and participate in a 90-minute webinar regarding ethics practices and new requirements /
policies / etc. without getting credit for continuing education toward that topic. The announcements for webinars state
that the event will be “Free Event (No CE granted)”. I don’t see how “free” and “no CE” fit together. If the Board wants
us to do more reported CE in more diverse areas, I’m all for it. If the Board wants us to spend even more money
maintaining certification, especially after hiking dues the way they did, I don’t think that’s fair. Let’s make this about
maintaining knowledge across the key disciplines, not about money.
Thanks for your consideration.
Tom Santi, CFP
®
Comments on CE Changes
The rationale outlined for increasing the hours to 40 seemed weak. Why 40 and not 35 or 100? If the Board desires to
increase the hours and based on the other proposed changes the Board has presented, perhaps the Board should
®
create and administer its own mandatory CE program and require every CFP [certification] licensee to take that
®
program every two years. This would fit better with the Board's objective of CFP [mark]'s remaining competent and
ensuring ongoing learning in the fast changing environment. Otherwise, it's too easy to take courses and accumulate
hours that don't meet's the Board's objectives. Some of the CE courses I've taken don't seem change related and are
much more academic than practical from my perspective. Having it's own mandatory program would give the Board that
®
much greater control over what courses CFP [professionals] are taking and how relevant that material is.
I'd be opposed to expanding the required ethics hours. At some point, people are either going to act ethically or they are
not. Requiring people to take more hours isn't going to weed out the bad apples. Personally, I think it would help if the
Board simplified the code of ethics to make it easier to follow.
Allowing CE credits for practice management is a great idea. Running a practice better benefits the clients, employees
and the profession and I'm very pleased to see the Board move in this direction.
I'm opposed to the CE for pro bono work. That doesn't seem consistent with the Board's stated objective of ongoing
learning to maintain competency in a fast changing environment. The Board should look for other ways to promote pro
bono work, but it is not a CE related activity. Likewise grading and research alone don't seem like CE related activities.
The 50% cap rule seems to create a level of CE complexity that is uncalled for. And excluding conferences only adds to
the complexity and certainly makes the attainment of CE much easier for those who can afford conferences vs. those
who cannot. Some should not be more equal than others relative to CE attainment. I'd hate to have my license revoked
®
because a course was reclassified or prorated differently than I thought and thus I violated the 50% cap. Also, if a CFP
[professional] primarily focused their practice on one area, based on the Board's stated objectives for increasing the
®
hours, it would make sense that such CFP [professional] could largely concentrate their CEs on their area of practice.
I'd much prefer to see an extension of the current process where you have to take at least 2 subjects plus ethics. Maybe
expand that to 3 subject areas instead of some arbitrary cap. But please, keep it simple and easy for us who work so
hard to meet the CE requirements.
I found the following two changes rather vague and hard to understand. Greater Board clarity on the details of these
proposed changes would be helpful and could elicit better comments.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.” Rationale: Recognize the quality control measures that regionally
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 196 of 379
Comment
accredited institutions are required to incorporate in the development and delivery of self-study courses offered for
academic credit.
• Encouraging increased rigor and quality of all CE program delivery methods.
®
Rationale: Help ensure that CE programs available to CFP professionals contribute to their professional competency.
I'm not sure if this is your intention with the "Review online courses...", change but please don't eliminate self-study CE
options. Once again, not all of us can afford the time or cost to attend conferences and live CE programs.
Overall, the changes seemed like a smorgasbord of ideas, not all consistent with an overriding CE objective. I'd
encourage the Board to vet each proposed change against one or two high level objectives for the CEs. If the change
doesn't meet the objective, don't make it.
Thanks for providing the opportunity to comment.
Tom Whitehurst, CFP
Tom Williams, CFP
®
®
CE
I encourage the board to keep the current requirements in place. Planners that care will far exceed whatever hours are
needed; "planners" that don't care will find a shortcut either way. There is already enough bureaucracy in the various ce
®
that most of us have to meet between CFP [certification], insurance, FINRA, firm requirements etc.
Proposed Changes
I have read, agree, and support the proposed revisions to the CE credits for CFP [professionals]. Thank you,
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Tom Zachystal, CFA,
®
CFP
Feedback on ethics CE
Page 197 of 379
Comment
Regarding the following:
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.
My comment is that it is already difficult to find meaningful and interesting ethics CE courses. I find myself each year
taking more or less then same ethics course just to get the 2 credits. Also, the courses are often quite expensive for
what they are – for example, there is only one 2-credit CE course available through FPA and it costs $110.
So I would suggest the following:
1. I don’t think it is at all necessary to increase the required number of ethics CE credits since the associated material is
quite limited.
2. However, if there is an increase, I would suggest expanding what qualifies as ethics CE so that certificants wouldn’t
have to repeat the same courses just to get credits.
3. Furthermore, since CFPB sets the ethics standards, it would be great if there were available CFP Board ethics
courses through online delivery at a reasonable cost. Preferably more than one option for reasons mentioned above.
Tracey L. McLain, CFP
®
RE: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I disagree with the proposed changes. Do you realize how hard it is to keep up with all the education requirements for
all of our licenses. For those of us who work for firms, we have many firm required courses to take throughout the year.
I have 6 on my calendar right now and I have already taken several this year. As far as I know, none of these will qualify
®
for the CFP [certification] requirement. We have to keep up with insurance licenses for as many states as we are
registered and now there are also specific annuity training courses specific to different states. For some of us, we are
also have management duties which add another layer of continuing ed.. Quite honestly, all of this continues to take us
away from what we should be concentrating on...our clients.
CE comments
I agree with all of the purposed CE changes, except getting rid of “self-study” CE programs, in this very fast paced world,
traveling for work, home life etc.. Doing away with self-study CE doesn’t make sense, not to mention that is how many of
®
us CFP [certificants] studied and prepared for the CFP exam in the first place
®
CE Requirements
I support the proposed Continuing Education Requirements.
®
CE Comments
I think work towards other designations should still count. I am currently in the CFA program and there is a lot more
work to it than the credit currently granted…
®
Travis Burke, CFP
Michael P. Truitt, CFP ,
®
CRPC
Todd R. Tweedy, CFP
Thanks,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Tyler G. Tredway,
®
®
CFP , ChFC
CE Feedback
Page 198 of 379
Comment
It is understandable that all programs need to be revisited periodically for the purpose of making improvements.
However, increasing hours based in part on what other industry groups do is not improvement. I would hope that the
CFP Board would choose to lead by improving the quality of the CE hours rather than increasing them. In a world that
continues to take our time, energy and resources we don't need another institution demanding more from us, especially
those of us who have already logged tremendous hours through the years handling CE hours and personally chosen
professional development.
®
It will also be helpful to have more flexibility and clear communication for which hours count for CFP [certification] CE.
I appreciate the job the CFP Board does overall in holding up high standards in a world of lessening standards.
Jaymie Upton, CFP
®
CE Ethics Requirements
®
I suggest that the CFP Board should produce the Ethics Courses & offer them free-of-charge to CFP certificants.
They are not easy to find, and I don’t think we should have to pay for them.
®
It would offer us a value-add for the increase in the CFP [professional] fees.
I’m fine paying for the other CE classes & finding them independently.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Christopher J. Asher,
®
CFP
Subject
Proposed Revisions to CFP
Board's CE Requirement
Page 199 of 379
Comment
I feel compelled to comment regarding the proposed revisions to the CFP Board’s continuing education requirement.
®
®
The first issue relates to obtaining CFP [certification] designation. In my experience the process to become a CFP
®
professional lacks rigor. You have a financial incentive to increase the size of the CFP [certification] pool of
professionals – especially with the recent change in dues of $325 bi annually to annual. While I support continuing
®
education for those of us in practice, my sense is it’s much too easy to become a CFP [professional].
I don’t have an issue with an increase in CE hours from 30 to 40, although I strongly recommend that qualifying
continuing education be substantive. Practice management programs have nothing to do with the practice of financial
®
planning. Awarding credit for practice management courses should be prohibited. I don’t know of a CFP [professional]
that doesn’t provide some advice pro bono. I believe this to be a moral obligation. Credit for pro bono activity is a nice
concept, however the requirement that the activities be “supervised by a registered CE Sponsor organization” is flawed.
®
This sounds like the registered CE sponsor organization stands to profit and CFP [professionals] will have to jump
through hoops to prove they’ve provided pro bono work.
®
Ethics are important and should be stressed when testing to become a CFP [professional] as well as once the
designation is attained. Doubling the ethics requirement to 4 hours makes sense.
I don’t think any professional activities ought to qualify for CE credit. Continuing education is just that – more education.
Whether you are the teacher, author, panelist, doing research, or in a study group this isn’t continuing education in my
opinion.
®
The 50% cap rule is logical. All CFP [professionals] need to be well versed in multiple planning topic areas - regardless
of the focus of their practices. Exempting conferences from the cap rule is a mistake. I suspect these conferences are
lucrative and you want to encourage participation, however no exemptions should be permitted.
Too many inferior designations have surfaced in recent years. While some of the program content is consistent with
®
CFP [certification] CE topics, the CFP Board ought to review each designation and determine what, if any, of the
®
course work should apply to continuing education for CFP [professionals].
Favoring live CE programs vs. self study has merit, however I’m skeptical that the motivation to do so is in fact to
increase the rigor and quality of the course work. Self study and online courses are essential to those of us with very
little time.
®
The process by which you contribute to my professional competency starts with the awarding of the CFP [certification]
®
designation. I believe it’s much too easy to become a CFP [professional]. Once we’ve attained the designation I
welcome the attempt to improve upon our continuing education. Requiring an increase of time, expense, and effort to
®
improve my competency ought to be clearly beneficial as we strive to fulfill our CE obligation. While proud to be a CFP
[professional], I don’t feel as if the planning Board has done anything meaningful to enhance the educational experience
®
or market the CFP [certification] designation to the public. Please prove me wrong with your future actions. Thank you
for reading my suggestions.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Joseph Catanzaro,
®
CFP
Subject
CFP proposed CE
changes
Page 200 of 379
Comment
COMMENTS ON PROPOSED REVISIONS:
Keeping up with established professions (architecture and law) is difficult and yet well thought of. CE that matches or
comes close to established professions is not the only way to alter the public perception of our wonderful designation. It
®
helps but the public does not know the number of required hours necessary for people to maintain CFP
[certification],CPA, MD, Architecture, etc nor do they care. Having a Board that “watches over us”, I believe, helps
validate our profession. Continuing to spread the word to the public that we are being watched like CPA, MD and etc. is
a great way to tell our story.
1. You indicate we are consistent with or below similar professions. Which ones are you trying to compare to? If you
are trying to compare to ones where we are consistent with already, then leave it at 30 hours. The additional 10 hours
are a lot. I believe people that obtain CE in the format that it is intended are getting the topic diversification and
education necessary to stay on top of the fast-changing knowledge and practices. The people that get the hours in any
way possible are going to continue to work the system the same way. I believe the number of hours (30) is adequate.
2. I love the idea of practice management programs count for CE. The rationale is spot on. Providing an incentive for
Pro Bono work is very helpful to our society and should be rewarded as long as people doing the work have the intention
where volunteering is first and not CE. Nothing is worse than volunteers sitting around doing nothing.
3. This item can only help our industry. I support this increase and would support an increase of 2 hours (going to 32) to
make this happen.
4. This topic is a bit vague. This seems a bit self-serving to CFP Board and I understand the value in it. When I
completed my exam, I was extremely pleased to sit in on test question development. It was very eye-opening. Yes, I
received credit. I guess if that is the only way to get people involved then providing an incentive should be done.
Study Group items needs more explanation and guidelines determined. Too vague.
Research – same as study group above.
5. The 50% rule makes sense and helps curtail people from getting credits just to get credits. I like this as it will help
with diversification of topics.
6. I believe the time involved to pass a license should be recognized by CFP Board. I did self-study of Series 65 and 24.
Both took a lot of study time. To not be given hours toward CE is wrong. Different licenses should earn different hours.
The designations you earn for sitting in a classroom for a day should NOT earn any hours of CE. Earning a designation
from the American College for something like ChFC which involves 10 courses and exams should count for CE (as you
indicated below). My suggestion would be to indicate a list of preferred designations and licenses that earn CE. Any
others need approval from CFP Board.
7. This makes sense.
8. If you are considering making CE as difficult as licensing or other major designations, then I disagree. CE’s role is to
sharpen skills already in place and peak interest in areas that are new or not common knowledge to a person. Then,
that person can dive into a more intense course for their own betterment. Earning more CE from that extra course load.
Making a person put in more hours than getting credit for in order to earn CE is not the intent of CE requirements.
++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++
The proposed changes under consideration are:
1. Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations. The proposed increase in required hours is consistent with
recommendations from CFP Board’s 2007 and 2008 Education Task Forces.
2. Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period. Practice management CE programs. Defined as programs focused on the planning, development and
®
management of a CFP professional’s business operations, office management, business model design, budgeting
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 201 of 379
Comment
processes and leadership.
Pro Bono (volunteer personal delivery of financial planning) services. These activities must be supervised by a
registered CE Sponsor organization and will be accepted for 1 hour CE credit per 4 hours pro bono service.
Rationale: Recognize the importance practice management plays in the delivery of competent and ethical professional
financial planning services to clients. Encourage pro bono service for the public benefit.
3. Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.
4. Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following:
Participation in Registered Program Financial Planning Development ("capstone")
course grading panels. These activities must be verified with documentation of active participation, written assessments
and qualitative feedback;
Study Group Activities that meet certain guidelines;
Research. Research may address future trends in financial planning beyond CFP
Board's current lists of Job Task Domains and Principal Topics.
Rationale: Encourage body of knowledge expansion and no cost CE opportunities.
5. Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of
total required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule."
Rationale: Ensure diversity of learning experiences across breadth of planning topics.
6. Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
7. Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
Rationale: Recognize the quality control measures that regionally accredited institutions are required to incorporate in
the development and delivery of self-study courses offered for academic credit.
8. Encouraging increased rigor and quality of all CE program delivery methods.
®
Rationale: Help ensure that CE programs available to CFP professionals contribute to their professional competency.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Jerry P. Boisseau, CFP
®
Proposed Revision to CFP
Board's CE Requirement
Page 202 of 379
Comment
I would like to make a couple of comments on the Board CE requirements.
n Increasing total CE hours from 30 to 40. /// I believe this increase is long overdue it could be more than 40, but I
think the increase is a good move.
n Granting CE credit for practice management program and/or pro bono activities. /// The “and/or” is a key phrase, I
believe practice management is good, however, I am not sure pro bono should be part of CE requirements. Pro bono
®
should be something we as CFP [professionals] should do without expecting CE credits.
n Increasing the Ethics CE requirement from 2 to 4 hours. /// Ethics training is critically important and necessary but
without a great deal of new material 4 hours is an overkill.
n Eliminating CE credit for completing professional licenses and designation examinations. /// Good.
®
Having been a CFP [professional] for more than 25 years, I believe the CFP Board is a collection of truly outstanding
professionals and do a great job. Thanks for your commitment.
I hope these few comments give you some form of feedback.
Valerie H. A. Schmidt,
®
®
CFP , ChFC , CFS
No changes for CE
guidelines
®
This email is to state that I would like you to consider leaving the CFP [certification] CE requirements as is with NO
Changes.
Although, I can understand the need to keep up with the current changes in the financial enviornment, it is already
®
difficult to receive the existing CFP [certification] requirements at 30 every 2 years. There are many trainings that are
®
offered throughout the year, but not many that offer CFP [certification] designated credits. The current threshold is
already at more than 1 credit hour per month, it would be difficult to maintain a practice and be on top of earning more
CE credit hours than the current standard.
Please consider this and make no additional changes.
Thank you,
Verne T Takagi, CFP
®
additional CE credits
Every day it seems that out industry is getting bombarded by more regulations and over site. And every day we spend
more time dealing with it and less time dealing with our clients and prospective clients. There is already so much overlap
for those who are securities and insurance licensed. (I need 24 credits every 2 yrs for my Life and P& C license)
Your proposal gives me the same dislike as ‘Big Government’. Adding additional requirements will make me think twice
about renewing my designation.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Vic Tedesco, CFP
Subject
®
Vicky Hopkins, CFP
®
Benjamin J. Voelker,
®
CFP
Page 203 of 379
Comment
Proposed Education
requirements
I feel the current education requirements are more than adequate to keep up with the changing environment. In my
opinion today's changes are not more demanding than that they were 20 and 30 years ago, in fact I believe they are less
today than in the past. Additionally the added education requirements placed by other entities such as Insurance
®
companies, Broker Dealers etc which are not counted toward CFP [certification] credit, as they are not submitted for
approval etc. gives us less time to help clients. Another issue that is taking more time out of our day is Compliance
Regulations, certainly necessary however, We are loosing sight to what is really important and that is having adequate
time to helping as many clients as possible. By increasing these education requirements you will be taking time away
time from clients, which is supposed to be our primary goal. Adding additional hours of education will not benefit the
client but will only be a boon to education providers while increasing costs to the planners. I strongly urge you to
reconsider your proposal and keep the education requirements as they are permitting us to do our job serving clients
needs. Thank You!
I do not agree
The Board has already doubled the cost of our membership fees. Now you want to, in effect, double the cost of our CE.
I feel that many of the changes you are making are to “justify” the expansion of the Board and the move to Washington,
DC. Count me among those who do not favor these changes, particularly requiring 4 hours for Ethics. Those of us who
are following the ethics guidelines don’t need “more study.” Those who are not will not be influenced by 2 more hours of
CE.
Please see my comments on the proposed CE change:
Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule."
Rationale: Ensure diversity of learning experiences across breadth of planning topics
While I certainly understand the “spirit” of the proposed change I believe this will be very difficult for compliance. Much
of my CE is an incorporation of multiple disciplines in one presentation. For example, a presentation that combines
insurance and estate planning, tax and estate planning, general principles and investments are very common. I think it
will be next to impossible to categorize much of the CE as single discipline.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Wade Meadows, CFP
®
Proposed revisions to CE
requirements
Page 204 of 379
Comment
I want to be on record that I am opposed to almost every change regarding new CE requirements.
First, increasing to 40 hours is an undue burden. Most of us have significant jobs and significant other demands on our
time including production requirements, internal compliance training, etc.
In addition, most people are also Finra securities licensed and have regulatory element training around this. Coupled
with insurance license CE requirements as well.
The board should make it easier to maintain the designation, not harder. People have gone through considerable
expense and time to complete it and are true professionals. Having big brother determine what qualifies and what does
not is not productive. I have to say that the training I have received at large banks, CIti, BofA and Wells fargo far
exceeds the quality and sophistication of what I receive in the public market with estate planning councils and other
online CE programs endorsed by the CFP Board.
®
I have a ChFC, CLU and CTFA in addition to the CFP [certification] and have CE requirements for each, as well as for
securities and insurance. It is a huge burden to coordinate this and find the time to complete it all.
Please do not make it more difficult. Thank you.
Melissa S. Wall, CFP
®
Walter J. Saganice Jr.,
®
CFP
Proposed Revisions to CFP
Board's Continuing
Education Requirement
With the proposed changes, I’d like to see the reporting period changed to mirror a calendar year versus birthdates. The
change would make the CE cycle much more clear and concise.
My initial thoughts "I think we're missing the point" re: CE in general.
Agree, concepts are rapidly changing, but in fairness, how many different ways can anyone "spin" any topic. Many of
the courses are redundant, time-consuming, and flatly non-educational, we just go through the motions, I speak from
fact as I am currently doing the full-court-press of completing 30 hours by my Oct 31 deadline.
Given my interpretation that we view our members as professionals, equivilant to physicians, attornies, CPA's, I would
suggest reviewing each of these professional approaches to CE and using components from each to create a new more
®
meaningful CE program benefitting CFP [professional] member and the public at large, with less a focus on number of
credits (40 vs. 30), but on broader topics that many of us encounter in day-to-day practice management.
As an example, we saw the Glen Neasham annuity sale case in California, what was learned from this??? True, I may
®
have missed the official CFP [certification] pronouncement, but this topic is one of value to all of us to avoid
®
embarassments to our ourselves and the CFP [certification] organization. How about concepts of the aging senior
citizen, not much offered on this topic either?? What about the continued low interest rate environment and impact on
seniors or younger clients saving for retirement or college costs??
Hopefully this input will be considered as we strengthen our image as professionals worthy of fees paid for financial
advice. It's simply not a matter of quantity of CE, but a matter of quality of CE.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Kevin M Brown, CFP
Subject
®
Page 205 of 379
Comment
The proposed changes under consideration are:
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations. The proposed increase in required hours is consistent with
recommendations from CFP Board’s 2007 and 2008 Education Task Forces.
Totally unnecessary, represents almost 1% of two years of work. The designation needs to mean more to potential
clients to justify either more CE time or money spent for renewal. I would rather spend the additional money more CE
would require for additional money for the CFP Board to spend upon public education about the value of the
designation.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
o Practice management CE programs. Defined as programs focused on the planning, development and management of
®
a CFP professional’s business operations, office management, business model design, budgeting processes and
leadership.
o Pro Bono (volunteer personal delivery of financial planning) services. These activities must be supervised by a
registered CE Sponsor organization and will be accepted for 1 hour CE credit per 4 hours pro bono service.
Rationale: Recognize the importance practice management plays in the delivery of competent and ethical professional
financial planning services to clients. Encourage pro bono service for the public benefit.
Totally unnecessary, as pro bono work is done by nearly all of us. The documentation process wouldn't be worth the CE.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.
*Additional comments below*
Totally unnecessary, as we've
already demonstrated knowledge of ethical behavior expectations. We know what ethical behavior is. There will always
be some who choose to step over the line.
• Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following:
o Participation in Registered Program Financial Planning Development ("capstone") course grading panels. These
activities must be verified with documentation of active participation, written assessments and qualitative feedback;
o Study Group Activities that meet certain guidelines;
o Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
Rationale: Encourage body of knowledge expansion and no cost CE opportunities.
Do it. It won't matter at all to 99% of us.
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule."
• Rationale: Ensure diversity of learning experiences across breadth of planning topics.
Just makes CE even more complicated.
• Eliminating CE credit for completing professional licenses and designation examinations.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 206 of 379
Comment
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible.
Do it.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.”
Rationale: Recognize the quality control measures that regionally accredited institutions are required to incorporate in
the development and delivery of self-study courses offered for academic credit.
Just makes CE even more complicated.
• Encouraging increased rigor and quality of all CE program delivery methods.
®
Rationale: Help ensure that CE programs available to CFP professionals contribute to their professional competency.
Do it. Just continue to offer a wide variety of suppliers and delivery methods so costs can be reasonable for the value of
the designation.
Wanda Scott, CFP
®
from a CPA
From a CPA’s viewpoint:
Just glancing at these requirements, it would seem to be becoming more trouble than it is worth to me. I have enjoyed
having the designation, but do not really do anything with it. Certainly no investments, etc. I am sure that there are
reasons for the changes, but I do not see how they will fit into my needs.
Thus, I think that this would make my decision on whether I should keep the designation or not more easily determined.
Thanks,
C. Richard Watson,
®
CFP
Proposed CE changes
I am writing to request that you do not change the CE requirements. I can barely keep up with current requirements, as
my workload is almost too much to handle. Add to that the CE requirements for our firm, insurance licenses, and
security licenses and it all seems a little excessive. (Not to mention that the hardest and most prestigious exam I had to
take was the CFA exam and there are no mandatory CE requirements at all!) I know several others at my company feel
®
the same way. The CFP mark is good to have, but not necessary in my current role – it is a carryover from a previous
position. I do not know if I will continue it if the changes are made.
Thank you for your consideration,
Wayne D. Jorgenson,
®
®
CFP , CIMA
Increasing the Ethics
Requirement from 2 to 4
credits
I oppose the idea of increasing the required Ethics Credit hours from 2 to 4. There are not enough ways to receive this
specific topic that are acceptable to the CFP board. The CFP Board is so strict about what classes are accepted for
accreditation that I look at this as a way to funnel revenue into some of the on-line service providers and question
whether they pay something to the CFP Board to get on the approved list. There's an ethical question for the Board to
answer.
I have been an ethical financial advisor for 37 years. I attend CIMA conventions every other year as well as the
Barron's magazine's Top Advisory Teams meeting every year. Ethics are often discussed as a part of what we do. They
may not be a specific hour related to the topic though sometimes there is time allowed, but I find the meeting is not
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approved for CFP [certification] credits.
In any event, I oppose it and would prefer you keep it at 2 credits.
Thank you for your consideration.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 207 of 379
Subject
Comment
Randall A. Weaver,
®
®
CFP , CRPC
Comment on Proposed CE
Revisions
Comments:
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Rationale: Personal financial planning knowledge and practices are fast-changing, which requires ongoing learning to
maintain competency. The proposed increase in required hours remains consistent with or below similar requirements
for established professions and comparable designations. The proposed increase in required hours is consistent with
recommendations from CFP Board’s 2007 and 2008 Education Task Forces.
• Opposed. Granted the industry is “fast-changing” as is the need for updating knowledge and practices, however a
practitioners resources for that information is seldom completely CE approved. Those who are serious about their
practices already search for this information from multiple sources, mediums and even other industries. Increasing CE
requirements by a third simply reduces a practitioners time to share their knowledge and expertise where it is
needed…with their clients and prospective clients.
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
®
Rationale: Results from CFP Board's 2009 Job Analysis Study, which is the basis for CFP Board's CFP Examination
and Education curriculum, reflect an increased emphasis on ethics knowledge.
• Opposed. Requiring planners to participate in Ethics programs for twice as long will not translate into a higher
percentage of ethical planners. Unethical practitioners will continue to practice without regard. While those planners that
live and work with a strict Code of Ethics will have to deal with another unproductive, bureaucratic program that reduces
their ability to serve clients. Requiring a “mandatory CFP Board-produced Ethics program” also begins to sound like a
revenue generating activity for our trade group.
• Support: CE credits that are able to carry-forward from year to year without becoming valueless simply because of a
calendar date.
William West Thompson
®
Jr, CFP
Comments
I am an newly minted CFP [professional] as of this January.
®
I already have to complete hours by October 31st. As if passing the exam wasn't hard enough you already want 9 CE
hours. At least give me two years after passing the exam.
As for expanding it from 30 hours to 40 hours, a 33.33% increase, I think that is onerous.
As for: "Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other requirements. Exam prep or review courses remain ineligible."
If you mean that I would not get credit for the CE that I must have for my Life Insurance Licenses every two years then I
disagree.
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There are 52 weeks in a year and if you require 40 hours for the CFP [certification] (a week by my calendar) and you
eliminate the CE hours that counted from my Life Insurance License, then it becomes a financial burden adding another
8 hours per year for that license, I begin to wonder what's the point of having the license. I already have spent 24 hours
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this year just complying with my mandatory CE with Wells Fargo Advisors, that is in addition to both the CFP
[certification] and my Life Insurance requirements. At this rate eventually all I will do is take CE classes.
I agree that we should police ourselves and require CE. But make it reasonable. 30 hours ever two years is at my limit
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 208 of 379
Comment
of reasonable.
William A. Weddington,
®
CFP
William D. Pitney, CFP
®
Increasing hours of CE
required
I currently hold a Series 7 securities license as well as an insurance license. I already have to complete CE for my
broker dealer and FINRA as well as the 30 hours that you require. I often state that I am one of the most tested
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individuals around. I know not all CFP [professionals] hold other licenses and designations. However many do. I feel
that another 10 hours will make very little difference in an individual’s ability to perform or stay current. You stay current
in your practice or you will soon be out of business in my estimation. This new requirement would just add more
pressure to completing required tasks in the same amount of work time. I believe that same amount of time would be
spent more productively gaining a greater degree of experience working with new and existing clients while also keeping
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up with specific changes pertinent to each CFP [professionals] area of expertise. Therefore I respectfully request that
you leave the current requirement at 30 hours.
Comments for Proposed
Revisions to CFP Board's
Continuing Education
Requirement
Thank you for requesting comment on the Board’s proposed revisions to the CFP certification continuing education
requirements. It appears that the Board gave considerable thought to the changes and I commend you for working to
raise the standards.
®
While the proposed revisions are a great step in the right direction, I contend the Board could go further to enhance the
proposal. Below, I list only the proposed changes for which I offer alternative along with my rationale:
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Proposed change: Raise the education requirement for renewal of a CFP [certification] license from 30 to 40 hours
every two years.
Alternative: Raise the education requirement from 30 to 60 – 80 hours every two years.
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Rationale: The CFP [certification] is the gold standard in the financial planning industry. The Board states on CFP.net,
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“The Standard of Excellence for Personal Financial Planning.” As such, the CFP [certification] should demand the
®
highest standards and requirements of CFP certificants.
NAPFA requires its advisors to complete 60 hours of CE every two years. IARFC requires its members to complete at
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least 40 every year. If advisors in these organizations can meet the CE requirements, we as CFP [professionals] can
do the same. (Note: I am not associated with NAPFA, but I am a member of IARFC).
Since 2009, I have earned an average of 56 CE units per year, ranging from 43 in 2009 to 76 in 2011. Of those units, I
®
receive CFP [certification] CE credit for about 75-80% of them. I earn them by attending two or more professional
conferences, attending local and regional half-day and full-day workshops, attending webinars and completing selfstudy.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 209 of 379
Subject
Comment
In addition, I spend about 10-15 hours annually attending various practice management workshops and webinars.
The Internet and a variety of web-based services are making it easier and more cost effective for sponsors to deliver CE
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inexpensively and for CFP [professionals] to attend and participate in these webinars.
Proposed change: Impose a “cap” of 20 hours of credit biennially on any single topic area, such as estate planning,
taxes, or retirement.
Alternative: Impose a “cap” of 33% to 40% of biennial CE hours on any single topic area.
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Rationale: The CFP Board exists to benefit the public by granting the CFP certification and upholding it as the
recognized standard of excellence for competent and ethical personal financial planning.
There are eight broad topic areas. (With practice management, it would be nine).
®
The current proposal allows up to 50% of all CE in one subject area. A CFP [professional] could fulfill the CE
®
requirement by focusing solely on two subject areas. By imposing the alternative cap, a CFP [professional] has to
complete CE in at least three topic areas. While not perfect, the alternative cap shows the commitment to uphold
standard of excellence for competency. Maybe the cap should be 25%.
Proposed change: Grant up to four hours of CE credit per renewal period for practice management programs or pro
bono delivery of financial planning services.
Alternative: Separate CE for practice management and pro bono:
Grant up to two hours of CE per renewal period for pro bono services.
Treat practice management as a single topic area, such as estate planning, taxes or retirement. Require a minimum of
8-12 CE hours on practice management and impose the same CE “cap” requirements just like the other topic areas.
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Rationale: Practice Management is the one area where many CFP [professionals] struggle. As a mid-career planner, I
dedicate sufficient time thinking about business mergers and business succession to ensure my clients will be okay
should something happens to me. As our industry continues aging, this specific area poses the greatest threat to the
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survival of today's solo and small ensemble CFP [certification] practices. How do we continue to serve planning clients
are planners retire?
The healthcare, legal and accounting professions have well conceived career and business transitions. These
industries are thriving and serving the public well. They do not face the same challenges that Financial Planning
professionals currently face.
We are greatly and appreciate of the financial planning pioneers. We honor and respect those who built the industry.
The young profession needed to ensure its survival and allow practitioners to experiment with processes, fees, and the
like, and to prove the models worked. For these reasons, it is understandable why the pioneers and leaders catered
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almost exclusively to high-net worth individuals. Thanks to the pioneers, CFP [professionals] know how to do planning.
®
Today, however, I assert that the majority of CFP [professionals] are poor business managers and strategists.
Planners nearing retirement often do not have succession plans and think their businesses are worth more than a willing
buyer is willing to pay. Many practices are built around a single planner. As such, mergers and acquisitions fail
frequently when the solo planner retires or exits the business. Until we solve these types of operational challenges,
retiring planners want receive equitable value for their life’s work, solo practices will die leaving clients to seek advice
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 210 of 379
Comment
from other professions.
To allow our industry to evolve, expand and make financial planning readily available to the broader segments of
Americans, we as practitioners need to begin experimenting with our delivery processes, pricing and other businessrelated challenging if we are going to survey in the rapidly changing world of technology.
The other professions are embracing the technology challenges and new business models emerge everyday. The CFP
Board should encourage and support future business model experimentation, especially when it serves the consumer
and general public’s best interest. One easy way to the CFP Board can show support is to treat practice management
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as a specific topic area. Moreover, younger CFP [professional] practitioners will be the innovators and will help
advance the industry. They will be the ones who use the Internet and technology to make financial planning available to
the more Americans.
Proposed change: Eliminate CE credit eligibility for completing professional license and designation examinations.
Alternative: Retain the CE credit eligibility for completing professional license and designation examinations. However,
reduce the maximum number of eligible CE units. Instead of earning up to 28 hours, impose the same CE “cap”
requirements of a single topic area.
Continue to grant CE hours for the licensing/designation exam and not for preparatory or review courses.
Limit the licensing/designations examinations that qualify for CE eligibility. I would limit the list as follows:
State Exams: Attorney License (for those specializing in family law, estate planning and similar areas) and CPA
(for those who specialize in personal income taxes, which include Schedule C filers and maybe some LLC and SCorps).
Designations:
Keep: CFA, ChFC, CLU, EA, LUTCF,
Maybe: CCIM CEBS, CIMA, CPC, CPCU, CTFA, RHU
Drop: AAMS, CFS, CIC, CMFC, CRPC, CRPS, FLMI, QKA, QPA
®
Rationale: The CFP [certification] indicates a generally broad financial knowledge. Earning another professional
®
designation or license indicates a CFP [professional] has developed a specialized technical knowledge in a particular
topic area.
Several of the current approved designation/license explores a topic area at a much deeper technical level. The Board
should recognize the effort and commitment required to earn the designation/license, as long as the financial planning
®
®
education continues to within the CFP [certification] topic list and the licensing or designation expands upon the CFP
[certification].
By limiting the list of eligible designations/licensing is an acknowledgment that some designations require a substantive
®
amount of time and effort and challenges the CFP [professional] to expand his or her technical competence in personal
financial planning.
The education requirements of the designations that I noted to drop do not expand the technical knowledge of the CFP
®
[professional] or are already satisfied by the education required to sit for the CFP examination.
Proposed change: Expanding the professional activities that qualify for CE credit (currently accepted professional
activities are teaching and authorship) with the following:
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 211 of 379
Comment
• Participation in Registered Program Financial Planning Development ("capstone") course grading panels. These
activities must be verified with documentation of active participation, written assessments and qualitative feedback;
• Study Group Activities that meet certain guidelines;
• Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
Alternative: Expanding the professional activities that qualify for CE credit (currently accepted professional activities are
teaching and authorship) with the following:
• Participation in Registered Program Financial Planning Development ("capstone") course grading panels. These
activities must be verified with documentation of active participation, written assessments and qualitative feedback;
• Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
Grant up to ten hours of CE per renewal period for the expanding activities.
Rationale: I agree with the rationale, but think there should be a limit to the number of eligible hours. There could be an
®
®
exception made for CFP [professionals] conducting research. However, CFP [professionals] who conduct research
must present the proposals to the Board in advance and indicate the number of hours requested. The Board must
®
approve the exception before the CFP [professional] commences the research.
In addition, the maximum allowable hours for research including the exception would be capped at the same maximum
as any single topic area.
As for study groups, I am unsure how these would be structured and/or monitored. That’s the reason I excluded them
from the proposal.
®
I recommend the Board study this for the next two years. For the first 12-18 months, ask existing CFP [professionals]
and other professional study groups for their practices. Spend the balance of the time developing best practices and
establishing methods for evaluating how to grant CE as well as the number to allow per biennial renewal period.
I appreciate your consideration and look forward to future revisions.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
William Ragle, Ph.D.,
®
CFP
Comments on Proposed
Revisions to CFP Board's
Continuing Education
Requirement
Page 212 of 379
Comment
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
®
I disagree with this proposal. The 30 hour CE requirement is quite adequate to ensure CFP professional are remaining
current in the field. While we can always find other professions that have more stringent requirements, existence of
those stricter requirements does not justify increasing our CE requirement.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
I disagree with this proposal. If the concern is that we are missing particular aspects of ethics CE, that may indicate that
CFP Board should produce the Ethics program. That should, however, replace other ethics-related content rather than
doubling it.
This may well present an opportunity for the Board to standardize this important aspect of CE, but it should replace the
other rather than being added to it.
Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours.
I disagree with this proposal. If a certified financial planner is engaged in a specialized practice, he should be able to
focus his CE efforts on his areas of specialty rather than dedicating 50% of his CE effort to areas in which he is not
working. He should use his CE to sharpen his skills in his areas of practice rather than being forced to review areas in
which he is not engaged.
Greg L. Wilson, CFP
®
RE: Continued Education
Comment
My points and comments are:
• Do not increase the hours required; but increase the comprehensiveness of the content of each hour. In other words,
adding more hours does not necessarily accomplish anything. However, increasing the comprehensiveness of the
content to acquire each hour does.
• Make sure the educational material needed to attain the CE hours remains affordable, easily accessible, and
consistent across all resources.
• If someone has only a year before they are required to renew – provide a “first-time” waiver for the increased CE hour’s
requirement. It would be wholly unfair to put someone in that “tight of squeeze” for time to complete the new
requirement.
• Otherwise, I do like the concept of having to balance one’s continued education throughout the various areas of
subject-matter; rather than all one’s hours being gathered in one “subject”.
Thank you.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
E. William Pastor, CFP
®
Comments
Page 213 of 379
Comment
Comments on the proposed changes to the continuing education requirements:
The proposed increase of continuing education hours from 30 to 40 every two years is excessive. It is NOT the case
that 20 hours of CE per year is the norm in other professions. 15 hours per year is perfectly adequate and
commensuate with the licensing requirements of other professions in many states. In addition, while new financial
products are introduced and tax laws evolve, the fundamentals of financial planning remain constant.
The inclusion of some other activities within the ambit of CE is commendable, provided these are readily assessable to
members generally. Additionally, it should be made clearer to the membership how coursework sponsored by other
®
disciplines, including accounting and law, can be applied to the CFP [certification] educational requirements. The
continuing education offered by providers for the two cited disciplines (accounting and law) are at least as rigorous and
often more rigorous than the tax and estate planning CE offered by providers dealing more with the financial services
industry.
Patricia Gaye Wood,
®
CFP
CE
This is ridiculous! You are a bunch of Nazi’s. Why don’t you spend more time, money, and attention to informing the
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public about who CFP [professionals] really are. Giving lot’s of personal service to clients is already time consuming
enough if you are properly servicing your clients. There are so many regulators in each area of our industry and
numerous requirements and more regulations etc. and more time spent on your proposed changes is totally over-thetop.
J.G. "Woody" Woodall,
®
CFP
Stephen A. Wright,
®
®
CFP , CRPC
Dan A. Young,CFP
®
®
Laura E. Youngs, CFP ,
MBA
I received your notice concerning continuing ed expanding from 30 to 40 hrs and
Ethics from 2 to 4 hours; we also have continuing ed requirements for our Firm and also insurance
continuing education. There are barely enough hours in the day to do all these continuing ed
classes/lessons as well as take care of our clients.
Proposed Revisions
I am not in favor of the proposed CE revisions. Increasing the required CE hours will take more time away from our
main job, which is servicing our clients', not taking tests in a classroom or on a computer. Many of us already have
several other licenses/designations that require CE as well. Eventually, at this rate, completing CE requirements
becomes the main focus and not the client.
CFP CE Changes
Any changes that enhance to reputation and quality of the marks are encouraged and welcomed. The marks will mean
nothing without quality, efficient, and meaningful continuing education.
Your extremely limited options that are available for continuing education would make this a Very frustrating and
expensive situation. If the options for education were broadened this would not be as big of a deal, but as it is, I am not
in favor of these changes. The new annual fee instead of biannual in addition to the additional expense of continuing
education in a down economy is not going to be looked favorably on by my firm, and somehow someone is making a lot
of money off of this.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jonathan Lachowitz,
®
CFP
Subject
Comments: Proposed
Revisions to CFP Board's
Continuing Education
Requirement
Page 214 of 379
Comment
I am writing in response to the CFP Board’s request for comments on the proposed revisions to the Continuing
®
Education Requirements for CFP Certification. My comments are focused on the following 2 proposed changes: 1)
Increasing the total CE hours required each renewal period from 30 to 40 hours and 2) Increasing the Ethics CE
requirement from 2 hours to 4 hours:
®
In the context of my response, please note that I am a CFP professional in both the US and Switzerland and I am a
®
board member of the Swiss Financial Planning Organization where we are authorized by FBSP to grant the CFP marks
in Switzerland. I am also a small business owner in both the US and Switzerland, running an RIA in Massachusetts and
an Investment Management company in Lausanne, Switzerland.
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours:
®
By increasing the CE hours required from 30 to 40 I don’t believe my clients or the clients of most CFP professionals
will be better served. If there is some additional information that we need to do our job, we research it and find out the
right information. Most of the continuing education I get has nothing to do with the formal CE process. I work with
lawyers, accountants, insurance professionals and read and research on a much wider basis than the material that is on
offer from CE courses, this work ethic is engrained in most of the other professionals I know. The material covered by
many CE courses I have attended, I must be frank, is often recycled material on topics many of us are already well
versed in or thinly veiled marketing with questionable educational content. The increase of 30 to 40 hours is like a 33%
increase in taxes and when coupled with the increase in fees and the questionable value of the “marketing campaign” I
®
feel we will likely see a decrease in the number of CFP professionals and drive our subset of the industry towards
becoming guild.
The last time I counted, I had almost 30 different regulatory bodies (between the US and Switzerland) government or
voluntary membership which I have to report information to, pay money to or both on at least an annual basis. Each
organization grows gradually each year and requires more and more information and money from an over taxed
(financially and time) industry. I must have at least half a dozen codes of ethics, practice standards, etc. that I have to
comply with and quite frankly most of this regulatory creep is just an increased cost that takes time away from one of two
things 1) giving more attention to client services or 2) spending more time away from the office and with wife and
children.
®
I think the body of CFP professionals should also be informed as to who else will benefit from this increased education
requirement and what ties they have to the CFP Board. Implementing this requirement would seem to be a great
financial windfall to any individual or institution that profits from selling continuing education services.
While I wholeheartedly support efforts of the CFP Board to maintain the high quality of its professionals, I really see this
proposed change as an increased cost/tax to membership that adds a few more straws to the backs of a lot of camels
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with a relatively minimal impact on the quality of service received by the clients of CFP professionals.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
I am firmly in the camp of people who believe that ethics has a lot of black, a lot of white and very very little grey. The
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initial training and preparation for the CFP [certification] licensing exam provides an excellent foundation. However, I
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 215 of 379
Comment
firmly believe that most issues around ethics can not be “taught”. As a professional, people are honest, truthful, ethical
etc. or they are not; there is not a lot of wiggle room. An extra 2 hours of ethics training every two years will not make
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experienced CFP professionals more ethical. The course providers already struggle to find 2 hours of relevant
information and again much of this is a repetition of prior learning. As an industry we are constantly faced with “ethics”
issues whether regulatory or not and most of this exposure does not come from any formal ethics courses. I am afraid
this proposal, like the previous one I have commented on is an additional tax on an over taxed population.
With respect to the other proposed changes where I have not made comments, these appear to make sense and I can
not see any objection to implementing those changes as proposed.
I kindly ask the CFP Board to strongly consider the point of view of the professionals (especially in small businesses)
who on a day to day basis do our best to serve our clients while dealing with the ever increasing burdens given by
®
regulatory bodies. I am afraid that by increasing the costs [financial and time] of maintaining the CFP marks, we risk
®
®
driving down the numbers of CFP professionals [Many professionals don’t need to maintain their CFP [certification]
qualifications, this is voluntary] and decreasing the amount of time dedicated to client services with the ever increasing
burdens of the various regulatory regimes.
I remain available to answer any questions on my comments, which are my views only and do not necessarily represent
the views of any other professionals I work with nor do they represent any official position of the Swiss Financial
Planners Organization.
James T. Dempsey,
®
CFP
Ridiculous- Opposed!
®
Inactive Status
An “inactive status” should be revisited. CPA licenses have that provision. Thank you
CE
If somebody is studying for a series 6 or 7 securities license, what would qualify for credit? WOULD ANYTHING?
Jeffrey I. Brooks*, CPA,
®
CFP , MBA
CFP Courses
I get most of my CPA credit through Checkpoint. Do these tax courses get credit to be applied against my CFP
®
education requirement? I have found it difficult to find courses that qualify for CFP [certification] credit. Any ideas?
Thank you very much!
Richard A. Ray, MBA,
®
CFP
CE requirements:
Please note that I only support our current level of CE. I do not believe that additional CE will enhance our
professionalism or perceived value to the public. This is also true for the proposal to double the ethics component
required. I recommend we retain the current standards.
Robert B. Noone, CFP
Russell Patton, CFP
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Melissa J. Sanchez,
®
CFP
Subject
Proposed Changes
Page 216 of 379
Comment
The proposed changes under consideration are:
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Paying for valuable, worthwhile CE is already expensive on top of a large fee just to hold the license. All of this after
spending thousands of dollars on classes and review courses to gain the license. Who is benefiting? CE Providers? I
do normally have more than required. However for younger planners, I see this as a burden. • Granting CE credit for
practice management programs and/or pro bono activities, up to 4 hours (total combined) per renewal period.
o Practice management CE programs/Pro Bono services.
If this is included in the total number of CE hours not in addition to the CE hours, I say it is about time. If we are not
successful business people, how are we able to provide good advice? I am concerned however, with how pro bono
activities would be counted. Most of us do pro bono activities, not because we gain anything in return but because it is
appropriate to give back to the profession and to help others who cannot afford it. However, the activities I do are not
always done through a registered CE Sponsor organization.
• Increasing the Ethics CE requirement from 2 hours to 4 hours
Increasing Ethics CE from 2 to 4 hours does not make anyone more ethical. Being involved in my local FPA chapter, we
struggle to find good ethics programs to offer our members at a reasonable rate. Does the CFP Board plan to offer
programming or again is this another way to make money for CE providers?
• Expanding the professional activities that qualify for CE credit
o Participation in Registered Program Financial Planning Development ("capstone") course grading panels.
o Study Group Activities that meet certain guidelines; I would like to know more about the guidelines.
o Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
Are certificants really getting all their credits from one study area? I highly doubt it. Also, how do you edit out those CE
from conferences versus other sessions. What about FPA chapter symposiums? Are they considered conferences?
Whose conferences qualify? The only thing I could see here is the above point from research, study group etc.
• Eliminating CE credit for completing professional licenses and designation examinations.
As long as a certificant is getting quality, related education why wouldn’t it be counted? Again, must be prior approved
as relevant material. Learning is learning.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.” Not sure what is meant here.
• Encouraging increased rigor and quality of all CE program delivery methods.
How do you plan to police this? Making it more difficult for (for example) FPA Chapters to get their CE approved does
nothing for the profession. All the meetings I attend seem to be quality in nature. Once in awhile I am disappointed but
not often. If this is approved, an exact outline of what the board is looking for is appropriate and should be provided to
all CE Providers.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Darlene Tucker, CFP
®
D. Randolph Waesche,
®
CFP
Page 217 of 379
Subject
Comment
CE Requirements Changes
Increasing CE hours adds an additional burden that doesn't take into account the extensive amount of CE hours that
most of us have to do in addition to those of the CFP Board. I feel it is unnecessary and at some point simply makes it
more difficult to justify maintaining the certification for those of us who work with the middle America clients that often
need professional advise the most. Many of us also hold securities licenses, insurance licenses, and other certifications
that each carry separate CE requirements. In addition to this there are specific CE hours required by state and federal
rules in order to serve our elder clients in the area of Long Term Care Insurance Planning, Medicare Advantage, and
Medicare Prescription Drug coverage. Additionally, since approved courses come in a multitude of CE units and excess
hours don't carry over it is common to end having to complete more than the minimum in order to reach it. I do agree
with including practice management as a category as well as Pro Bono services, although I expect arranging for the
supervision of Pro Bono work by a registered CE sponsor will be next to impossible in the smaller cities due to the lack
of presence of these organizations, virtually eliminating any potential benefit of this option for many of us. The increased
focus on Ethics makes perfect sense but the way the rule is proposed it appears the extra hours will have to be taken in
the form of a completely separate course. I think a less burdensome option would be to develop a four hour course that
would satisfy the requirement without the duplication. Expanding the professional activities that can satisfy the
requirements appears to be a way to make it easier for those in academia to meet it as opposed to those of us who are
actively involved with clients. I would hope that the 50% rule would apply to professional activities as a total so as not to
satisfy the entire requirement through professional activities alone. I disagree with eliminating the allowance of credit for
earning additional designations unless the courses required for these will be quickly added to the acceptable CE
courses list. For the most part, these changes appear to me as a signal that the Board is moving in a direction that
favors substantially the Practitioner located in the more densely populated, high net worth areas of the country and away
from a system that will encourage and allow Practitioners in low density, middle America communities, whose practices
®
are not comprised of high net worth clientele, to continue and succeed as CFP Certificants.
CFP Board Continuing
Education
My response to your proposed changes is not favorable. Allow me to make comments on each section:
1. Increase total CE hours required each renewal period (every 2 years) from 30 to 40 hours. – Every professional must
commit to learning; without a drive to learn the practitioner will not be productive and the profession will suffer. I am a
huge advocate for continuing education; but with access to the internet as a resource for information and the lack of
diversification in educational venues approved by the CFP Board, I appose the additional hours.
2. Granting CE credits for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period. Neither practice management courses nor pro bono activities increases competency. We all should give
back and provide pro bono services, but not for CE credit. How a practitioner manages his practice is immaterial and
the CFP Board should not grant credit for taking practice management courses. Rather than extending 4 hours for
credits not directly associated with making us better practitioners’, don’t increase the hours.
3. Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethic program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board’s Standards of Professional Conduct and general ethics-related content. I’m appalled at the CFP Board’s
arrogance; a CFP Board-produced Ethic program wrong. The CFP Board’s purpose is not to create educational
programs. There it an entire objective and unrelated industry designed to serve this need.
4. Implementing a “50% cap rule,” which will limit CE credit for any single topic area or professional activity to 50% of
total required CE hours. We are not all generalists and some do not practice in a related discipline. This is absurd, if I
want a higher level of knowledge in an unrelated field, I’ll bring an expert into the engagement.
5. Eliminating CE credit for completing professional licenses and designation examinations. No comment
6. Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or
universities as “live” CE programs, rather than “self study.” No comment
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 218 of 379
Comment
7. Encouraging increased rigor and quality of all CE program delivery methods. No comment
Pam Loduca, CFP
®
Jerrold E. Slutzky, J.D.,
®
CFP
CFP Continuing Education
Requirements
I am opposed to increasing the CE credits from 30 to 40 hours. Personal financial planning has always been fastchanging and required on-going learning to maintain competency, increasing CE credits by 10 hours will not ensure that
we are meeting this requirement. Requiring greater diversification of CE credits, various areas will better serve this
objective, not increased hours. I am also opposed to eliminating CE credits for additional designations. On-going
education that is more specialized in a particular area more closely aligns to the goal of maintaining competency.
Weather this is accomplished thru continuing education classes or another designation, is not important, on-going
education and competency is what is important.
Comments on proposed
revisions to the Continuing
Education requirement for
®
CFP
I would like to respond to the proposed revisions:In general, I find most of the proposed revisions to constitute a
narrowly-focused, micro-management of how those of us "in the field" must continually "update" our knowledge. They
completely ignore all of the information we obtain on our own to be of service to our clients...all of the additional reading
we do, seminars we attend, educational workshops we give, and other research and work we do that doesn't "qualify" as
continuing educational hours. As an attorney, I am required to obtain 30 CE hours every other year. And as a licensed
insurance professional, I am required to obtain 28 CE hours every two years. And as an arbitrator for FINRA, I can
spend several days at a time adjudicating disputes between investors and their financial advisors, covering issues that
®
most CFP professionals never encounter. I receive no CE credit for those services. There is seldom any over-lap
given for all of this additional knowledge I am able use to provide my clients with broad-based services. So, while my
own situation may be somewhat unique, I am already investing 88 "qualified" hours in maintaining my various licenses.
Given an 8-hour work day, that's the equivalent of 11 full days of education...would you care to give-up one of your oneweek-a-year vacations each year? An additional 10-hour requirement is not going to make me a better advisor. So
unless and until you are willing to give credit for other types of educational programs in other professional areas of
concern, even if they are not directly linked to the financial planning process, I would strongly object to any additional
®
required hours to maintain our CFP certification. Similarly, regarding an increase in the ethics requirement, the same
objections above would apply. One cannot be taught ethics; one either has them or they don't. Requiring two additional
hours to "teach" us how to be ethical serves to punish those who are already ethical; those who aren't are still going to
be unethical. Finally, mandatory attendance at "live" events ignores all of the additional time and expense required to
prepare for, travel to, and travel from the events. Please leave the current requirements in place, and stop "tweaking"
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 219 of 379
Comment
what you believe those of us "in the field" need to know. I'd prefer that you focus your time in educating the public on
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the importance of the CFP [certification] designation in selecting a financial advisor, and shutting down those advisors
who don't live-up to the standards expected of us in this noble profession.
Fred Forbes, CFP
®
Christina Bater, CFP
®
Changes
I am fine with most of the changes mentioned. I do not see the need to go to four hours for Ethics. Most of the material is
a "firm grasp of the obvious" and pretty boring. Frankly, if one does not have ethical practices pretty firmly ingrained by
®
the time one qualifies as a CFP [professional], there isn't much hope for them anyway! One change I would make is to
provide a carryover of excess credits. When I attended an FPA Symposium in Tampa recently, I went in with 31 credits,
came out with 45. I have another convention in Washington in 2 weeks where I will pick up another 12 or so giving me a
total of 57 vs. my required 30 when I need to renew at the end of September. What a waste! How about a provision that
any excess CEs earned can be carried over?
Increased CE
Requirements
While you may believe that increased continuing educational requirements will help maintain and enhance competency
in financial planning principles and practices, I beg to differ. I do not believe that increased and more stringent CE
®
requirements will make CFP certificants any more knowledgeable or honest than they already are. Have you seen a
deterioration of such in the ranks that would prompt you to take such remedial action? More over, for those of us who
run our own independent fee-based firms, these requirements represent an additional administrative burden. It may be
®
easy and cheap for a CFP certificant employed through a broker-dealer, insurance company or other large financial
institution to meet their CE requirements. These types of firms sponsor many in-house CE events free of change and
conveniently scheduled on-site. For those of us who run their own shop, we must work to locate acceptable CE events,
pay for them, and take time away from our practice, clients and the running of the firm. While I am happy to meet the 30
hour requirement, I do not see that an additional 10 hours is going to make me any better at what I do. I am a
professional and I go out of my way to make sure that I am knowledgeable on those specific areas of investing, estate
planning, retirement planning and cash flow planning that are important to my clients. So if I believe that 60% of my CE
credits should be in the investment area because it is germane to my practice and my clients, why should the CFP
®
Board override this? Lastly, should we not compare two designations: CFP [certification] vs. CFA? The CFA Institute
does not require its charter holders to complete ANY annual CE requirements. They believe their charter holders to be
®
professionals. These CFA charter holders earn on average 2x what a CFP [professional] earns. So it goes to reason
®
that continuing to increase the hurdles to earn and keep the CFP designation will result in only one thing – fewer CFP
certificants in the future.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Timothy J. Harrison,
®
®
CFP , CLU
David L Holtz, CFP
®
Christopher Dorsett,
®
CFP
Page 220 of 379
Subject
Comment
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I do not agree with the proposed changes to the CFP [certification] Continuing Education Requirement. This expansion
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of the continuing education requirement only further increases the cost of the CFP [certification] designation (which is
®
already pricey enough) and continues to diminish the profitability of holding the CFP [certification] designation. The
amount of changes proposed all at once seems out of touch with what advisers are truly dealing with in the field with
already increased regulation from various government entities. Each new requirement takes time away from meeting
and serving clients and is counter-productive to why I earned this designation in the first place. The current system is
adequate.
Comments on New CE
Requirements
I do not agree that changes are needed or desirable in the CFP [certification] CE requirements. I am increasing my
opposition to relentlessly increasing regulation by government and quasi-government agencies of all kinds under the
current regime. I call for a moratorium on further ratcheting of the non-income producing activities mandated “for our
own good and that of the profession”. In particular, the teaching of ethics is ineffective, in my view, if a person doesn’t
have deeply grounded principles from their earlier religious or moral training. Another two hours is not going to change
anyone’s behavior. To quote George Gilder quoting Richard Posner from a recent article on capitalism in National
Review: “Richard Posner, now an eminent judge, was one of my inspirational sources for the idea that capitalism is
inherently favorable to altruism “The market economy,” he wrote, “fosters empathy and benevolence, yet without
destroying individuality,” because for an individual to prosper in a market economy he must understand and appeal to
the needs and wants of others.” The self-policing of the marketplace is far more effective than artificial requirements by
organizations that may not, efficiently, at least, address the true needs of the members.
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Regarding the Proposed Revisions to CFP Board's Continuing Education Requirement, I am against the proposed
changes. The regulations that are currently enforced and constantly changing are truly challenging. I recently completed
a FINRA principal tutorial requirement that took 6 hours of my day! I have securities license CE requirements, Insurance
®
CE and my Broker Dealer has compliance requirements, not to mention the 30 hours of CFP [certification]
requirements and incredible amounts of required paperwork. I read many articles and periodicals throughout the month
and the WSJ daily. There are too many requirements currently, and the dishonest will remain if you add 10 more hours
of CE to an already outstanding designation. I understand the desire to keep individuals informed of the ever-changing
planning landscape, but I feel there are more efficient ways of keeping practitioners informed, if that is your ultimate
goal. One suggestion is to make the CFP [board] website a portal of information that is more user-friendly. A reference
that practitioners would use as their first source of information or daily news source, keeping us informed of that “everchanging” landscape.
®
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
®
Karl E. Klinger, CFP ,
®
CLU
Page 221 of 379
Subject
Comment
RE: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I disagree with and oppose the proposed changes discussed below.
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Increasing CE hours requirement is overkill. I personally must satisfy CE requirements of four different designations and
®
programs. I am sure many if not most CFP [certification] licensees are meeting CE requirements for multiple
designations. Personal financial planning is not advancing at a rate which required additional hours of CE each
biennium. A “me too” desire to increase hours because other professions are doing so is not justification for doing so. •
Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
o Practice management CE programs.
o Pro Bono (volunteer personal delivery of financial planning) services.
Practice management is NOT a proper topic for CE credit. Hew to the basics in defining subject matter acceptable for
CE. Do not give in to the clamor from the rabble to accept topics which are not related to financial planning. Pro-bono
work may be commendable, but no more worthy of CE credit than billable work. This is an exceptionally outlandish
idea.
• Increasing the Ethics CE requirement from 2 hours to 4 hours.
Work on improving the quality of Ethics CE, not the quantity. Quality is what is lacking.
Janet S Elinoff, CFP
®
Matthew W.
®
Quebbeman, CFP
Dwight Moats, CFP
®
Robert E. Adams, Jr.,
®
CFP
Fwd: CE Changes
I think that self-study and on-line courses should not be discounted by 505 for the hours to complete. Many times, these
methodologies require twice as much time. There is no one to speak with about the class or questions! Many of us
have to do the continuing education on the weekends, without employer support. Requiring 40 hours is really like doing
classes for 80 hours!
CE comments
Increasing to 40 hours is too much. The cost in terms of time and fees will be excessive and some employers may not
allow or pay for the increase. Increasing Ethics CE requirement to 4 hours is too much, unless you mandate that all
®
CFP [certification] courses must contain some part of an Ethics discussion. Adding a 50% cap rule to limit CD for any
single topic is too low.
Raising the amount to 75% allows specific industries and disciplines (i.e. tax) to concentrate on our specialties while still
allowing for other topical areas. While we don’t get credit for doing our jobs, the day to day interaction with clients and
other professionals, and outside reading, does provide some training. All professionals need to stay abreast of breaking
developments in their industry, most of which is achieved outside the formal classroom.
FW: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Proposed changes indicate increased CE hours from 30 to 40 hours. I find it very difficult to find enough CE providers to
full fill the current 30 hours. Most in our area do not provide it or have gone out of business.My concern is where are we
going to find providers to full fill the 40 hours.
CE Requirements
I am opposed to increasing the continuing education requirements from 30-40 hours and particularly opposed to
increase of the ethics training. I just did my 2 hours of ethics training and once again it was nearly a complete waste of
time. You can’t teach ETHICS! I don’t buy into the reasoning for additional hours being necessary to meet increase
®
changes in our business. I have been a CFP [professional] since 1992 and just don’t see how this is going to benefit
me or my practice in any way. Thanks for your time and consideration.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Mary Lou Reid, CFP
®
Tom Rickey, CFP ,
CRPC, CFM
Roy Holtz, CFP
®
®
Page 222 of 379
Comment
COMMENTS TO
PROPOSED REVISIONS
IN CFP CONTINUING
EDUCATION
REQUIREMENTS
It seems that too many different types of increases are being proposed for implementation at the same time. The
increases should be phased in over time. There is a fine line between raising the standards and communicating a
®
pompous attitude regarding the CFP marks. What are the requirements for attorneys and CPAs in relation to what you
®
are proposing for CFP [professionals]? It’s my understanding that CPAs, for example, are required to complete 15
hours per year of continuing education. Firstly, adding more credits to the Ethics requirement will never make a person
ethical. Secondly, if this seemingly complicated system is implemented, there should be simpler requirements for those
®
CFP [professionals] who have retired. Other professions, such as Real Estate, do not require continuing education
®
after age 70, for example. A retired CFP [professional] should be allowed to keep the credential after retirement with
some modified continuing education requirements. Retired doctors are still MDs. Thirdly, some of the areas in which
you are expanding allowed credits, i.e. study groups and research, vs. areas restricting credits, i.e. training required to
renew licenses such as insurance, bias the credential in favor of certain aspects of the profession which appear to be
®
passive and educational in nature vs. active field work. Is the CFP [certification] designation moving more toward
encouraging people who wish to be professors and research specialists vs. active planners who want to spend time
finding and working with clients who need their services? Finally, there is already too much bookkeeping/tracking work
®
required in our business. This suggested segmentation of requirements (50% rule) forces the CFP [professional] to
spend time “finding and paying for the right course in the right segments to follow the rules” instead of spending time
helping people and being out in the field on the “front line,” taking courses/seminars in one’s area of specialty, love and
service. Many CERTIFIED FINANCIAL PLANNERS™ prefer computer work to people work and these requirements
seem only to encourage that approach to the profession. During one’s initial education process and perhaps early in
one’s career it is important to receive diversified credits and information. Late in one’s career is usually the time of
specialization. During the specialization phase it is important to continually sharpen one’s skills in one’s area of
®
expertise. To quote business coach Dan Sullivan, are we driving CFP [professionals] to “hit the ceiling of complexity”
or are we encouraging them to develop their “unique Abilities?” In conclusion, I think that these listed proposed changes
need to make a trip back to the drawing board.
Proposed Increase in CE
Hours for CFP's
The proposed increase in the 2-year requirement for CEU’s from 30 hours to 40 just adds yet another burden to our
profession and workload. Instead of placing an additional administrative requirement on us, I’d suggest the BOD
reallocate more time and resources to marketing our skills and credentials. As such, I am respectfully requesting that
you reconsider the proposed change. Has the AICPA or other professional financial organizations implemented similar
changes?
comments on new CE
requirementsu
The CFP [certification] is already requiring stringent continuing education and another 10 hours is not going to keep the
bad guys from committing crimes. You are just heaping on more work for those of us who work at this business faithfully
every day and do our best to help our clients. Please DO NOT increase the work load already upon us. It seems more
and more intrusions are on us every day from a government committed to making more rules and regulations and
making it increasingly difficult to do business. Want to stop the crooks? Make the penalty fit the crime. Do away with
the slap on the wrist and make it hurt so badly that others contemplating the same crime will think twice.
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Tyson C. Lewis, CFP
®
New CE Rules = wrong
direction
Page 223 of 379
Comment
As a Financial Advisor at a/any major brokerage firm I spend an unbelievably large amount of time on CE. Increasing
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this requirement is the wrong direction for the Board to take. As a 14-year veteran and decade long CFP [professional],
I don't need an increase in the requirement, I need a decrease. Further, I need a broader range of subject matter to be
credited as CE to accomodate/facilitate meeting the requirement.
®
RECOMMENDATION 1: Reduce the CFP [certification] CE requirement after every six years of tenure, just like many
®
state insurance departments do. In addition to the CE to maintain my CFP certification, I must complete CE for (1)
FINRA, (2) state life, heath and VA insurance licenses, (3) my firm's internal CE, and (4) many required courses that are
not considered CE. While the content of the materials between these different courses is very similar, the overlap in
®
credit-given is small. For examply, this year I will complete an ethics course specifically for CFP [certification], another
for Florida's insurance department, and a third for my company; every few years I will have to complete one for FINRA,
as well. Re-completing the same basic level exams year after year does nothing to further or even reinforce my
profession.
RECOMMENDATION 2: Accept a broader range of education as Continuing Education. The CE requirements have
become a major distraction to my passion to grow professionally by learning about the subjects that are important to me
and my clients. Professional subjects that simply have not been packaged into a pre-approved and reportable CE
course. I spend literally hundreds of hours per year reading and 80+ hours per year in formal courses furthering my
knowledge and education about the practice of financial planning. Why shouldn't more of those hours count as official
CE?
Amy Jo Lauber, CFP
®
[FWD: Request for
Comment: Proposed
Revisions to CFP Board's
Continuing Education
Requirement]
• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
I agree with this only if the following proposal is accepted. This will make it easier to obtain the additional credits while
also helping us be more successful in our practices.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
o Practice management CE programs
o Pro Bono (volunteer personal delivery of financial planning) services.
I very much like this idea and I think the spirit of it is very considerate.
• Increasing the Ethics CE requirement from 2 hours to 4 hours
I think this could be difficult to implement unless additional ethics course providers are made available.
• Expanding the professional activities that qualify for CE credit
This is a good idea, especially if the increased CE hours are approved.
• Implementing a "50% cap rule,"
I agree with this idea. Our loal chapter of the FPA strives to vary the programming to suit this particular model.
• Eliminating CE credit for completing professional licenses and designation examinations.
I'd like to see you retain CE credit for eligible coursework.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jeff Hamilton, CFP
Subject
®
Increased CE Requirement
Page 224 of 379
Comment
Please know that while I generally take 40 plus hours of CE, I am not in favor of the increase.
This year, in addition to the requirement to maintain the CFP designation, I’m required to take hours specific to tax
preparation. To the best of my knowledge, my CFP hours do not in any way count toward my Return Preparer’s
requirements to the IRS. And at this point, none of the courses I taken to date qualify for CFP credit. My guess is that
there are plenty of us that do tax preparation and will be trying to meet this additional burden.
Laura M. James, CFP
®
Comments for Proposed
CFP Continuing Education
Requirements - Quality
over Quantity
Below are a few comments on the proposed changes to the current CE requirements for the CFP [certification]:
®
• An increase in the number of required hours, from 30 to 40 (When you compare the CFP [professional] to other
professionals like CPAs and CFAs the current amount seems comparable. CPAs in Alabama are required to submit 40
hours of CEs while CFAs are required no CE. The CFP board should focus first on quality over quantity. Many of the
rules below focus on increasing the overall quality of CEs, which is a better place to start the reform.)
• Granting up to four hours of CE fir practice management and/or pro bono. (This is a great idea. Our local FPA chapter
is always interested in Practice Management topics. Practice Management is an important part of setting up a true
planning practice. Also, I think it is always a great idea to encourage Pro Bono work.)
• Increasing the number of required ethics hours to 4, and additional ethics program requirements ( Again focusing on
quality over quantity is more important here. A lot of the ethics courses I have attend are not very professional. It would
be more import to first focus on making the current programs better before increasing the required amount.)
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• Broadening the list of activities that qualify for CFP [certification] CE ( The board should be careful here. There are a
lot of programs that are not worthwhile learning opportunities. These new programs would need to be reviewed and
studied carefully before credit is granted.)
• Capping continuing education credit from any single subject area to 50 percent of required hours. ( There is value in
this, but is this a large issue and does it hurt the profession? One important item to note, is the best planners have niche
specialties. These planners may require special CE to maintain their practice focus.)
• Eliminating CE for completion of professional licenses and designations. ( I am currently working to completing the
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CFA designation. Just like the CFP [certification] program this test requires hours of self study, 16 weekly classes, and
a 3 day live review. Well, if you want to be in the 38% of people that pass Level 1, it requires this amount of preparation.
To not allow credit for this in depth 6 to 8 month long process for each level seems a little unjust. A program and test
like this is one of the best CE credits, many other programs are simply not up to par. Programs where participants are
required to complete an exam is the best way to ensure the program covers the required knowledge. Taking away CE
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credit for these learning opportunities would be a loss of value for the CFP [certification] profession. We need the most
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highly educated people possible carrying the CFP [certification] designation.
• A change in how accredited universities who deliver content online are categorized for continuing education purposes.
Encouragement of increased rigor in continuing education programs ( These last two items are by far the best items for
the board to approve and focus their time and resources. Before the board focuses on increased CE requirements, the
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board needs to ensure the programs CFP [professionals] receive these credits are up to par. It really doesn't help CFP
[professionals] or the public if we receive more sub par credits.)
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CE changes
I am a big believer in continuing education as an important ingredient in keeping us current and improving our general
image. That being said, the program in place is adequate. I have been a designate since 1998 and I am well aware of
the ethics component and as we all know ethics is not something that can be taught. Increasing the requirement from 2
to 4 hours will benefit a cottage industry, but will not in my opinion enhance ethical behavior. While much is changing in
the industry, much remains the same. We still have to save and invest or nothing else will happen. I would rather spend
my time encouraging productive behavior among my clients than taking one course after another. Would you consider
Brad Case, PhD, CFP ,
CRC
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 225 of 379
Comment
exempting people over 65? In short, 30 hours of CE is enough.
Laurie J. Lang, CFP
®
Scott H. Altman, CFP
®
CE Requirements
Proposed Changes
Although it increases the demands on my time, effort and financial resources, the proposed changes should inevitably
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raise the bar for CFP professionals improving our standing and the quality of services provided. In short, I support the
proposed changes.
CE
I appreciate your desire to keep CFP [professionals] uniquely sharp in serving the public. Adding more hours to the
certification requirements will not increase our effectiveness to the public. At the major firms we now spend nearly half
our time on some sort of compliance or continuing education. It is difficult to serve investors when we spend a large
percentage of the time routinely going over material just so the firms or organizations can proclaim how well trained we
are.
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David R. Hannay, CFP
®
comments on proposed
changes regarding CE
I disagree with this change. I believe that practising CFP [professionals] are carrying on education all the time, thro ad
hoc issues that come up that they have to research. In addition, so much is constantly changing in the Regulatory,
Investment and legislative fields, that on going education is part of the practitioners required modus operandi. I doubt
that the theoreticians at the CFP Board appreciate this.
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Michael McIntyre, CFP
®
Re: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I am patently against needing to earn more CE credits and more complex rules to maintain my CFP [certification]
designation. I am a long term practitioner with a sterling record. Between the requirements in place and the other
training I must do for my licenses, I receive way more training that the 30 hours required by the Board already.
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People should be required to fulfill greater requirements only when they are not demonstrating a professional and ethical
commitment to the marks. Instead, your suggestion burdens all the other professionals for the actions of a few.
Marilyn Capelli Dimitroff,
®
CFP
Proposed CE
Requirements
I support the proposed requirements for continuing education. As past chair and Board of Directors member, we had
ongoing requests for some practice management credit as well as pro bono work credit. The proposed plan
incorporates both of these areas. The increase from 30 to 40 hours every two years is reasonable and important to
maintain knowledge and competence. Given the many ways to earn CEs, it is not an onerous requirement.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
John C. Ryan, Jr., CFP
®
Comment on CE changes
Page 226 of 379
Comment
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Increasing the total hours required: Not needed. With multiple CE requirements already in place (CFP [certification],
Insurance, FINRA, SEC, firm element, etc.), not all of which can be used interchangeably, current CE requirements are
more than enough to keep us informed of fast changing environments. An additional ten hours is a needless expense.
CE credits for practice management and pro bono: Makes sense.
Increasing the Ethics requirement: Current requirement is sufficient. If you’re going to violate the ethics component of
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being a CFP [professional] having an additional two hours CE won’t stop you. The additional two hours would replace
CE from other subject areas that an individual may prefer to study.
Expanding the professional activities that qualify: Makes sense.
Implementing a 50% cap rule: Makes sense.
Eliminating credit for professional licenses: Makes sense. Never understood why this qualified in the first place.
Brad J. Bryan, CFP
®
M. Cobble, RN, GG,
®
CFP , CFA
®
Cont Edu Credits
I am not in favor of limiting the number of credits that can be earned towards continuing education when a CFP
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[professional] holder goes through a professional licensing program. CFP [professional] holders should be encouraged
to build up their credentials and rewarded for doing so. When I went through my Series 7 licensing course curriculum
last year, I learned topics about the investment industry that I had never studied before or encountered during 10+ yrs
career in financial services. I spent many hours studying and preparing to pass my exam. This training helped me to be
a better financial advisor and was invaluable in enabling me to serve my clients. The hard work I spent becoming a
broker should be counted, especially considering that most CE courses are much shorter in length and often constitute a
review of previous subjects already mastered.
Changes to CE
Upping the CE requirement to 40 hrs? NO NO NO NO NO!!!!!!! The whole system is a money-generating scam for
CE providers as it is. You are not my professional competancy nanny. I have to read reams of info for my own areas of
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expertise; the courses I have to attend or articles I have to read to meet the CFP [certification] CE requirements are,
for the most part, worthless. For instance, the tests in the JFP are a joke; they mainly test your ability to uncover some
obscure minutia that have nothing to do with the main points in the articles.
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The CFA charter is is a much more challenging designation to achieve than CFP [certification] and, thankfully, the CFAI
has not gone to the bureaucratic boondoggle of mandatory CE. Getting 30 hours or 40 hours, etc. of CE will never
ensure a competant, ethical practitioner.
Theresa M. Flemma,
®
CFP
Proposed increase of ce
hours
®
As a consultant that holds a CFP certification, series 7, series 63, series 65, and insurance licenses, I am already
spending to much time away from my actual work with clients in order to keep up with all the CE requirements. The
insurance license requires 15 every two years. My firm requires four courses every year on top of 529 planning, variable
annuity training, anti money laundering, and FINRA requires an additional test every 2 to 3 years. If you take all the
other CE requirements which are required by those who hold other licenses, it is very obvious that we are already
inundated with extra course work and to require an additional ten hours (33 percent increase) is unreasonable.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
LuAnn Chapman Gatts,
®
CFP
Subject
Comments on proposed
changes
Page 227 of 379
Comment
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours. Comment: This change
makes no sense and appears to only be directed at generating revenue for the CE providers. The additional 10 hours is
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not going to make any real difference. The vast majority of CFP professionals are well trained, well educated and try
and do the best for their clients.
Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period. Comment: Seems like a lot of administrative time on the Board's part.. The probono having to be done
under a CE sponsor negates any potential for encouraging probono work. Again appears to be generating revenue for
CE providers and not effectively making any difference to the quality of service.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
Comment: None of the major ethics violations are committed due to not understanding the rules. People either have
ethics or they don't. An additional two hours is NOT going to stop an unethical professional from stealing, lying or
defrauding their client. Again, this looks to be a revenue generating change for the CE providers.
Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following: Comment: This is a good idea.
Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. Comment: Excellent idea. This will help keep people "up" on areas they don't work in as much
Eliminating CE credit for completing professional licenses and designation examinations.
Comment: This is totally unacceptable and makes no sense. The courses are designated as being both insurance and
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CFP [certification] credit. If I am taking a designation exam, it is covering areas that are covered in the CFP
[certification] topics.
Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities as
“live” CE programs, rather than “self study.”
Comment: Not sure what this is directed at.
Encouraging increased rigor and quality of all CE program delivery methods.
COMMENT: For the most part, this appears to be a revenue generating program for CE providers. There is nothing in
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this that will change the services provided by the CFP [certification]. The people that are true professionals and serve
the client first will continue to do so and those who don't put the client first will continue until they get caught.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
®
Paul J. Fallace, CFP
Page 228 of 379
Subject
Comment
Increasing CFP CE Hours
Comments in Red. I’m a new CFP [professional] just finishing my first year as a CFP [professional] after 7 years as a
Financial Advisor passing the exam last July.
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• Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Why a 33% increase in one step. Seems like move in one step. Recommend more systematic process of at least two
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steps 5 hours now and 5 hours in the future. Gives time for CFP [professionals] to incorporate extra training time and
evaluation of most positive training to help your business.
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period. Seems like reasonable addition.
• Increasing the Ethics CE requirement from 2 hours to 4 hours Seems like reasonable addition.
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• Expanding the professional activities that qualify for CE credit How many CFP [professionals] are familiar with
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capstone course grading panels? Does this really reflect a high percentage of practicing CFP [professionals]?
• Implementing a "50% cap rule Again this seems like a large increase in one step from no cap to 50%. Can’t you start
with 25% cap and get some feedback over a number of years then increase in incremental steps up to possible max of
50%.
• Eliminating CE credit for completing professional licenses and designation examinations. Seems reasonable.
• Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
as “live” CE programs, rather than “self study.” Don’t understand the significance of whether CE credit is live or self
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study? Why does this matter and how does this change effect CFP [professionals] currently running a book of client
business?
• Encouraging increased rigor and quality of all CE program delivery methods. The general terms of increased rigor and
quality sounds good but what are the specific steps or deliverables the CFP Board is interested in improving? Shouldn’t
they be highlighted in some specific bullet points with more detail?
Lois Isbell, CFP
®
Rather than make it more difficult to keep our certification, why not consider making it more difficult to get the
certification.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 229 of 379
Comment
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Lesley M. Gross,
®
®
CFP , CRPC
I believe that if you are looking to increase the CE hours required to maintain the CFP designation, you need to
broaden the scope of acceptable activities for CE credit. I am employed at an investment firm and spend 100% of my
day managing individual portfolios, researching appropriate Mutual Funds and ETFs as well as working with Financial
Advisor teams and Trust Officers to arrive at appropriate investment solutions for Clients. In addition, I have a book of
High Net Worth Clients who require portfolios consisting of various investment vehicles including separately managed
account solutions. My responsibilities also include tax planning strategies that will be beneficial for my Clients with
substantive unrealized gains.
Our Portfolio Management group also participates in due diligence meetings on the investment strategies we offer in the
form of Portfolio Management meetings that take place annually which span several days and include Compliance
training. Also, my firm has mandatory internal Compliance training.
Will any of these activities be acceptable for CE credit under practice management activities?
The CFA designation currently has no CE requirement.
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My particular area is strongly considering making the CFP [certification] a requirement for the position of Portfolio
Manager.
I ask that consideration be given to granting 2 CE credits for the FPA Journals if the decision is to increase CE
requirements to 40 every two years.
I look forward to your response.
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Franklin Miller, CFP ,
MBA
Continuing Education
Requirement
®
With all of the increased CE requirements at all levels, firm, insurance, CFP [certification], etc., I find that I continually
do more overlapping coursework that adds little value to my clients. Regarding ethics the same classes again are
required at all levels and with much overlap. Increasing continuing ed requirements may not be a benefit to our clients
and will not make advisors more ethical. In fact it just decreases available time to provide client service.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
David R. Bier, CFP ,
®
CRPC , CFM, CSNA
Revision To CE
Requirements
Page 230 of 379
Comment
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
I would not like to see increased requirements. 30 hours is already more than state required CE for Insurance and far
above other licensing requirements. CFA’s have NO CE requirement. This, in my world, is only going to help the CE
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industry not the CFP [professionals]. Most of what we learn is self initiated and those who don’t stay up to date will fail
(let them).
• Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
I am not in favor of any allowance for these activities. Practice management should be done as a matter of course and
not rewarded by granting CE credits. Even more so, pro bono services should be a part of every practice and there
should be no form of compensation for PRO BONO activities, not even CE credits.
Increasing the Ethics CE requirement from 2 hours to 4 hours
Ethics cannot be taught or placed upon people, it has to be part of our nature. I have no problem with 2 hours but a
further mandate will, in reality, not help with actual ethical results.
Expanding the professional activities that qualify for CE credit
I am not in favor of this as it allows busy work to substitute for course work. Either have CE or don’t. They may be useful
things but remuneration should not be reflected in CE credit.
Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours.
These topics intersect frequently and the practical ability to delineate may work against your overall goal. General CE
across disciplines should be encouraged for a holistic practice approach. Don’t define it for the participant, let them get
help where they feel they need it most.
Eliminating CE credit for completing professional licenses and designation examinations
Agreed!
Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities as
“live” CE programs, rather than “self study.”
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I understand the issues of quality control, but it becomes Orwellian. If somebody has done the work to become a CFP
[professional], they should be ethical enough to take the tests/programs in a way that leads to further education and
learning. If they don’t, they may satisfy requirements, but they won’t grow and that is their problem. If it affects their
practice, that will quickly come to light and they will suffer the consequences in the marketplace. Also, as busy people, it
becomes more and more difficult to make specific class times at the expense of actual practice work.
Encouraging increased rigor and quality of all CE program delivery methods.
Agreed.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Mark DiGiovanni, CFP
Subject
®
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Page 231 of 379
Comment
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As a CFP Board Ambassador, I am strongly committed to all measures that will increase the stature of the CFP
[certification] designation in the eyes of consumers. Part of an increase in stature must come from an increase in the
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requirements to earn the CFP [certification] designation. I am in favor of all the proposed changes.
I am a regular contributor to www.financialplanet.org, a global forum for the financial planning community. September's
topic of discussion is financial planning as a career field. Below is the first part of my article titled "The Right Profession
- For the Right Reasons." It expresses my feelings about the importance of being properly qualified to render financial
advice:
Let me get this out of the way right at the beginning - in my opinion, there is only one kind of financial planner, and that’s
a CERTIFIED FINANCIAL PLANNER™. Those who are not CERTIFIED FINANCIAL PLANNER™s, but call
themselves financial planners, are attempting to be viewed as part of a profession for which they have not yet qualified.
They may be a world-class stock broker, insurance agent, tax specialist, whatever, but until they make the effort to earn
the one designation that the public knows and respects, they are merely riding the coattails of those who have made the
sacrifices to create a clear definition of what a financial planner is and does.
After reading the previous paragraph, it should not surprise you that I emphatically believe that anyone considering a
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career as a financial planner should have at the top of his/her to-do list the attainment of the CFP [certification]
designation. Think for a minute how profoundly our work affects our clients and their families. Based on the importance
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of our work and on the impact we have on those with whom we work, earning the CFP [certification] designation should
be the minimum entry requirement, not the pinnacle of achievement that it currently is in our profession. Physicians go
to college for eight years and endure a grueling two-year residency before they can practice on their own. Attorneys go
to college almost as long and have to pass a grueling bar exam. CPAs must have a college degree and pass a test that
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is twice as long (and, in my opinion, at least twice as hard) as the CFP exam. If we want people to see us on the same
level as these other professions, is passing a ten-hour exam too much to require?
William E. Bender (Bill),
®
CFP
I disagree with the proposed revisions to the CFP Board’s Continuing Education (CE) requirements for the following 3
primary reasons:
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• In today’s tough economic times, this is an additional cost burden being levied to CFP [professionals].
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• In today’s tough economic times, this is an additional time burden being levied to CFP [professionals].
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• I am multi-certified with over a dozen certifications (including CPA, CMA, FRM, CIA, CISA, CFE, etc.) and the CFP
[certification] is the most burdensome CE requirement for me along with being the most restrictive with the largest
monitoring process.
• I disagree with the contention that these changes are consistent with the other certifications recognized by the NCCA
and ICE.
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Hope this helps explain my position. I also disagree with any actions that will allow the CFP certification to be obtained
easier, i.e., without actually having to take the exam along with the experience requirement as I believe that will reduce
the quality of the profession. It always appears that the CFP Board wants to raise fees along with more CE and other
restrictions while allowing a lower standard of entrance. I appreciate you allowing these comments and hope they will
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be considered. I would like to see more efforts on educating the public on the merits of the CFP certification and to
promote its recognition. Thanks again.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
®
Lindy Stirton, CRPS ,
®
CFP
Page 232 of 379
Subject
Comment
Comments on the various
changes being considered
for CFP Ces
1. Increasing total CE hours required for each renewal period (every 2 years) from 30 to 40 hours.
Increasing the hours to 40 hours does not seem to take into consideration the fact that many of us are working on
financial planning matters on a daily basis. Forty hours every two years, without consideration for drive time & expense
is the equivalent of a more than weeks’ time. This will take more time away from working with my clients & the stock
market isn’t closed just because I’m taking a CE course. If this is required in addition to eliminating the CE credit
required for completing professional licenses & designation examinations, I will be spending more of my “work time” in
class and less & less time for me to do my job. This works a hardship on those of us who have our own business and
work on commission. I know that CPAs have to have CEs and attorneys need CEs. As an investment advisor, I have to
have 16 hours of CEs for most states’ insurance licenses, an addition of 8 hours for California Long Term Care and
Partnership long term care, 4 hours every two years thereafter (no reciprocity with VA); 8 hours on variable annuity
training for California, 4 hours every two years thereafter (no reciprocity with VA)long term care, 4 hours of annuity
product specific training for most states and the other odd states that require yet another a 6- 8 hour course every two
years. I also have to do about 12 -14 hours FINRA coursework annually which includes ethics coursework. Then, I have
to do another 16 hours of CEs for my company’s compliance every year. Additionally, I have to take a few courses to be
licensed to sell a new alternative investment, a new insurance products, options courses and futures training. All of
these classes add up to a lot of time spent on courses that someone else thought would be a good idea to require us to
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take without consideration for all the other coursework we must do that is directly related to our CFP [certification]. I
show a total of 122 hours every two years. I don’t take that much time off for vacation. Would you like to pay us for the
additional 10 hours of course work? I realize that some people are on salary so they get paid if they are in class or the
office. Not so for many of us!
2. Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period. Pro Bono (volunteer personal delivery of financial planning services)
How on earth are you going to regulate this? Are we going to be able to just say that we did 4 hours of pro bono service
& get a credit for it? Do we submit a copy of a financial plan with all of the personal detail blackened out? I do pro bono
financial service almost every day in counseling my clients. But I can’t give the specifics out to the board.
3. Increasing the Ethics CE requirement
Do you really think that having more ethics coursework will make us more ethical? If so, perhaps we should require 40
hours of ethics for our elected officials! Don’t forget that we have to take an Ethics course for FINRA every year, ethics &
law for insurance licenses (and more for some state that don’t have reciprocity with our resident state) and mandatory
ethics& compliance courses for our individual companies.
4.Implementing a “50% cap rule”, which will limit CE credit for any single topic area or professional activity to 50% of
total required CE hours. Unfortunately, even though I think it is a good idea to have some knowledge outside of my field
of practice, I cannot legally give tax advice or legal advice. I think that the converse could be said about attorneys and
tax specialists. If I have to spend 50% of my CEs on areas that I cannot legally use, it is not very practical. Don’t get me
wrong, I do think I should have an awareness of changing tax laws & their impact on my client’s investments, but we
need to keep in mind what is useable in our businesses.
5. Eliminating CE credit for completing professional licenses and designation examinations.
Perhaps I don’t understand the changes being suggested here. If a course has no relationship to financial planning, why
would we give credit for it or an exam prep course? If it is on topic (i.e. an insurance class), why wouldn’t it be credited?
6. Reviewing online courses for academic credit (with grading) delivered by regionally accredited colleges or universities
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 233 of 379
Comment
as live CE programs, rather than “self study”.
How much more is this going to cost us? How available and what variety will there be? This will probably add greater
expense to something that is already fulfilled online and has been for years. What time of the day/night can I take these
college courses? Why must we make everything so much more expensive & inconvenient?
Mary Stone Davis,
®
CFP
CE Requirement
changes....
What percentage of members of the board are actually full time financial planners?
How much more in fees are you estimating you’ll earn if these changes are implemented?
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I have been a CFP [professional] since 1989. I do not use the CFP marks on my letterhead or business card and do
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not use the CFP marks for advertising. I do however have a plaque on my wall indicating that I have held the
designations since 1989. I practice comprehensive financial planning on an ongoing basis and practice fee based
investment management under an RIA. I take courses in areas that I find of interest or as a requirement for insurance
licensing or firm element requirements. I have never had a complaint in 23 years and have maintained my
FINRA/formerly NASD license the entire time in good standing.
®
I can understand why you would want to implore new CFP [professionals] to a more rigorous standard but as an
established practitioner, I would be more likely to remove the plaque from my wall than to continue funding this endeavor
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with my money or my time. It will never forget how grueling it was to get through the CFP Exams, and it would be
difficult to walk away from now, but with these changes, the benefits of leaving outweigh the benefits of remaining.
Having said that, I would recommend a grandfathering provision, lowering the requirement for long term certificants like
myself, and maintaining or raising them for newer recruits.
Kyle B Whittington,
®
CFP
CE Updates
®
The proposed revisions to the CFP [certification] CE requirements seems very rationale given the ever changing
financial environment. However, if this change is implemented, I believe the CFP Board needs to take the initiative to
make sure that additional resources are available to access CE programs. Many programs now provide CEs for
attending seminars, webinars, reading articles and completing quizzes, etc. These tools are not always very broad
regarding topics and may make it much more difficult to meet the total 40 hours while also staying under the suggested
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cap rule. With the cost that it requires to maintain the CFP [certification] and to join the FPA and other organizations,
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there should be more available to CFP [professionals] to attain the CEs.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Don Popovitch, CFP
®
CE Requirements
Page 234 of 379
Comment
®
I have been a CFP [professional] since July of 1990 working with PEOPLE some with money, some without, it seems to
me the CFP [board] is more interested in academics and theory, rather than real peoples problems.
Adding more study and defining the amount of allowable credit per topic is absurd !
Clients many times seek my help and knowledge for specific problems it does not necessarily involve developing a full
blown financial plan or having them sign disclosures that we discussed the importance of some type of income , health,
or insurance protection, enough....
I laugh about your definition of Pro Bono Work and how to qualify, having to be supervised by some registered CE
sponsor, it's like CNN live at the scene.
I recently received a referral from a client of 27 years, asking if there was something I could do for her friend with
elderly parents who recently entered an assisted living facility. I visited the couple they had $80.000 in 3 or 4 stocks, a
pension, SSI and a home with a equity loan, trying to figure out how to pay the entry fee for the assisted living home
they just moved to. The couple is trying to sell there house for their needs, they have all sorts of expenses to prioritize. I
spent 8 hours giving them and their adult daughter suggestions and ideas to help in their current situation @ no charge;
that's pro bono, that ads to their quality of life, simply giving people the clear path to solving their problem.
®
Doing the street work gives the CFP [certification] designation more credibility than any ivory tower marketing
awareness programs could ever do.
I am tired of feeling demonized by the very organization I am a member of, adding more and more regulation and testing
does nothing but rob my time.
Morgan Alley, CFP
®
Jonathan Lachowitz,
®
CFP
CE Changes
I have received your recent e-mail regarding proposed changes to the CE requirements. I am strongly opposed to an
increase in the yearly requirements from 15 to 20 hours. As a practicing Virginia attorney, my CLE requirements are 12
per year. A 33% increase in CE requirements is overly burdensome, and I fail to see what benefits would stem from
such a large change.
Comments on Continuing
Education Requirement
Proposed changes
As a follow-up to my comments sent on August 24th, I would like to add some brief comments in support of my previous
message. This is in light of the post below that appeared on a message board for FPA in Massachusetts from one of the
FPA members in Massachusetts and which was also submitted to the CFP Board with respect to the proposed changes
to the Continuing Education Requirements.
The author, to his credit, mentions that “[he is the] president of the Candura Group a firm that provides continuing
education for certificants particularly in ethics”. However, in my opinion, his message when posted in such a public
forum looks amongst other things also like an advertisement. The author fails to mention any conflicts of interest [the
audience certainly contains many of his potential customers] that his comments have in influencing if the CFP Board
implements the proposed changes. Certainly an increase of 33% in the formal Continuing Education requirements as
well as a doubling of the ethics requirements would have the potential to increase his company’s revenue substantially.
One may see that the author has a strong profit motive in supporting the CFP Board’s proposed changes. From
someone who focuses on teaching ethics, I am surprised at the oversight which if looked at objectively would certainly
seem to be not in line with the CFP Board’s Standard of Professional Conduct when submitted in such a public forum. In
fact the strongest comments of the author seem to be in the area that would most affect his business’ delivery of ethics
training as a “competitor” to the CFP Board. This is nothing personal against the author who I have never met [I have
taken one of this ethics courses on-line and am neutral in terms of my opinion there], but a good example I believe of
how these issues should be considered from all sides.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 235 of 379
Comment
I am very concerned that regulatory bodies of all natures feel that evolution and improvement are synonymous with
expansion. With respect to the CFP Board, I am concerned that, like the FPA, we will drive our membership down and
lose some very good people along the way. While I believe a more ethical and educated body of professionals will better
serve the public, I am not convinced that an increase in credits required will achieve this goal. The increase in fees and
the increase in formalized education requirements are all synonymous with “tax” increases for our members.
William P. Gedemer,
®
CFP
PROPOSED CONTINUING
EDUCTAION CHANGES
Most of my clients would be categorized in the bottom third of the middle class.
My career started in the Debit Insurance business 40+ years ago. I worked hard
®
and became a CFP [professional] in 1993. I function as the "Old Country Doctor of
Financial Stuff'. I believe I serve a segment of the popUlation that is underserved
by the following professional areas ..... and definitely not by persons
competent in more than 1 area of knowledge.
Perhaps 1/2 of the people in the USA have inadequate ( or none) financial
direction ..... These people have less financial opportunities and less of a chance
of financial security. I have provided my clients with up-to date, well informed
professional services for almost 41 years ..... never a substantiated complaint.
Valuable services for my client population.
In my business I am providing the following services
Insurance Life & Health
Investment Brokerage
Income Tax Preparation
Financial Planning
I now have the following CE requirements
Insurance WI-Each 2 Years-24 CE Credit Hours
Insurance WI LTC-Each 2 Years-6 CE Credit Hours
Insurance WI Annuities-New Product/Year 8-CE Credit Hours
Investment Broker - BD-Each Year-6 CE Credit Hours
Investment Broker - FINRA-Each 2 Years-4 CE Credit Hours
Registered Tax Preparer-Each Year
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Proposed CFP [certification] Requirement-Each 2 Years
Total CE Required of ME- Each 2 Years-124 CE Credit Hours
Total Ethics (Included)-Each 2 Years-10 CE Credit Hours
Recently I am seeing a reduction in CE opportunities that provide CE credit in
more than 1 professional area. We seem to be trending toward elitism in each
area .... and perhaps by the CE providers too (sell more classes & get more
fees). It just might be easier/cheaper for the Licensing Parties keeping records
too.
I ASK YOU, THE CFP BOARD:
®
PLEASE ALLOW CREDIT FOR NON-CFP [certification] CE CLASSES I!WE MUST
TAKE. IRS, FINRA & THE WI OFFICE OF THE COMMISSIONER OF
INSURANCE HAVE QUITE HIGH STANDARDS WHEN OVERSEEING &
APPROVING MY OTHER CLASSES.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 236 of 379
Comment
INCREASING CE REQUIRMENTS IS UNLIKELY TO INCREASE THE
QUALITY OF SERVICE THAT I AND PEOPLE LIKE ME PROVIDE
..... AND IS VERY LIKELY TO REDUCE THE KNOWLEDGE QUALITY OF
THOSE SERVING CLIENTS IN THE BOTTOM HALF.
DEFINITELY REDUCING THEIR CHANCE TO ACHIEVE THE
AMERICAN DREAM!
I am definitely pro-education and appreciate your consideration of my
®
comments as you consider these CFP [certification] CE Changes. Please feel free
to contact me if you have any questions or advice on how to absorb
the mounting CE requirements I am facing !
David Pedley, CFP
Daniel J. Candura,
®
CFP
®
CE Change
I don’t believe there is a need to increase the CE requirements for the CFP. The current amount of hours is sufficient
enough. I personally have to do insurance license CE (30 hours plus 2 hours ethics) and Series 9 and 10 CE. If some
reps/advisors do not have other licenses then they may need more CE hours, but I think you would find most
advisors/reps have multiple licenses. More is not always better.
Thank you for the opportunity to provide feedback on proposed changes to CFP Board's continuing education
requirements. As a former member of the Board of Directors, I led a previous study of CFP Board's CE requirements. I
am encouraged to see some of the ideas contained in the earlier report reflected in the current proposals. I am also
president of Candura Group, LLC, a Firm that provides continuing education for certificants particularly in ethics. Over
the last five years, I have conducted hundreds of presentations for certificants and have also developed training for the
Financial Planning Standards Board (FPSB). I am generally in favor of the proposed changes but have comments to
offer on the specifics of each proposal.
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours. This is a good first step but
should go further at a measured pace. The higher requirement still trails other professions such as accounting and law.
Since we aspire to be the highest standard in the financial planning profession, I urge CFP Board to continue to ramp up
the overall requirement over the next several years. In this way, certificants and CE providers alike can adequately
prepare for a more rigorous CE requirement.
Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period. I support this change since it helps advisers to maintain and expand their practices. Thriving financial
planning practices that operate efficiently and effectively support the goal of CFP Board to serve the public interest.
Allowing firms to focus some time on these issues for credit may help expand the profession’s ability to lower costs and
serve a broader segment of the public I support capping this at no more than 10% of the required CE.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board--‐produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre--‐approved
programs on CFP Board's Standards of Professional Conduct and general ethics--‐related content. I support expansion
to 4 hours (10% of total requirement) and inclusion of general ethics related knowledge. However, I oppose a
requirement that 1/2 of the hours be CFP Board produced programming. Since CFP Board has never produced
certificant training in the past, this raises capacity and experience issues. It also represents a signiFicant shift away from
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the distributed education model that has been a cornerstone of the CFP marks. It may diminish the market for CE
providers by reducing the incentive to develop innovative and engaging training. It is also out of alignment with most
state insurance regulations that mandate 3 hours of ethics training. If CFP Board determines to begin to offer CE
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courses directly to CFP professionals by mandating their use, I suggest one hour of CFP Board on--‐ line training as a
starting point. CFP Board could increase their offerings as it builds experience and capacity. Rather than mandate that
the CFP Board have a monopoly on certain courses, I suggest that enrollment in CFP Board developed courses be
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 237 of 379
Comment
optional and That CFP Board allow approved CE providers an opportunity to develop courses that achieve the same
learning objectives. In this way CFP Board encourages CE providers to offer more courses and creates greater choice
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for CFP certificants.
Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following: Participation in Registered Program Financial Planning Development ("capstone")
course grading panels. These activities must be verified with documentation of active participation, written assessments
and qualitative feedback; Study Group Activities that meet certain guidelines; Research. Research may address future
trends in financial planning beyond CFP Board's current lists of Job Task Domains and Principal Topics. I support this
proposal since it allows greater flexibility in meeting the increased requirements and supports new and creative ways for
professional development. However, more information is needed on guidelines contemplated for study group activities.
Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. I support this proposal since it recognizes the multi--‐disciplinary nature of financial planning without
undo burdens. I ask that CFP Board clarify the requirement to describe how the 50% requirement would be calculated.
Would it be 50% of the overall requirement (20 hours, as proposed) or 50% of the requirement exclusive of Mandated
ethics (18 hours)?
Eliminating CE credit for completing professional licenses and designation examinations. I support this change but
request that CFP Board clarify that courses and materials used in to prepare for examination may be eligible if they are
pertinent but the exam itself does not count.
Encouraging increased rigor and quality of all CE program delivery methods. I support the objective. It is sorely needed
and was the impetus for my forming Candura Group, LLC in 2005. The proposal lacks specificity. I suggest CFP Board
institute a uniform system to collect customer satisfaction data from CE course participants, including any courses
offered by CFP Board. This could be conducted on CFP Board's website to assure the integrity of the data Then CFP
Board could set minimum satisfaction scores for future consideration as a CE provider. CFP Board could encourage
higher quality by waiving or reducing fees for providers with high scores. Publishing satisfaction scores of courses would
also serve to allow certificants to enroll in higher rated courses and avoid those that are sub--‐ par. In conclusion, the
changes proposed are important if we are to continue to gain the respect afforded to other professions. There is no
doubt in my mind that they are overdue, but CFP Board should allow sufficient time for CE providers to develop
additional courses to serve the needs of certificants. Thank you for your consideration.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Steven R. Seligman,
®
CFP
Subject
RE: Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Page 238 of 379
Comment
I am very concerned that the proposed revisions to CE requirements will add unnecessary and burdensome costs and
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time out of the office. If my concerns are realized, on top of the recent doubling of CFP [certification] registration fees
enacted to fund a marketing program which I don’t support and which I don’t think is effective, it will cause small,
independent certificants, such as myself, to reconsider the benefits of remaining certified and continuing our affiliation
with CFP Board.
I cannot assess the costs (to certificants) of these proposed revisions, in advance, but CFP Board can and should.
However, two specific areas of concern are the proposed (1) 50% cap rule and (2) the proposed ethics requirement
changes.
(1) I make extensive use of the free CE exams offered by Financial Advisor Magazine and Financial Planning Magazine.
These exams test knowledge in a wide variety of planning areas, including insurance, estate, retirement, investment,
and tax planning. I can’t tell under which topic area the results of these exams are reported, but the exams are quite
diverse. If, for example, they are reported as “general principles”, capping the allowed use to only be accepted for 50%
of the CE requirement would probably lead to unnecessary and burdensome expense of purchasing additional CE
testing, or time out of the office to attend conferences every year. If the cap is implemented, free and diverse testing,
such as that offered by Financial Advisor and Financial Planning Magazine, should be exempt from the cap.
(2) I currently use free ethics curriculum and testing offered to investment advisers by the Vanguard Advisor website. If
the proposed changes to the ethics requirement, result in requiring paid content or testing, or require attendance at
conferences or seminars, this too would cause burdensome expense and time out of the office.
CFP Board should not adopt these proposed changes until it has done a complete cost impact analysis, especially as it
relates to small, independent certificants. It should report its findings to the membership, and allow ample time to
comment on the cost analysis.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Mark O. Flaherty, CFP
Subject
®
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Page 239 of 379
Comment
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours. Concur
Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period.
Concur on limited practice management CE but do not agree that it is CFP Board of Standards responsibility to
encourage pro-bono activities which are best left to the purview of other professional organizations.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content. Concur with reservations. The
restrictions on providing CFP Board produced Ethics are welcomed in order to raise the standard of this presentation. If
similar restrictions are placed on the “programmable” hours, delivery becomes very difficult unless easily accessible
(universal). Recommend define the terms and establish the program to define the hours necessary vice set the hours
and let content expand to fill the requirement.
Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following:
• Participation in Registered Program Financial Planning Development ("capstone") course grading panels. These
activities must be verified with documentation of active participation, written assessments and qualitative feedback;
• Study Group Activities that meet certain guidelines;
• Research. Research may address future trends in financial planning beyond CFP Board's current lists of Job Task
Domains and Principal Topics.
Concur with reservations. The intention of CE is to increase the professional competence of the individual which the
listed activities would provide. However, the activities that will be forwarded for consideration could become a
substantial burden for the Board.
I am particularly concerned about the “documentation” and efficacy of “Study Group Activities” [undefined].
Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. Concur with reservations. Recommend change to read: “…, which will limit CE credit for any single
topic area, professional activity or single event to 50% of total required CE hours.”
Eliminating CE credit for completing professional licenses and designation examinations. Do not concur. The list of
professional licenses and designation exams should be specific and limited after CFP Board of Standards review.
Completing these licenses and designation exams does increase the professional knowledge of the certificant and
should be recognized with some reasonable level of CE award.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Waylon F. Peterson,
®
®
CFP , CTFA
CFP CE changes feedback
Page 240 of 379
Comment
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These proposed changes could lead to increased costs to maintain a CFP [certification] designation so please be
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understanding of the fact that we need to control expenses or many advisors will drop their CFP [certification]
designations. (I recently stopped my FPA membership because of the cost.)
I am fine with expanding the number of required CE hours as long as it becomes more affordable to take those exams.
Other required CE, like life and health insurance CE, should always be accepted as CE in the future. Make it automatic
reciprocal treatment of CE.
I support the CFP Board reviewing the online “self-study” courses to ensure the courses are valuable, but please
understand it is much more expensive to take live courses.
®
I am the person who makes the decision at our credit union on who should earn their CFP [certification] and if the credit
union should pay for the classes to earn it as well as the CE hours to maintain it, and if these CE changes lead to higher
costs, I will need to discourage future advisors from earning this wonderful designation that I am proud of.
John B. Morrow, CFP
®
Increase in required CE
I would suggest that with the proposed increase in required hours, that the Board might consider allowing carry-over of
excess hours earned in each CE term. Frequently we have excess hours during the period and it would be helpful to
apply that excess to future requirements. This would save both time and money.
Jason R. Muench,
®
®
CFP , CRPC
CE requirement proposed
changes
I believe these changes would help to keep and improve the integrity of the CFP [certification] designation.
Joseph L. Gagnon,
®
CFP
Proposed Revisions to CFP
Board’s Continuing
Education Requirement
I vote we do not change the current continuing eduction requirements in any way, shape or form.
Personally, I have an SEC, insurance and CFRC license which also require continuing education.
®
Like myself, most of the CFP [professionals] I know also have multiple licenses.
Enough is Enough. Once again, do not change the current continuing eduction requirements in any way, shape or form.
If you are confused with my response, please call me at 805-564-4196
new CE requirements
It has become quite costly for solo practitioners to get CE requirements filled.
I think 30 hours is adequate.
Ethics could be changed from 2 hrs/year rather than 4 hours with a broadened program.
Remove the fee to certify hours from recognized organizations like the AICPA or the various Bar associations.
Vivian K. Holzer, CFP
®
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
W. Lawrence Buck,
®
CFP
Continuing education
Page 241 of 379
Comment
The current continuing education requirements do need some modifications but many of these proposals seem
counterproductive and overly burdensome.
Most courses one takes for CE credit cover multiple areas such as insurance, tax planning and estate planning. How
are you going to decide which area gets the credit? Often the best topics that are the most helpful in practice do cover
multiple areas. This proposal will push creators of CE courses to limit discussion to only the area being covered and
ignoring other areas that would have a meaningful applications.
Further the increase by 33% in the number of CE hours required seems overly burdensome. 40 hours is one work
week I would suggest a 3-5 hour increase is more acceptable.
I like some of the ideas on ethics and improved quality control.
Ruby Yap, CFP
®
Edmund F. Di Leone,
®
CFP
®
T. Lee Eubanks, CFP ,
®
®
CLU , CWS
Steve Hawkins, CFP
®
CE requirements
I agree with the proposed 40 hour increased requirement especially the increased ethics hours.
CE credits increased
I am absolutely opposed to these changes. We are already burdened with firm compliance and educational product
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requirements that add up to 15 hours or more. Also other non CFP [certification] licensing requirements easily add
another 25 -30 hours. This does not even scratch the surface of what I have to learn in the course of conducting my
business in the areas of keeping current with the tax laws, retirement planning, estate planning and investment
research.
This is not helping. I am firmly against it.
®
Help us promote the value of the CFP [certification].
CE
I wanted to comment on the proposed CE requirements. I believe that additional hours are unnecessary addition to the
CE requirements adding to the burden, complexity and expense already placed on planners. Additional hours will not
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accomplish anything. It seems the additional fees the CFP board is charging the CFP [professionals] is just generating
more bureaucracy and spending by the board. If 10 hours are better, why not a 100 more hours? This process is akin
to government raising the minimum wage. You would be better served by eliminating anyone with even one bankruptcy
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on their record if you really wanted to do something constructive about CFP [certification] quality. I continue to be
disappointed by the direction and ideas of the current board.
CFP Changes
I don’t agree with the CFP [certification] changes for designation courses. I have signed up for the CLU program and
one of my reasons is that course will give me several CE credits which I need and they are in the Protection planning
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section of CFP [certification] program. Why would you penalize someone for gaining knowledge?
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I could go take some Life Insurance courses and gain knowledge AND Get CE?
But If I take the CLU program and gain knowledge about Life Insurance It won’t count?
Am I understanding this correctly?
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Cornelius Henry Van
®
Zutphen, Jr., CFP
Subject
comments on proposed
revisions to CFP Board's
CE Requirements
Page 242 of 379
Comment
I appreciate the increase in total CE hours required and the increasing the quality of the CE (rigor) for CE
I appreciate the increased Ethics CE requirement and the additional of allowing study group that meets certain
guidelines
I appreciate the 50% rule which structurally requires the certificant to expand CE beyond a particular area of intense
interest
I applaud the Practice Management as part of CE – even if limited
I believe that Courses taken online or in a classroom for academic credit from regionally accredited colleges and
universities should be given FULL CREDIT and should be recorded by the CFP Board regardless of the certificant
having satisfied CE requirements for a reporting period
In addition, when a certificant contributes to the body of knowledge CE credit should be provided (FULLY) and the
credits should be accepted regardless of the certificant having satisfied CE requirements for a reporting period
These two areas allow for a ON THE RECORD of education and contributions and the certificant should be recognized
by allowing the full recordation of such accomplishments
I am uncertain that a certificant who achieves a Chartered Financial Analyst Chartholder does
not deserve CE credits for this achievement – although she should certainly receive CE credit for completed coursework
and successfully passing exams
Maureen McCabe,
®
CFP
ce changes
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I don’t know how many CFP [professional] designees hold other designations but for me, I have a CLUPACE and State
insurance licenses which require CE as well. These are not on the same 2 year dates and many CE programs do not
bridge all designations which means I spend a lot of hours doing CE. It is already burdensome. I understand the logic in
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expanding the requirements but at what point is it enough. Why not make the ability to become a CFP [professional]
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more difficult. Anyone who has spent the time and YEARS ( in my case) beings a CFP [professional] deserves to be
recognized for that accomplishment and it must be assumed that we work hard to keep current. Taking more CE will not
make us better only less productive.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
James W. Watkins, III,
®
®
J.D., CFP , AWMA
Subject
Proposed CE revisions
Page 243 of 379
Comment
Overall, I think the proposed changes are good. Increasing the overall hours would bring us in line with other
professional groups, although I've always been of the opinion that the issue should be quality over quantity. I especially
like the elimination of credit for professional licensing and designation exams and the proposed cap rule re any one area
of study.
I do not agree with the proposal to increase the required number of hours of ethics hours. As a fellow attorney, I'm sure
that you have heard of the joke about legal ethics being an oxymoron. Unfortunately, over my 25+ years of practice, I've
found that to often be true, both with regards to attorneys and judges.
I think Will Rogers summed up my position re ethics courses when he said that "I don't think you can make a lawyer
honest by an act of the legislature. You've got to act on his conscience. And his lack of conscience is what makes him
a lawyer." If someone is dishonest, no amount of ethics training is going to change him/her. The recent scandals on Wall
Street and in the financial services in general certainly have not improved the public's feelings about the financial
services industry.
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My experience with CFP [certification] related ethics presentations has not been favorable. I've been to some
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excellent presentations. I've have been to far too many CFP [certification] ethics presentations where the presenter
and the attendees have laughed off the whole presentation and turned it into a comedy skit. I hope to be able to work
with the Board and blend relevant legal principles and some of the Board's case studies to produce some meaningful
ethics presentations.
As long as the proposed CFP [board] produced ethics material is not expensive, I think it might have the most merit.
However, for the reasons stated, I would not be in favor of increasing the required number of ethics hours, as I do not
think it would result in any meaningful impact.
Thank you for providing me with the opportunity to comment.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Bruce Kentfield, CFP
®
New Revisions to CE
Requirements
Page 244 of 379
Comment
I would like to add my comments to the newly proposed CE requirements.
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1) I do not feel that adding 10 more CE hours will make me a better CFP [professional]. I understand that many need
ethics training, but perhaps those that have been disciplined by the Board need more CE hours, not the general
population.
2) I also disagree with telling us what areas we need to take our educational training in. You must think that we do not
have the ability to think for ourselves and that you need to take us by the leash to lead us.
3) I have no problem giving credit for pro/bono or practice management programs. For those who do this work, I applaud
them.
4) I also disagree with eliminating CE Credit for designation exams. Think about the time spent trying to qualify for a
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CFP [certification] designation. These are high learning times. Grading on Continuing ed. courses - Are you kidding?
Do you have nothing else to do?
You must realize that we are also trying to run practices. We do not need to go to school again.
Respectfully,
P.S. The finest compliment I can receive is an introduction to friends or colleagues from an appreciative client.
®
Kenny Divelbiss, CFP ,
MSFS
Proposed Changes in CE
requirements
Having 30 hours of CE that would be more stringent or significant than simply adding ten hours makes more sense to
me. Time is valuable and many of the CE programs hold little pertinent planning education.
The proposed 4 hour Ethics requirement is also a questionable use of our time in my opinion. It’s difficult enough for
providers to accumulate 2 hours of material as it is.
Would a requirement to attend a planning conference at least every two years be a viable solution to “enforcing” learning
and staying up to date?
I love learning and being as knowledgeable as possible but abhor time-wasting activities.
Robert A. Lee, RFC,
®
CFP
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Brian L. Dietz, CFP ,
CFA
CE changes
The regulatory environment is becoming overwhelming at each and every level of oversight and I oppose any increase
in the CE requirements.
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These CE changes are a great step toward enhancing the stature and credibility of the CFP [certification] designation.
I wholeheartedly support such efforts to raise the professional bar.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Gregory L. Nebel, CFP
®
Comments on proposed
CE changes for CFP
Joseph D. Jackson,
MBA
ChFC, CLU, CRPS,
®
CFP , AAMS (several
others that I've dropped)
Page 245 of 379
Comment
In reviewing the proposed changes it is unclear who benefits. My practice provides a holistic experience to better serve
my clients, and the amount of "required" CE credits from all licensing boards, designation boards, FINRA, the Firm,
Insurance companies, and the State has become a significant burden. The danger in continuing to add requirements
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and cost, which you have done in the few years I have been a CFP [professional], always forces an evaluation of the
worth of these designations to my business and my Clients. I have known professionals who have decided you are not
worth it, and dropped the designation. We worked hard to obtain our designations, and we did so to better serve our
Clients, but you obviously think you must force an ever more burdensome accounting system of CE on us. We all have
accepted there must be some minimal system to protect the designation, but maybe you should give it a rest. I would
rather spend my time helping Clients than navigating through all your CE rules. Looks like government at its worst, with
too much time on their hands and on my nickel to boot.
Several comments:
1. Pro bono work counting as CE is ridiculous. It, in no way, increases knowledge, and those who volunteer countless
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hours in other ways should not be required to do more than those who do pro bono CFP [certification] work. Those of
us that consult with dozens of people a year, without a charge for the consultation, are always doing pro bono work,
without it being officially listed as such.
2. Those of us that have other designations, which 90% of us do, would all agree that the continuing ed requirements
should count towards multiple designations. The only reason they don't is simply because all the different organizations
want the revenue that CE requirements generate. I'm working on obtaining a CPA designation simply for the credibility
that it carries with clients. The continuing ed for the CPA, as well as the college level accounting classes, should
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definitely count toward CFP [certification] continuing ed. It is hilarious how basic some of the CFP [certification]
continuing ed classes are that actually count, relative to an intermediate tax class that has real life "applicable"
information.
3. 30 hours is enough. Just because it has been 30 hours for years does not mean it's not sufficient. Going to 40? Why
not 80 or 100?
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I do value the CFP [certification] tremendously. Making it more expensive and time-consuming to maintain DOES NOT
INCREASE IT"S EFFECTIVENESS. The program required to obtain it in the first place is what makes it legitimate.
Neil P. Downing, CFP
®
Proposed increase in ethics
CE requirement
Mandating a two-hour CFP Board-produced ethics program is fine, but should absolutely be made available at no extra
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charge to CFP professionals.
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CFP Board recently implemented a sharp increase for renewal for CFP professionals. The increase should more than
cover the cost of a CFP Board-produced ethics program.
In other words, the proposed program should not be, in effect, another way to raise revenue for CFP Board.
Thank you for the opportunity to comment.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Scott Heess, CFP
Subject
®
Proposed changes to CE
Page 246 of 379
Comment
No thank you on all fronts to expanded CE. Structuring my learning to fit my business and the demands of my clients is
critical to my success and regardless of how well intentioned the additional structure that this council is proposing may
be, it will be a hindrance and imposition in that it is and will continue to be another person’s opinion and not my own, a
conflict between how I should be learning and spending my valuable time. Besides, CE is not a substitute for knowing
where to find information or how to apply it. The materials are generally outdated when you study them while
speculating on multiple future possible outcomes that never occur. While I am not surprised that a council comprised
largely of academics is recommending that we spend more time and money on their products, at this juncture I prefer
independent study and research to find reliable experts and specialists offering cutting edge sources of information to
remain competent. In fact, relative to the rigorous daily reading and learning that is an integral part of this business, I feel
that any amount of miniscule CE reporting that the board could require is nothing less than a burdensome insult. I
certainly hope the university I attended doesn’t decide to jump on this continually feed academia scheme bandwagon or
revoke my diploma. With this viewpoint, it is my contention that I earned the designation by passing the comprehensive
exam, while in that very act demonstrating an ability to grasp the material and nothing more. I think it should be entirely
up to all of us individually to remain abreast of changes in applicable law without having to augment CE reporting while
sacrificing time, talent and treasure to a morphing bureaucracy growing up around what is otherwise a fine program. To
be subjected to the various whims and influences of a board creating new rules and additional conditions after the fact is
bad precedent and is not why I entered the program. If there are those among us who insist that a mere ten hours of
addtional approved study per year will somehow make all the difference for them or an extra two hours of ethics will
make them more ethical, then they should be offered the opportunity to earn a gold star – literally. As for me the existing
structure is sufficient.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Chuck Houser, CFP
Subject
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Proposed CE requirements
for CFP designation
Page 247 of 379
Comment
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I am writing to express my opinion and opposition /resistance regarding the proposed revisions to CFP [certification]
license renewal, specifically what appears to be a drastic change to the CE requirements. I have held the designation I
believe since 1987. In addition, I hold the CIC, CLU, LUTCF professional designations and also have a Series 7
Stockbrokers license, life and health license and property and casualty insurance license. I own an independent
insurance agency and employ many people.
1) Please consider the tenure of some of us! Other organizations have actually grandfather rules that give respect to the
time one has held the professional designation and given experience – there is NO substitute for experience!
2) Increasing time needed in CE credits can be a burden not just in time but in costs- we are working in a “more
competitive than ever” fast-paced lifestyle environment where time to actually EARN a living is fading
3) The idea of possibly having to have to show CE in several different discipline areas bother me for many reasons:
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a) Some of the CE that is NOW approved does not really provide meaningful education to a CFP [certification] rather it
can be approved yet be fairly basic information that is contained in a course rather than technical and meaningful.
b) CE is not required for ALL of my licenses including the stockbrokers license – it would be nice if you would consider
some of these as well. I am also required to do CE for the CIC designation EVERY year.
c) Some of the CE that I have taken in the last couple of years has been a bit difficult (at least in my humble opinion!) to
get approved. Example: Ruble Graduate Level courses that are only offered to those of us that hold the CERTIFIED
Insurance Counselor (CIC) designation – these courses are “high-end” and since you no longer seem to have a
relationship with the SCIC ( The National Alliance for Insurance Education & Research, http://www.scic.com/ ), it has
been challenging to show the Board why ALL of those hours are top-notch and meaningful learning that should be
counted. There has NOT been one time (and I have taken these for many years) that I have not learned many things
that I did not previously know or found out that I was mistaken about a particular issue- despite 30 years in the business!
Often it is scary to learn how much you do not know!
d) Tied in to item b is the pure time and work involved in the current process in getting approval. It appears that there
has been an effort to force us to take “approved” courses in order to satisfy the renewal process and this can be a
burden to those of us that prefer LIVE instruction that is NOT on-line due to travel time and expense. The pain of getting
my CE approved is mounting while I feel that I am taking some pretty good and difficult “stuff”!
e) What is wrong with being a specialist in one area over another? I specialize in insurance and it constantly overlaps all
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areas of the CFP [certification] disciplines and since this is where I make most of my money, this is where I want to
spend most of my energies! I am not interested in getting into just taking a course to satisfy what may be a new licensing
requirement! I know what I am good at and where I am weak and I tend to not go into the weaker areas to practice
without proper support of other professionals.
f) The designation itself is not as meaningful or as well known to the general public as let’s say CPA and I do not feel
that increasing the CE will change that at all. Our industry has more professional designations out there than people in it!
g) While I consider myself to be a professional, the idea that somehow that I am held to a HIGHER level of care than say
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the brand new planner (that knows very little or has very little experience) bothers me- I am speaking not of the CFP
[certification] standards but of the idea that if I am sued over an errors or omissions claim that the courts will use my own
education against me while my competitor that has the same license and do the same “damage” did not bother to
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pursue or perhaps could not pass the test to obtain the CFP marks or other professional designations!
h) The number of hours of CE approved/taken is NOT necessarily a true indicator of one’s ability and knowledge to
practice but it can be an indicator of how much time and money they have on their hands. I would challenge you to show
me the proof that shows one is more competent because of the number of CE hours that are logged!
I also feel that we have way too many competing organizations in our profession. Too many organizations are really
trying to make money at providing CE courses. Too many organizations are coming up with all types of different
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 248 of 379
Comment
professional designations to make individuals sound like they too have good “credentials” while often the way you “earn”
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them are not very meaningful. Please CONTINUE to make the entry requirements to EARN the CFP marks tough – this
weeds folks out up front without penalizing those of us that have been around a long time.
I appreciate the fact that I was asked to express my opinions and hope that you will reconsider some of the proposed
changes as it certainly may lead to a significant loss of designees and may keep many others from pursuing the marks
all together – I for one, may be one of those. I not convinced that tightening the reigns is a good idea. I would rather see
more and better enforcement of what is in place now and better publicize those that are making us look bad – the public
perception of “financial planners” is not very good. Despite that, I have been proud to be allowed to use the marks and
hope that this can continue as my track record so far has been flawless and I have been proud to use the CERTIFIED
FINANCIAL PLANNER™ marks.
PS I admit that I am partial to the CIC (http://www.scic.com/ ) programs and especially the Ruble Graduate level
seminars, but if it were not so hard to show the Board that they also teach things outside of just the insurance discipline
it would not so difficult to show enough CE to satisfy the new proposed regs. Often you can take courses that are in
areas such as retirement planning, senior care, estate planning, etc. but since they are often just a PART or SEGMENT
of the entire course, it is difficult to get approval from you on CE. During my last license renewal, I settled with you on
approving a few hours of CE even though I had 20 hours for just one course- you folks made it too difficult to try to show
you what the course entailed and I “gave up” knowing that I had enough to pass the 30 hour requirement. I hope we are
not competing with each other as I was disappointed to see that they no longer are automatically “pre-approved”
sponsors/ vendors for CE. While I see a list of 1363 according to your website, I doubt many of them are as good as
what I have been doing all along.
Thank you.
Glenn Van Gieson,
®
CFP
Denise Brown, CFP
Jonathan Sweeney,
®
CFP
®
®
CE proposed changes
I am against increased hours. Many of us must complete CE for insurance, mortgage broker/originator besides CFP
[certification] designation. Increased hours would simply place more burden on us to maintain and operate our
business.
new proposed CE
requirements
I am against the proposed change in new requirements for CE. I do realize financial planning changes with each and
every year but I believe changing the current CE programs to adapt to those changes should be sufficient to keep us up
to date. With more CE required, more money is being made by CE providers. We have already been asked to pay
additional money each year to keep the certification rather than every two years at renewal ad in years past. Now this
requires additional money and time. It does make me wonder if this is to help me as a certificant or if it is to increase
profits. I will do what’s needed to keep my certification because I believe in what the certification stands for but
expanding the scope of current CE courses rather than increasing hours seems to be a better way to me. Thank you.
Input on Pending CE
Changes
I am writing to respectfully request that you keep the current CE requirements in place without adopting the onerous
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changes you're considering. I wear many hats as a CFP practitioner for Navy Federal Credit Union managing clients
and education of prospective clients, monitoring their plans, keeping up to date on the market and products along with
your current CE requirements. I feel your current high standards with the CE requirements are sufficient when you take
into consideration the workflow of real life practitioner.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 249 of 379
Subject
Comment
Thank you for your time,
Judy Perez, CFP
®
Proposed CE Revisions
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The CFP Board may feel the need to appear as if it is moving forward by asking CFP [professionals] to answer endless
hypothetical questions in increasing Continuing Education, but in fact you are moving "our" organization backward.
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Increasing CE hours takes each CFP [professional] out of the real-world testing environment: Their interaction with
real-world clients, getting to know their changing risk tolerance, insurance needs, investment needs and estate-planning
needs. The research required to answer these questions provides the ongoing learning experience so much better than
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answering hypothetical questions on a computer or in a seminar. Each CFP [professional] is tested on each
appointment by their clients. The research required to answer each client's questions and challenges is the true
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continuing education all CFP [professionals] undergo daily. The clients' financial success is the CFP [professionals]
grade.
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Have you forgotten the extremely-difficult test(s) all CFP [professionals] must pass to become CERTIFIED FINANCIAL
PLANNERS™? Many of us have proven our ongoing knowledge by keeping hundreds of satisfied clients for many
years. In my case, it's been 25 years in business with no complaints.
If you are reacting to individual complaints or problems, sanction those individuals! Require them to complete more CE
for two years, etc, but don't knee-jerk into wasting all our time with more CE, while asking for more money.
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Many of us built large client bases using our CFP [certification] credentials to open doors. We value the CFP
certification, but as some members near retirement age, they may not "need" these initials behind their names if the cost
in time and effort and money continues to increase. By increasing "busy work", you could very well lose a significant
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number of CFP [professionals].
Robert J. Sullivan,
®
CFP
Comments
®
The proposed revisions look reasonable to me. That said, as a practitioner of 34 years and CFP [certification] for 28
years, I think my biggest frustration is that you have not allowed credit outside the “core” planning areas.
In my opinion, there is great value for all practitioners to be well versed in the core competencies, but we also need lots
of “soft subject” knowledge and experience, along with practice management skills. The best technician will not serve
his/her clients well without strong “people skills”, complemented by diverse business/practice management knowledge.
All of these areas need to be encouraged in our profession and should be recognized as essential elements of our
ongoing professional development and training. The best way to accomplish this is to make them a part of a
comprehensive CE requirement.
The proposed changes seem to be moving in this direction, so let’s do it!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 250 of 379
Comment
Jude T. Stambone,
®
CFP
Re: Updates from CFP
Board, August 30, 2012:
Study Measures Value of
®
CFP Certification
RE: Comments on the proposed revisions to the CE requirement
I think it's a bad idea.
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It will cost more money to keep up with more CE requirements for your CFP certificants which are paying to keep the
organization going. Certificants like me have shown an increased awareness and engagement toward keeping a high
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level of knowledge in financial planning and principles. I paid for and studied for the CFP [exam]. Certificants have their
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own firm requirements to keep them up to speed as well as CFP [certification] current standards. I don’t think adding
the encouraging statements of increased rigor and quality of all CE programs and methods is a rationale to have me pay
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out more money when I have already voluntarily paid for and achieved CFP [certification] status.
Eliminating some of the ways certificants receive eligible CE credits and adding other ways which will cost more money
to acquire credits is not a good idea.
Gary T. Kolodziejczyk,
®
CFP
CESponsor
My immediate reaction to these changes is not favorable. What is the justification? What has happened in the CFP
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[certification] world that someone feels more stringent requirements are necessary? The CFP [certification] cost has
already doubled (don’t care for that) and now additional requirements will not be accepted by how many? One fears the
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loss of this designation without justification. And if I was to get another securities license and can’t get CE CFP
[certification] credit? That would make no sense.
CE Comments
I agree that 30 hours every two years is light and more hours should be required - 40 is acceptable and eventually
should be increased.
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Michael Moberly, CFP
®
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Would love to see large recommended coursework that enhances the knowledge of CFP [professionals] compared to
FA peers. Many ways this could be done, but just some suggested coursework from CFP Board would be terrific.
Perhaps the coursework would point to key changes across the 6-7 broad subject matters (tax, investments, estate
planning etc).
Not sure about the ethic’s increase. Ethics is usually the most mundane and onerous part where I feel I’m not receiving
much from it – I know it ‘s necessary but increasing it? Hopefully it’s interesting, I prefer to keep it at the two.
Thanks so much,
®
John A. Macon, CFP ,
SIMC
RE: Updates from CFP
Board, August 30, 2012:
Study Measures Value of
CFP(r) Certification
Leave the C.E. requirements at 30 hours every two years or you will lose certificants.
The burdens of internal and other regulatory requirements have been increases so
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much that something will have to give. The CFP [certification] is the path of least resistance and
greatest cost.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Carol Anderson, CFP
®
Page 251 of 379
Comment
I strongly oppose the increased CE requirement being considered by the CFP board. I
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have been a CFP certificant for over twenty years. See my "bullet points" below".
• If not weekly, monthly as a practicing planner I am constantly learning new
information for clients. Sometimes it is possible to receive credit for the
learning but most of the time it is not. Adding additional "credit only" hours
would not further my learning, it will only hinder the time I have to spend
with clients and focus on their needs.
• I typically attend the national convention every other year and often obtain 1020 hours of the CE currently required. Due to my years practicing however I
rarely learn more than a few hours of "new" material and often leave feeling I
could teach the sessions. If additional hours are required I fear practitioners
will not be furthering their learning which the spirit of the CE .
• In addition, for anyone associated with a national brokerage firm there are
additional CE requirements for each firm. I sometimes wonder with all the
rules/regulations/CE requirements for planning, security license and insurance
if I am not spending more time on regulations than practicing.
I take seriously the ethical and professional oaths of a planner. Additional
education is not going to alter my dedication to the field.
Thank you for requesting comments.
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Gary T. Kolodziejczyk,
®
CFP
Nick Steinbach, CFP
®
With all these proposed changes and the doubling of the CFP [certification] renewal fee I will seriously consider not
renewing. This designation is not a license to make money. It does not open doors of opportunity nor increase my
commissions.
CFP
I think it would be wise to keep the CE credits for completing other professional licenses/designations per your emails as
long as it pertains and is consistent with the area of financial planning and topics. In addition if the board does adopt
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more required CE hours from 30 to 40, plus increases ethics from 2 to 4 hours that will help many CFP [certification]
holders with those new requirements too.
I would hate to see those other designations and competency level decline because we could no longer receive CE
credit for those courses that are very valuable to our current and future clients in the field of financial planning.
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A side note that I think it wise to consider is that many CFP [certification] designation holders will continue to face
increase regulations and other mandates from a wide variety of areas too that must be fulfilled.
In my opinion I think it is ok to increase the requirements because the field has been changing so rapidly and will
continue to do so, but let’s also help our fellow colleagues meet these new requirements as efficiently as possible, in
addition to all of our other professional responsibilities as well.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Carol M. Zitzelberger,
®
CFP
Subject
Page 252 of 379
Comment
It is wholly agreed that in order to maintain the highest of standards attached to the CFP Board it
is necessary to create a robust and extensive continuing education program.
With respect to the time and effort the Board has devoted to the revision of the CFP Board's
Continuing Education Program I offer the following comments:
• Increasing the hours from 30 to 40 over a 2 year period is over burdensome. It is
agreed that knowledge and practices are in a continual process of change however
2 hours from the CFP Board-approved program and 28 additional hours continues
to be more than adequate to demonstrate financial planning and to meet the
requirements of an ever changing industry. In addition continuing education can
be costly. In this time of decreased margins and increased business costs this
would be one more additional burden that would have to be individually taken on;
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• So much of any CFP [professionals’] practice incorporates pro bono and practice management.
In most cases it would not be possible to have a CE Sponsor oversee the pro bono
work. Many wonderful programs in need of pro bono work would suffer;
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• Increasing the Ethics program would serve no purpose. Most CFP [professionals] hold other
designations that also require ethics training. Increasing the ethics training will
not decrease unethical behavior;
• It is agreed that by expanding the professional activities that qualify for CE credit
will broaden the scope of knowledge;
• Also in agreement is a "50% cap rule" this allows for better diversification of
industry practices;
• Eliminating CE credit for completing professional licensing and designations
would eliminate potential growth of a planner. It is agreed that the list of
designations should be better qualified so as not to allow for frivolous
designations. However acquired FINRA, Insurance and SEC designations and
continuing education for each should be permitted. These designations are highly
regulated and also require extensive continuing education.
• Making online courses for academic credit, with grading by accredited institutions
rather than "self-study" will serve no purpose other than to generate income for
the academic institutions. It is suggested that both be permitted. In order to stay
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current a CFP [professional] will continually read publications and attend sponsored meetings.
• It is agreed that the Board must continue to vigorously increase rigor and quality
of the CE Program. This is evident with the current program as is.
For my Advisors that are able to hang the shingle of CERTIFIED FINANCIAL PLANNER™ [certification] it is a source of
pride. They continually strive to have a greater knowledge base through training, continuing education and individual
drive. Unfortunately the Board is making it more and more difficult by suggesting new extensive and costly continuing
education and increasing
membership dues by almost 61% annually.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Frank Scanlon, CFP
Subject
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Comments on CE
proposals
Page 253 of 379
Comment
Some quick comments on the proposed CE changes:
* An increase in the number of required hours, from 30 to 40
• My feeling on this is contingent on the acceptance or rejection of other proposals, specifically:
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o Broadening the list of activities that qualify for CFP [certification] CE Conceptually agree
o Eliminating CE for completion of professional licenses and designations Strongly disagree. Learning in related fields
should be encouraged, not discouraged. How can a policy contrary to this be considered a "best practice"? This almost
contradicts the rationale for the proposed broadening of activities change. The amount of credit should depend on the
license and designation.
o Encouragement of increased rigor in continuing education programs Agree and this is a pet peeve. I have seen
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classes very outdated still be accepted for CFP [certification] CE credit
o Granting up to four hours of practice management Conceptually agree as long as it is not a requirement. I am in a very
large organization and do little active management. and/or pro bono continuing education I applaud the concept but the
4-1 ratio is not practical, especially when it requires a sponsoring organization. I would rather do a couple of hours
without the credit than go thru the hassle of finding an organization that does what I would want to do. At 2-1 my guess
is you would get more interest from organizations and from certificants.
So, overall comment on the increased hours could be summarized as OK with it, but only with expanded quality
opportunities for CE, not reduced or impractical opportunities to achieve a higher standard.
I generally support these proposals:
* Increasing the number of required ethics hours to 4, and additional ethics program requirements
* * Capping continuing education credit from any single subject area to 50 percent of required hours
* * A change in how accredited universities who deliver content online are categorized for continuing education purposes
Thank you for the opportunity to comment.
John W. Weber, CFP
®
CE requirements
I think the current CE requirements are satisfactory and I do not agree that more hours are appropriate. If the field is
rapidly changing them let's be specific and define those areas requiring more attention. I think 30 hours is more than
sufficient if the content is pertinent. The CFP board can define ethics and 1-3 other topics as required and make sure
the content is pertinent and contemporary.
I also think that excess hours should carry over to the next certification period.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Carol K. Lampe, CFP
Subject
®
Comments to your
Proposed Changes to CE
requirements
Page 254 of 379
Comment
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I appreciate the very high standards you expect and enforce to maintain our CFP [certification] status and I am sure the
consumer does as well. I am in disagreement with increasing the required hours to 40 because more often than not, the
quality of the courses that offer the credits is not of the same standards. We sit in classes with speakers making errors,
not knowing the rules about 529 plans or retirement plans and are bored to death with the presentations. It doesn’t
seem ethical to be able to satisfy the requirement with mediocre products and to have to waste valuable time that we
should be spending with our clients. I feel 30 hours is quite adequate, unless the quality of what is offered is truly
improved.
In other words, if you want to raise the standards for maintaining the marks, please also raise the standards of what is
offered to us, making sure they classes are of high quality. And don’t offer expensive conferences in order to get the
credits if they conferences have no substance.
I like the idea of granting credit for practice management programs. This kind of help is valuable to us in running our
practices and we should be rewarded with CE credits for taking the classes. I never understood why we didn’t have the
opportunity for this before. In my opinion, one can’t be a good business person on education alone.
Thank you for the opportunity to comment.
Jeanne Peterson,
®
CFP , LUTCF, CLTC
CE Comments
I would like to express my comments regarding increasing the amount of CE required for certification from 30 to 40
hours. I received my certification in January of this year, and had to complete 19 hours, I believe, by August of this year,
just to recertify. I think the CE requirements as they stand are more than adequate, and in fact, it would be helpful if
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more seminars and other classes carried CFP [certification] CE credits. I know that I am constantly attending seminars,
reading trade journals, staying abreast of current issues. However I get no credit for most of what I do to stay current.
And while there are some free CE credits available, most end up costing money. I feel as if the increased requirement
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will not do much to increase the caliber of the CFP [professionals] out there, however it will generate income for those
that offer CE programs.
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It must also be noted that many CFP [professionals] have to do compliance training for our employer, plus we usually
have CE requirements for things like insurance licenses, and have ethics requirements for state licenses as well. This
doesn't even mention all of the CEs and recertifications we need to do for FINRA. Of course, while all of these are
®
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relevant to the CFP [certification], none of them count for CFP [certification] CE credit either.
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If you are going to increase the CE requirement, you absolutely need to make sure that you give CFP [certification] CE
credit for far more programs that are offered/required by other authorities. I feel like I have to go through so many
redundant courses, exams, etc. because no one accepts anyone else's programs, and it's all just designed to generate
income for some organization, but is obviously not just set up to make sure that professionals are competent.
I appreciate you taking the time to consider my comments.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Page 255 of 379
Comment
Mary T. Young, CFP ,
®
CRPC , ChFC
Proposed Revisions to
Continuing Ed
I believe the increased CE hours will only put additional stress on individuals without any additional benefit to the end
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client or enhancement to the intelligence of the CFP [certification] candidate. People do not have the money for all the
credit courses, the renewal fees and licenses that they have to keep already. The requirement to cap the amount of
credit in an individual topic area inhibits the ability to focus on an area where one may feel the need to focus on in any
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given year. The cost to obtain the CFP [certification] designation is already cost prohibitive to many individuals that
would strive to obtain the designation if not for the expense of doing so.
Michael J. Mussio,
®
CFP
CE Content Revisions
The only proposed change that I have any problem with is the: Maximum hours per area of expertise. Specifically as it
relates to other professional designations, in my case the CFA Charter holder designation. Each of the levels of the
CFA designation on average entails nearly 300 hours of study for successful candidate. If you are going to cap the limit
for ‘investments’ credit for example at 20 hours this is fine, however, you should consider the full body of work and the
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other areas within the various curriculums that may apply to CFP [certification] areas. For example, the Ethics
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component of the CFA curriculum is as rigorous as the CFP [certification] curriculum and could/should count for 2 of the
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proposed 4 required hours of CE for the CFP [certification].
Response to CE
requirements
To increase the CE hours from 30 to 40 is not necessary. For a successful financial planning practitioner, CE should be
an integral part of the profession and daily routine. Personally I allocate at least one hour a day on CE. But not all the
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articles/materials are CFP [certification] approved for CE requirement. So to increase the CE hours will just put more
focus on those CE materials, which may not be the most practical, useful or pertinent for each practitioner's specialty.
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Swan Shen, CFP ,
®
®
CRPC , ChFC
Thank you for your consideration.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Scott F. Hogan, CFP
®
Page 256 of 379
Comment
Comments regarding proposed changes:
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board’s Standards of Professional Conduct and general ethics-related content.
Implementing a “50% cap rule,” which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours.
I disagree with all of the above proposed changes for the following reasons.
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In addition to my CFP [certification] license I currently hold FINRA Series 7, 24, 63 and 66 licenses. These licenses are
held with ING Financial Partners, Inc. I must adhere to the diligent continuing education requirements of FINRA to
continue to hold these licenses. My Broker/Dealer has required training for each of my licenses. I am also securities
licensed in GA as well as 12 other states. The insurance industry has substantial continuing education requirements.
Each year the amount of gross revenues relative to “Assets Under Management” that I am able to generate has declined
significantly since I entered the business in 1989. This has been a very good thing for the clients that I serve as they are
able to get more for less. The amount of time I spend each year complying with continuing education is time that I must
take away from helping the very people we are here to serve each year. I do not believe that taking time away from my
clients to participate in any additional continuing education will benefit the clients that
need my service. If anything it will prevent me from helping one or more families each year.
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A qualified CFP [professional] will seek advice from a specialist when needed because we put our clients’ interest first.
Pamela Baker, CFP
®
I feel that the current requirement is sufficient. We also do ce for state requirement and broker/dealer, finra.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Catherine D Burgess,
®
CFP , ADPA SM
Subject
Comments with regard to
the new CE guidlines for
CFP's
Page 257 of 379
Comment
I applaud the continuous self-review and evaluation of our standards to maintain a high level of professionalism as well,
as knowledge. Although some ideas proposed I agree with, I do have a couple comments regarding a few of the
proposed changes.
If you are going to increase the CE requirement for Ethics, I think it is important that the CFP Board offer significantly
more options for us to be able to fulfill that obligation. I find it challenging to find appropriate venues/opportunities to
meet that requirement, and I do not feel that it should be a high cost issue either. Why is it that I can gain credit for
®
everything but Ethics without paying. The education should be about effort and intellect not getting CFP
certificants/practioners to “pay” for the credits.
As for increasing the number of hours from 30-40 every two years I’m not overly opposed, but think I’d prefer a stronger
rationale. For those of us who are ‘in ‘ the business on daily basis, practicing our skills, training and knowledge I don’t
see why taking additional hours of coursework or quizzes or exams is going to make us that much better. I’m not a fan,
but I probably accomplish it anyway already.
I am very much for the recognition of Volunteer or Pro Bono work. Specifically in the low-income or senior markets.
®
I also wonder what will be accomplished by increasing the Ethical Requirement from 2-4 hours……A CFP
[professional] is either ethical or they are not. The difference between 2 and 4 hours will not make a difference in one’s
level of Ethical Understanding. I have no problem with the CFP Board creating a two hour Ethical Course each year for
the purpose of standardizing the Ethical Continuing Education for all persons. Possibly to focus on the topical Ethics
issues each year.
*
Most importantly I strongly disagree with eliminating CE Credit for completing professional Licenses and designation
examinations. I recently pursued and acquired my ADPA SM designation. The coursework for this exam went beyond
®
®
CFP [certification] course work and knowledge but was based on a minimum CFP [certification] designation credential.
Why should I NOT receive credit for enhancing my knowledge of the subject matter in an advanced capacity? It was
much harder than sitting in a room for a few hours listening to a lecturer, or taking an on-line review course.
I think what I am seeing is a question of perception of what would make individuals better professionals vs. what would
actually make individuals better professionals. I would like to see the CFP board do a better job focusing on the
®
distinction of how a CFP [professional] is different from a Financial Advisor/Consultant/ Stock Broker/Insurance Agent
®
what have you. Create a better standard by educating the public as to what they should expect from a CFP
[professional], and if they do not receive that level of expertise, than they should move on to one who does demonstrate
that expertise.
®
I pursued my CFP [certification] designation to push myself to a higher standard of care for my clients, and higher bar
of excellence in terms of knowing what’s available and best for the end-user. I take my ethical standard VERY seriously,
and adhere to best practices in every aspect of what I do. I do take my continuing education very seriously, and know
how important it is to stay on top of ever-changing laws, strategies, markets etc. I would rather see my recurring dues go
®
towards creating a stronger sense of differentiation in the industry for CFP certificants, than making continuing
education more complex to understand and fulfill, while I’m working in and on the business every day.
Thank you for considering my comments.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Eileen Shannon, CFP
John C. Classe, CFP
®
®
Page 258 of 379
Comment
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It does not make sense in this economy, when most people have suffered financially, including most CFP
[professionals], for you to double the fees and increase the CE. It seems you are doing your best for Lobbyists rather
®
than the CFP [certification] membership.
Comment on proposed
changes to the CE
Requirement
I will be brief.
Jude T. Stambone,
®
CFP
Comments on the
proposed revisions to the
CE requirement
I think it's a bad idea.
®
It will cost more money to keep up with more CE requirements for your CFP certificants which are paying to keep the
organization going. Certificants like me have shown an increased awareness and engagement toward keeping a high
®
level of knowledge in financial planning and principles. I paid for and studied for the CFP [exam]. Certificants have their
®
own firm requirements to keep them up to speed as well as CFP [certification] current standards. I don’t think adding
the encouraging statements of increased rigor and quality of all CE programs and methods is a rationale to have me pay
®
out more money when I have already voluntarily paid for and achieved CFP [certification] status.
Eliminating some of the ways certificants receive eligible CE credits and adding other ways which will cost more money
to acquire credits is not a good idea.
Todd Scorzafava,
®
®
CFP , AIF
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I believe these are great, agree that much changes and we need to stay on top of rules and regulations. Thank you.
Comment regarding
proposed CE changes
I like the proposed changes to CE with this exception:
• Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then "cap" would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the "50% cap rule."
Rationale: Ensure diversity of learning experiences across breadth of planning topics.
Seth Kelly, CFP
®
It is my hope that the board would place its focus on a CE program of superior quality and less on an assumption that an
increase in quantity is somehow equivalent. We do not necessarily need more hours, we need better ones.
If you are pursuing another designation such as a CFA or JD you will have a concentrated area of focus. Additionally,
these professional designations are rigorous and require significant time. I think the amount of work and time spent
working toward these designations should be counted even if they are in concentrated subject matter. Requiring an
individual to shift focus to other areas in order to satisfy a broad planning base hinders his/her ability to obtain additional
specific knowledge. The only manner in which I would find this requirement sufficient were there to be an exception if a
financial planner was pursuing a CFA, JD, CPA/PFS and CLU.
Please let me know if you have any questions with my comments.
Thank you,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Christopher Ketcham,
®
Ph.D., CPCU, CFP ,
CIC, CRM, CISR
Subject
Continuing Education
Changes
Page 259 of 379
Comment
I think there needs to be a reevaluation of the purpose of and benefits from continuing education. Here are the questions
that I believe require answers before the board can consider these changes as being meaningful to certificants and to
the financial planning profession.
®
• What are the purposes of mandatory continuing education for CFP certificants? What are the explicit and identifiable
goals of this continuing education program?
• Why are 40 hours better than 30 hours? Please be specific.
• If I am required to produce evidence of 40 hours of intensive study, why must I also be required to obtain half of these
hours in a discipline for which I may not have a need to learn more information right now? At one time the board
required education in multiple disciplines but changed that. Why change it back?
• Do we have peer-reviewed evidence that continuing education has reduced fraud or other misbehavior in the financial
planning industry, insurance or other related financial professional communities? If other organizations have found such
evidence, is this evidence applicable also to the financial planning profession?
• How does the advice from legal and architectural subject matter experts equate to appropriate and applicable advice to
financial planning?
®
• Can incompetence be a reason for the suspension of the CFP certification? If so, can the requirement that a person
be competent in the products or services he/she sells/provides be an adequate measure of maintaining professional
knowledge? Do we have peer-reviewed evidence that continuing education training has reduced mistakes, errors, or
other incompetence in the financial planning profession?
• Why is four hours worth of ethics training better than two hours? If ethics training be expanded from where it is now,
which is essentially a review of the code with associated practical case studies, what will that increased breadth entail
and why is it important for certificants and others to know and to take time to learn it? Again, what data is there that
ethics training such as proposed will reduce the incidence of fraud? Has ethics training reduced the ranks of the Bernie
Madoffs’ of the financial planning world?
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Deana Smythe Healy,
®
CFP
Page 260 of 379
Subject
Comments
Comment
Per the Board’s request, I’m sending along comments related to the proposed changes:
* An increase in the number of required hours, from 30 to 40
I think this change makes sense. Given the ongoing change in the industry, it makes sense to continue to drive rigor as
®
it relates to the CFP [certification]. Given that Registered Tax Return Preparers need to have 15 hours every year, and
CPAs (in MN) need 120 hours every 3 years, 40 hours every two years is very reasonable.
* An allowance for four hours of practice management and/or pro bono continuing education
®
I think this is a good change, as it will help drive behavior and skill in areas that may be lacking. A CFP practitioner
may be technically astute but if they can’t manage the practice, their knowledge will be for naught.
* Increasing the number of required ethics hours to 4, and additional ethics program requirements
While I think that the ethics part of the requirements is important, I don’t think that most courses hit the mark. The topics
are frequently dry or uninteresting, usually obvious and frankly are unlikely to promote ethical behavior. They might
encourage better practices in documentation etc. in those who are already ethical. If that’s the end objective, that’s fine,
but I think this suggestion needs to be fleshed out more to be sure to be of value.
®
* Broadening the list of activities that qualify for CFP [certification] CE
I think this is fine, though I don’t usually have any problem finding ways of meeting CE requirements. It will likely help
make the process more interesting.
* Capping continuing education credit from any single subject area to 50 percent of required hours
This seems fine, although I think you want to be careful not to make this too complicated. You’ll find yourself needing
some sort of CE calculator to figure out what you need to pursue to finish the requirements.
* Eliminating CE for completion of professional licenses and designations
This suggestion seems to fly in the face of the one earlier (broadening the list) and in my opinion doesn’t serve a useful
®
purpose. Pursuing additional licenses does add to the body of knowledge possessed by the CFP [professional]. If it
also serves to help add additional credibility through the achievement of additional creditionals, I don’t think that should
®
be held against the CFP certificant.
* A change in how accredited universities who deliver content online are categorized for continuing education purposes
* Encouragement of increased rigor in continuing education programs
These last two seem fine, though I’m not sure I think you need to ask for comment on them.
Thanks & I hope you find the comments useful.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
David Thrasher, CFP
Subject
®
Michael L. Gloss, CFP
®
Page 261 of 379
Comment
Proposed new CE
requirements
Please note that I am opposed to the proposed increase in CE Requirements for the CFP License. Your proposal would
increase the time away from my practice by a full one third without providing any additional benefit whatsoever to me or,
more importantly, to my clients. Rather than spend your time and mine on less important issues such as this, I would
strongly recommend that you spend your time on the exceedingly important issue of the legal implications of the CFP
License. Upon advice from my attorney, my firm has stopped using the CFP Designation on any of our correspondence
or our business cards. My attorney advised us that the CFP Designation implies an impossible standard when reviewed
by courts or arbitration boards. He also told us that many other firms were telling their advisors NOT to use the CFP
Designation. This impossible standard would hold the CFP Certificate Holder liable for ANY loss endured by the client,
whether or not the client was invested in appropriate investments. In addition, it very well could hold the CFP Certificate
Holder liable for any unrealized loss if the client was invested in a safer security that did not perform to some higher
performing standard that may or may not be related to that security. This is untenable, it is wrong, and the CFP Board
should be making every effort to do away with this impossible standard.
I have been a CFP Designee for many years and I believe very strongly in the professionalism that this
designation is supposed to bring to our industry. Before entering the financial profession, I was in the engineering
profession and I continue to hold the designation of Professional Engineer, even though I no longer practice
engineering. I continue to hold this license because of my deep conviction to professionalism. Even so, the fact that I
cannot use the CFP Designation renders that designation practically useless to me. In addition, if you propose to
drastically increase the time I must spend away from my practice to maintain a designation that I cannot use, then you
surely must see what my only option can be. I strongly hope that you can see the importance of this issue.
Increasing CE requirement
I oppose the increase in required hours from 30 to 40 hours and from 2 to 4 hours for ethics. As an insurance licenced
and Registered Representative with additional designations,I am mandated to complete required continued education
for the following:
*State of Ohio Department of Insurance
*FINRA
*CFP (registered Trademark)
*AFC
*Broker Dealer as RR and IAR
*Each Individual Insurance Company represented *Company that I have a DOD contract
All are not reciprocal and all contain ethics requirements.
Enough is enough! Please reconsider!
Bruce R. Farman,
®
®
CFP , CEP , RFC
Proposed Revised
Continuing Education
Requirements
For those of us in the real world of the bordering-on-the-ridiculous continuing education requirements imposed by FINRA
over the past few years for all Registered Representatives, I would submit that the proposed revised CFP Continuing
Education requirements are not necessary … and duplicitous.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Patricia Wellman, CFP
Page 262 of 379
Comment
®
CE Proposed Revisions
A couple of comments. While I intellectually understand your rationale to increase total CE hours, you are not perhaps
taking into account the increased demand (total CE hours) in other disciplines which we must concurrently adhere
to…..fundamentally, it begs the question: are we that lax that we don’t know how to be/get informed? Alternatively,
forcing additional CE hours on us doesn’t mean that we are actually more informed and/or learning anything.
Likewise, I don’t see the need to increase the Ethics from 2 to 4; one is either ethical or not; increasing the hours will
have no effect whatsoever. And, perhaps if we stop treating one another as children (who cannot be trusted), then we
would all act as responsible adults/professionals.
®
no no no
As my representative I would like you to please stop the madness! Most of us have more than enough to do without
increasing the number of CE hours required to maintain the CFP license. I would like to formally propose we
DECREASE the number of hours required.
Craig Lindemann, CFP
Please find something else to do with your time, we don’t need more CE hours.
®
Chris Schaefer, CFP ,
CPA
Proposes Revisions to CFP
CE Requirement
I am writing in regard to the changes to the CFP Boards CE requirement. I am especially against the increase in hours
from 30 to 40. Many of us hold dual designations and the CE requirements are becoming a difficult burden to overcome.
There is not significant overlap between the various designations/licenses that we hold. For us true professionals, we
would be looking at close to 150 hours of CE each year. This will be very difficult to obtain as we are all trying to run
and build our practice.
If the CFP Board would be willing to allow overlap with other designations, then the burden would be lessened. Please
feel free to contact me with comments.
Joseph DeBonis , CFP
Geraldine Raymond,
®
®
CFP , CRPC
Brock Ayers, CFP
®
®
(none)
I am against this proposal. CFP's should be able to reap additional revenue from the boards supposed CFP
awareness program , before increasing any other requirements. The CFP Board just doubled the revenue they received
from CFP's without the CFP's realizing any additional revenue.
Expanding CE
Requirements
My preference is not to expand the number of credits required. 30 in two years is sufficient – keeps us current without
being onerous. In addition, studying to obtain the CRPC which provided me with CE credits was a great source not only
of credits but of in depth knowledge and refresher on retirement. It was probably one of the best sources of CE credits
in terms of review – not just one hour here and there but it was necessary to study, take practice exams, and really
refresh on the retirement topic.
Expanded CE
Requirements
I am opposed to the changes in the continuing ed requirements. I think the current system works fine as it is.
You are correct that other areas of practice have increased the requirements, and in some areas, like annuities, there is
significantly more
Product testing and education required. Practice management does not really apply to those who may be working for
other firms or in other capacities.
The dues increase was bad enough, but a 30% increase in requirements is extreme. CFP CE hours were already
higher than some other CE requirements.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 263 of 379
Comment
In my view, the system is not broken, so I would leave it alone.
I do not think the public would be served any better by these changes, nor do I feel it will help me or my fellow CFPs.
Gaye Wood, CFP
®
Steven Jensen, CFP
®
certifications
I actually enjoy the continuing classes that I take, BUT there aren’t enough hours in the days to complete & more
important comprehend all the rules, continuing ed for CFP, insurance for various states as well as all of our individual
firms and regulatory bodies as well as take care of our clients.
Comments
I read the proposed CE requirements and would like to make the following comments:
1) While I don’t disagree with the goal of maintaining standards, the Board should consider that most practicing
®
professionals are already engaging in CE activities beyond the CFP . If I were to combined the 40 with my insurance
and my own firm’s annual requirements, I am exceeding 100 hours of CE. And if the Board adopts the proposal that
eliminates professional license CE, it becomes an even more laborious task of collecting CE credits.
2) Increasing the Ethics portion from 2 to 4 hours sounds like a move toward higher ethical standards on the part of
practitioners but taking a class in ethics does not mean one becomes more ethical in ones character. The insurance
®
licensing, as well as our own firms CE, already has an ethics component which, when added to the 2 hours of CFP CE,
is more than sufficient to get the point across.
3) Because the Board is seeking to diversity the classes that would be required under the program, the Board also
needs to have a better reporting system to the participants. Emails that confirm completion might include a matrix
showing how that particular course not only counted but also to which type of CE it applied, i.e. ethics. In addition,
because of the cap rule, it will be important to show participants how a CE class met or did not meet the requirements.
It would be onerous to ask the participants to try and keep track of that each time we attend an event and, in most
cases, the presenter does not tell the class which category the class fits under. I see lots of confusion and frustration
over the cap issue and I would recommend that the Board not consider implementing this aspect.
Ken Eidson, CFP
®
Changes in CE
Appears to be more about finding more ways to raise revenue. Along with the DOUBLING of fees, this board is starting
to look more and more like Washington DC
Ken Eidson, CFP (since 1989, but probably not much longer)
Cheryl Dabney, CFP
®
I vote NO... for increasing
continuing education
requirements
®
I am obligated to complete many CE requirements in addition to CFP requirements. I have insurance requirements,
®
corporation requirements, FINRA and individual product requirements. I will strongly consider dropping my CFP
certification if you pass increasing the CE requirements.
Please consider… when you increase CE requirements you are really taking time away from servicing our clients. The
tradeoff between what I learn from the CE test taking does not improve what I offer clients.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Steve Doucette, CFP ,
MBA
New Education
Page 264 of 379
Comment
I really have no problem increasing all the education requirements for maintaining a CFP certification, as I usually gain
much more than I need by attending conferences.
However, it seems you are making it more difficult to meet certain requirements and trying to control all the coursework.
It will also add costs, to each practitioner for attending or buying each of the additional courses.
Additionally for senior advisors, you should consider practice management (and pro bono) as a much larger part of the
acceptable ongoing education. Much of the individual topics require us to do the research for clients and learn it in
much more detail than attending any course work. Additionally, if you do the research it will stick with you much longer
than a short course that you have to pay for and attend. All the technical skills education may not keep an advisor in
business and I think that being there for clients is the most important part of our job. Running a practice is a very
important part for most of us.
I do appreciate the 2 hour Ethics course as they make you think about all the potential things that could cross the line.
However, I really believe that 2 hours is usually enough, as most presentation are extremely dry and boring and always
cost a pretty penny.
The biggest question I have however -- Is there a problem with the current requirements? You did not provide any real
justification or rationale for why these education requirements need to increase at all.
H. Peter Petrosky, CFP
®
(none)
I strongly feel there is really no need to increase the requirements for the CFP continuing education. Many of us are
professionals who are governed by other regulatory agencies who also have educational requirements including courses
in ethics and practice management i.e. SEC, insurance regulatory bodies, and state requirements. I'm a great believer in
education to keep professional standards but there has to be a limit to the requirements one must meet. Professionals
will always rise to the occasion and those who are not, will not change no matter how many courses they are required to
take.
Stuart J. Pastrich,
®
CFP , CLU, ChFC
Grandfathering?
I can fully appreciate your desire to enhance the CE credits and requirements and for the most part and I applaud your
move in this direction.
®
Someday I would love to see the CFP up there with the Esq. and CPA designations!
One point...for those in this business for more than 30 years, I would like you to consider some “grandfathering”.
®
This is my 35th year in the financial services industry and my 25th year as a CFP
As a seasoned professional with not a single blemish on his U-4 in these 35 years, I think it would make sense to give
us some flexibility and not mandate us to meet these time consuming and more stringent requirements
Bettye Y. Kerckhoff,
®
MBA, CFP
CE Requirements
Between CE for the CFP and compliance training the firm requires I feel that more than enough hours are dedicated to
CE that it is not necessary to increase any requirements. The regulation the industry demands is enough that more CE
is redundant.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Patricia Meidell, CFP
®
V.E. “Gene” Lambert,
®
CFP , CDFA™
Page 265 of 379
Comment
Response to CFP 40 hours
CE
I think the increase from 30 to 40 for CFP designation is excessive when you consider that there are already other
requirements from Finra and our own broker dealer affiliations. To do this job, we are also reading newspapers,
other professional journals, and books on related topics to keep on top of the changing events in our industry and in
the economy. Rather than increase the number – more is not always better- be more discriminating in the Code of
Ethics portion and beef up the existing content. Be advised that we have additional code of ethics and know your
customer education elsewhere in our licensing requirements and affiliations. If I were given credit for all the
coursework and study I do, I would far exceed your 40 hours. It is too bad that the CE credits can’t be all coordinated,
but that is not the case. I vote NO.
CE chg
I'm against an increase as proposed.
If it was proposed to increase to 35 hrs every (2) two yrs I would support a change.
James J. Cha, CFP
®
Request for comment
I think that in this environment of Over-regulation/burden, we should not self-impose additional costs, restraints,
®
®
conditions or requirements in maintaining our CFP mark. The practicing CFP professionals are busy servicing our
clients, and by nature of our work, we are keeping up to date with the planning issues. That fact that we passed the test,
met the requirements of the 4 E's and currently have 30 CE credits to complete every 2 years should be sufficient in
®
recognizing those of the CFP designation. Plus many of us have CE credits to complete for the insurance, CPA, CIMA
or other designations.
®
I oppose additional or increased requirements in either obtaining or maintaining the CPF designation. Many potential
applicants will choose other designations to achieve as Over-regulation/burden will discourage applicants and existing
members.
®
Rosemary Gans, CFP
Comments on proposed
changes
I read over the proposed changes and I absolutely disagree with increasing CE requirements.
Those of us that are active are under increasing amount of requirements from our broker dealers to satisfy FINRA
requirements. Then there is the Life Insurance requirements.
I am already overwhelmed with all the requirements that is being thrown at me at this time. I am a one person office and
I would like to slow down my pace and not increase
additional CE including additional Ethics training.
I just completed my requirements for this year. I feel it is more than enough. Perhaps , these additional requirements
should be targeting at new personnel coming into this field.
Give us old timers a break already. Anyone that has survived since 90s, knows how important Ethics in our business is,
we have seen too much unethical behavior. I am glad the CFP Board addresses this issue, but more CE and ethics CE
should be for younger and inexperienced designees in this business.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Jerry A. Sackberger,
®
CLU, CFP , ChFC
CFP Requirement
suggested Changes
Page 266 of 379
Comment
I disagree with most of your changes for the following reasons:
You eliminated comparable courses and learning several years ago. And, while I agree we are living in a more complex
world with more rapid changes, you ignore that those CFPs employed by national wire houses who also have their
internal, and some time redundant courses increased. For example, I have had to take over 25 hours of internal learning
this year, some of which are redundant to what CFP requires. Yet you do not give any credit for external courses,
thereby wasting my time.
Let me expand my comments of your criteria and rationale comments:
Proposed increases might be ok, IF you allowed us to apply any and all internal courses if administered by a National
Wire House, National Bank or Insurance Company.
Ethics is ethics, you can set criteria in 2 hours and do not need to take 4 hours. In addition, many of us have to take
ethics courses for both the banking and securities industries.
Giving one hour for four hours of pro bono work is too restrictive and unfair. If a CFP is giving four hours, give him four
hours of credit.
I agree with the 50% cap rule in order to restrict one product concentration.
I disagree with eliminating CE credit from competing professional licenses. All you are doing is trying to justify in your
own existence and fail to recognize that Financial Planning is diverse and other designations broaden our capability not
restrict it. You even acknowledge how divers he field is in your opening Rationale, so this rule seems contrary to your
own position!!!.
Thomas Dafnos, CFP
®
my comments
My general comment is for practitioners that carry other professional licenses, the most common of which would be
securities and insurance, we carry an increasing burden of compliance and CE requirements. I do not see any
overriding need to expand hours of training for the sake of saying we have done so. In particular, I would submit that no
amount of ethics CE requirements will change the heart of an unscrupulous planner. The requirement of additional
“training” actually gives those folks more credibility with the public…after all they will purport that have taken and
“passed” the new and more rigorous standards….so of course their next victim can trust them.
Most of us are specializing in certain practice areas. In our firm we have several specialties and call in partners (all
partners are CFPs) for detailed assistance to best serve a client’s needs. I do not need to take detailed training on long
term health care; I bring in a specialist when needed. I have expertise in succession and estate planning and the
partners ask me to join based upon client needs. It would be a waste of time and effort to dig into myriad of areas for
the sake of diversity. As our areas of specialty become increasingly complex we need to spend more time in reading
and discussing those intricacies, not less as the proposals seem to suggest.
In general I would think that more in depth and detailed CE training for specialty areas would be more productive than
just more hours. If you are an accredited fiduciary for qualified retirement plans then let’s have some great CE courses
around that; one example might be how employee education can be addressed. If you are a specialist in succession
and estate planning then lets dig down into more sophisticated planning options and opportunities. If you are focused
on charitable planning then let’s look at how that planning can produce great results for the client and for society.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 267 of 379
Comment
To summarize, I would ask that the focus be upon upgrading the quality of the CE courses, adding courses that drill
down into specialty areas, and allowing the practitioner to spend additional time really learning and reviewing areas that
can be applied to their practice. To ask that the body spend time training in areas outside their practice seems to be non
productive at best.
Michael P. Schiffer,
®
CFP , CRPS(r)
L. Mike Heuple, CFP
®
Comment
No additional changes.
(none)
All this continuing education is getting ridiculous. 30 hours is plenty. Those of us who are actually running businesses
are practicing “education” every day. The more time I have to spend on academia type stuff the less time I have to
attend to clients. If you are a CFP and insurance licensed you’re looking at 80hours of continuing education. This
check the box mentality will not stop all the bad practitioners out there. It only serves as a deterrent for us who run good
businesses to keep the credentials. I really hope we concentrate on the type of education instead of the more is better
mentality.
In summery please do not add more hours to the CFP renewal.
Richard P. Pauli, ChFC,
®
CFP , CLTC
Jan Shortz, CFP
®
Richard Strasburger,
®
CFP
Jeff Kirkpatrick, CFP
®
CE Comments
While I believe that relevant, quality CE is important, I don't believe that increasing the number of hours required is the
answer. In an increasingly regulated industry, with significantly ramped up compliance burdens on those in the field,
adding yet another layer of requirements would tend to be onerous.
CE
Proposals to increase CE requirements for renewal, will benefit the organizations that sell the CE programs far more
than CFP holders who are required to spend even more to maintain their designations. I am near retirement and this
really will not impact me but I see no benefit to our clients nor the knowledge base of the CFPs.
Proposed CE Revisions
I am not in favor of the proposed revisions. I think 30 hours is plenty. I particularly dislike the requirement: Eliminating
CE credit for completing professional licenses and designation
examinations. I feel like continuing education classes should be able to be used to meet continuing education
requirements for other professional licenses, such as insurance licenses.
CE proposal
As a CFP for the past 14 years, I cannot disagree more with this proposal. Practicing CFP’s do not need additional CE,
we get enough real world experience every day. I smell a way for CE firms to get a hold of more of my money and time,
what a waste….this is how politics work and that is bad enough to endure every day.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jay B. Barclay, CFP
Subject
®
Response to new CE
recommended changes.
Page 268 of 379
Comment
I am very concerned with the additional burden onto the individual advisor by many of these recommended changes.
If the Board decides that two hours in not enough time to cover targeted topic in ethics and four hours is needed I am
okay with that change. I hope the decision was not based on the rational that if two hours is good, four is better.
I see too much added complication in the recommended changes. Now instead of having a set number of total hours
plus the ethics requirement, it is suggested that we will need a matrix of training and hours to track. To get credit for
activities requires reporting and approvals that many providers with find too much hassle to complete.
I spend more than 50 hours a year facilitating the Dave Ramsey Financial Peace University classes. That should
definitely fit the pro bono category but I believe CE hours would not be accepted (even partially) on face value and the
Dave Ramsey organization would not be inclined to jump through the approval process hoops.
As a financial advisor I hold other licenses and are subject to other CE requirements. The CFP Board should realize
that the majority of advisors are in similar situations. The accumulation of CE requirements is becoming too
burdensome.
I recommend the board not accept the posted recommendations. Please have the strongest rational before adding
these types of burden on the advisors.
Michael G. Moore,
®
CFP
Sandy H. Wilcox, CFP
Edmund D. Tschopp,
®
CLU, ChFC, CFP
®
New Rules
I would keep the current system in place, between having to do regulatory from our respective firms, CE for insurance
related licenses, regulatory work for exchanges and now more CE work for CFP(r) credentials. You end up spending all
day taking courses and not enough time actually meeting with clients and providing them your utmost attention. I would
®
focus more effort on making our credentials of being a CFP more well known vs. other non recognized credentials
(CRPC, AAMS, etc…..) Some people think that the more letters the more in-depth a credential is.
Continuing Education
Requirement Proposal
I disagree with increasing the number of hours for CE Requirements. In conjunction with various life/health insurance
CE requirements, now additional state requirements for annuity product required learning in the home states and other
states. All our time will be spent in CE meeting those requirements. More does not mean better. We are overwhelmed
with all the “learning requirements” All the CE trainings should be coordinated so that they support each other… when
you complete any one ce it can also satisfy other ce requirements. Again, more is not better… better to raise the quality
of training than just incease the time required.
Response to increase in
CE reqm't
I am 100% in favor of keeping CE requirements as they now are. You need to consider that most CFPs also have
insurance and series 7 licenses which also require CEs. Add that to the fact that most all of us have a back office broker
dealer support staff to educate us and answer any questions regarding advanced planning tax and estate issues. The
fact of the matter is that our BEST education is in our every day transactions for which no credits are allocated.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Robert L. Baumann,
®
CFP , MBA
CE Comment Period
Page 269 of 379
Comment
I would vote AGAINST the proposed amendment to the CE requirements on the basis of increased hours. It is already a
challenge to meet all the requirements of the Board, your broker dealer, FINRA and LIMRA, ethics, as well as any
insurance or LTC licenses a professional may hold, it takes up to several wks to complete them all. I don’t see any
topics that are so new out there that the thirty hours could not cover.
Increasing ethics training/hours required is another waste of time. You cannot train ethics. In addition, all other aspects
of the profession have added ethics training. Making the ethics training more rigorous such as case study where you
would have to point out specific areas for ethical concern would be an enhancement, vs. just “adding” more hours and
calling that sufficient.
All other aspects of the changes look benign enough.
®
Erin L. Cockman, CFP ,
MBA
proposed new CE
®
requirements for the CFP
Just the thought of these proposed changes stresses me out!
I have been an advisor for 16 years now and here is what is required of me:
20 hours (every 2 years) for my NC insurance license
®
30 hours (including 2 ethics) for my CFP
40 advanced credit hours for my internal designation-Premier Advisor (earned through production level and client
service)
13 internal training modules (such as firm element: product risks and sales practices; code of ethics 2012, reporting
suspected financial abuse 2012, etc)
Hopefully you have been in our role and realize that there is no such thing as being caught up when handling clients’
assets. There are always additional reviews, research, etc that can be done. We are never sitting at our desks
twiddling our thumbs wondering what to do with free time (what the heck is that?) I already spend countless hours
working on client cases at home at night. Then, you add on all the requirements that I listed above and people wonder
why I am up until midnight. Are their folks like me that actually have time at the office during the day to fit in all these CE
hours?
It is ironic that I chose to increase my knowledge in order to be a better advisor to my clients, yet because of that choice
®
and my success, I have the 30 CFP hours and the 40 Premier Advisor hours on top of the standard 20 NC insurance
hours and our Wells Fargo 13 online modules.
I beg you to please reconsider the proposed changes. Like I said above, just the thought of even more CE, makes me
want to throw in the towel. I want to advise my clients and manage their assets; I do NOT want to spend hours upon
hours doing CE work. Why don’t you devise a plan whereby newer certificants and/or those that have had any kind of
reprimand are required to do more CE work but for those of us that have not had any complaints/problems, we should
®
not have the extra hours. We should be rewarded for abiding by the CFP boards ethical and moral standards NOT
punished.
On a personal note, I also have 4 children under the age of 7, so I am a working mother. I hope you decision-makers
also realize that we do have a life outside of the office and every extra requirement you place on me, takes away from
either time with my children, my spouse or my sleep! It isn’t fair.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Page 270 of 379
Comment
More regulation
More regulation from those who want to make themselves seem worthwhile…Who need to justify their existance.. We
are regulated far beyond need based on my 28 years in the business
Eric K. Peterson, CFP
New CFP CE Req's
I believe all of the proposed changes should be adopted. I am in absolute agreement.
John D. Dragonas,
®
MBA, CFP
Proposed Revisions to CFP
Board’s Continuing
Education Requirement
I agree with the all the proposed changes, except for the increase in the requirement for Ethics Credits.
Don Gleason, CFP
®
Requirement for Ethics Credit should be eliminated all together. The requirement for training tutorials, to be ethical, is
plainly absurd.
"You don't need a patch on your arm to have honor." -- A Few Good Men.
Please eliminate that pretentious "Ethics Credit" all together.
Tom Dillon, CFP
®
®
David L. Frank, CFP ,
CIMA
new CE rules
I AM AGAINST ALL OF THE PROPOSED CHANGES. We are being over-run with compliance and CE requirements.
Everyone, from B/Ds, to state insurance depts., to FINRA, to you guys is demanding more. And, most CE is a joke
anyway, especially for Ethics. We continue to receive credit each year for listening to the same presentations over and
over. As for ethics, if someone does not have integrity, then taking 4 hours of an ethics class instead of 2, will not
change them.
Comments on CFP CE
I am a big believer in CE. I think the board needs to be cognizant of practitioners holding multiple designations or
licenses that also require CE. If the board makes too many changes or implements changes that are too onerous,
practitioners will not be able to maintain their licenses. I would be careful about making too many changes to fast. I
would suggest implementing the changes slowly, perhaps one or two a year, and monitor the impact.
I do not have a problem with 40 hours over two years. However, I when adding in all the other licensing / CE
requirements it could become overwhelming.
Eliminating CE credit for completing professional licenses and designation examinations needs clarification. If I
take a series of courses to improve my knowledge and understanding of the industry I should be able to earn CE credit
for the course. Example, If I sit for IMCA's CPWA I should be able to get CFP CE credit. That course can only enhance
my knowledge and my abilities. The same goes for CIMA, AIFA as well as several other certifications. If this is about
credit for a review course, then that might be different. I think CE should be awarded for CFPs taking other real
certifications that will enhance their knowledge in any of the CFP areas of study.
This is unclear and wrong. This needs clarification or should be removed altogether.
Eliminating CE credit for completing professional licenses and designation
examinations.
Rationale: Inconsistent with professional certification program best practices. Program
content or coursework may be eligible if consistent with CE topic and other
requirements. Exam prep or review courses remain ineligible.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Gary P. Ruchin, CLU ,
®
®
ChFC , CFP , EA
comments and changes to
CFP guidelines
Page 271 of 379
Comment
Granting CE credit for practice management programs and/or pro bono activities,
up to 4 hours (total combined) per renewal period.
My only concern regarding the pro bono and/or practice management CE will be if the Board is going to charge a fee of
up to the $100 to register that program the way you charge $100 to register any other CE program that needs to qualify
CFP CE credit. If there is no charge or fee related to this type of program I think it's a great idea.
Increasing total CE hours required each renewal period (every 2 years) from 30 to
40 hours.
I have no problems or concerns with increasing the CE requirement from 30 hours to 40 hours over a 24 month period.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include
a mandatory CFP Board-produced Ethics program (2 hours) plus 2 hours of ethics
programming, which is expanded to include both pre-approved programs on CFP
Board’s Standards of Professional Conduct and general ethics-related content.
If the additional two hours of ethics programming is also compliant with the state ethics (law and ethics) requirement, I
see no problems with increasing it to four hours. However, the problem is in my mind if this may only give a private
company the opportunity to charge more for the two additional hours and yet not provide any additional new information
in their course they sell that provides the two or four hour ethics program.
Implementing a “50% cap rule,” which will limit CE credit for any single topic area
or professional activity to 50% of total required CE hours.
My only concern on the 50% Rule, is that if you have an individual who specializes in a very specialized area this may
prove to be burdon. For example, if you have agroup of planners and each handles a specific area there may be an
issue. If you have a CFP who specializes in 401(k) business for example, just to keep up with that and could easily be
over 50% of their CE credits. I'm not sure if the Board has seen this as an issue in the past, if it's a big problem I can
understand your concern but if it's a minor problem why create the added complications or burdons. This particular rule
has no effect on me as all of my CE tend to be equally distributed among all the categories that are currently available.
Eliminating CE credit for completing professional licenses and designation
examinations.
I am a bit confused on this one. In one part of your sentence the rationale says it is inconsistent with this practices and
yet the second sentence you say it's okay. This is quite confusing either is or is not. I think you need to reword your
rationale regarding this part of the CE changes.
Thank you for your time.
Stuart Richards Pfeifer,
®
CFP , CDFA™
please consider
I do not mind the increased rigor of the CE as long as it doesn’t increase our costs to maintain the license. It is already
very expensive and firms are reimbursing less and less and cutting payouts more and more. I would hate for this
designation to become cost prohibitive to good high quality candidates. The listed changes looks as if they could
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 272 of 379
Comment
increase the cost by as much as 25% over the existing requirements.
Sherry B. McKinney,
®
CFP , MBA, CPA
Comments on Changing
the CE Requirements
I would like to make a few points about the proposed changes to the Continuing Education requirements. As a CPA
since the early 1990’s, I have participated in continuing education for that certification for many years now. One thing
that I have noticed is this: every organization seems to be adding an ethics requirement to continuing education. The
CPA certificate has a 2 hour requirement. It seems to me that 2 hours is more than sufficient to cover this topic. It is my
opinion (and I have heard many others express this same opinion) that it is very difficult to teach ethics. The people who
need it pay little attention while the ones who follow the rules to begin with are made to sit through longer and longer
classes. So, my suggestion would be that the 2 hour ethics requirement remain as is.
In addition, I would like to speak about getting continuing education hours for completing professional license and
designation exams. When a person is taking these classes and exams, they are already spending a large amount of
time updating their knowledge base. To state that this time does not count would be a hardship. Most of these
individuals are taking classes to increase their skill set while working. If the hours did not count for CE, they would end
up with even more time spent in class. From my recollection, people are most informed and prepared while studying for
an exam. So, I would also like to see credit for this continue.
Thank you for your consideration.
Lanny K. Marks, CPA,
®
CFP , AEP
Proposals
While I agree with having a 50% cap rule for CE topics, I am not in favor of expanding the CE requirements or granting
credit for Pro bono activities (who will monitor this and what criteria will this entail). Too much is already required for
those of us with multiple licenses and keeping track is a nightmare.
However, I would suggest that consideration be given to having a more rigorous/lengthy exam for those wanting to
obtain the CFP designation. More CFP licensees does not necessarily mean “better.”
Thomas R. Anderson,
®
JD, CFP
Revisions to CFP Board's
CE Requirements
1. Increasing CE hours to 40 per renewal period is a bad idea. 30 hours per period is the perfect amount of hours.
Adding 10 hours will not add significant expertise to planners. I am a licensed attorney and my state bar requires only
15 hours per year and that is plenty. Don’t make things more complicated than they need to be.
2. Granting CE credit for practice management is a good idea. Planners need to run a business and practice
management learnings will help planners run their businesses better and clients will benefit in the long run. CE credits
for pro bono work is a great idea.
3. Increasing ethics credits is ok but make sure planners can take these courses online or via webinar.
4. Implementing a 50% cap rule is a bad idea. You are making compliance too complicated without any value to the
client.
5. Reviewing online courses for credit is a good idea.
6. Encouraging increased rigor and quality of CE programs exists today and you do not need to make any changes. All
the programs I attend are high quality and contain advanced content. This is another example of over thinking
something and making it complicated with no real benefit.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Ed Berruezo,
®
®
CFP ,CIMA
Subject
Opinions
Page 273 of 379
Comment
My opinion is to leave the current requirements intact.
As a result of the 2008 Financial Crisis, brokerage firms are demanding that we take increased training modules to
remain current on ethics, rules and regulations etc.
Additionally, if we are insurance licensed, we have hoards of hours required to continue to maintain our licenses. Those
of us who have CIMA's are required to have 40 hours every two years to maintain our license.
It is becoming increasingly difficult to spend time with our clients, our families and loved ones, etc due to the debacle
and the government imposed rules and regulations due to the increased demands of continuing education.
I would implore you not to increase CFP hours by another 33 1/3%. Enough already!
Mark S. Stratton,
®
LUTCF, CFP
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I wanted to take a minute to express my thoughts regarding the proposed rules changes that govern CE Requirements.
®
I understand the emphasis that the CFP Board is wanting to place on maintaining integrity within the profession and
®
preserving the significance of the CFP marks. My thoughts are that some licensing exams aid in this process. For
®
instance, the series 7 exam has a strong degree of overlap in helping CFP professionals maintain proficiency in their
knowledge regarding investments. Another example is the CLU designation whereby professionals can continue to
®
develop their skills and become more proficient with planning in various areas tested on the CFP exam. These are a
®
®
couple of examples of designations that aid the CFP board in accomplishing their goals. It does not require the CFP
®
board to spend a lot of time and money to review curriculum thereby helping the CFP board save time and money
which can be spent on public advertising to raise awareness, fighting battles with congress or the regulators that impact
®
CFP professionals, etc. which might prove to be a better use of resources. There are however some designations that
®
I believe to be irrelevant in helping CFP professionals enhance their proficiency in planning and further their integrity.
®
®
My suggestion is that the CFP board spend their time eliminating those items that are not helpful to the CFP board in
accomplishing their objective instead of unilaterally disallowing them.
Furthermore, capping the number of credit hours allowed for any single subject area may not be adviseable. Some
prcticioners may only focus on a single area of planning or maybe 2 areas of plannign (i.e. investment planning, estate
planning, risk management, etc.). capping the number of hours on those practicioners would limit their ability to
enhance their knowledge in those areas that are important to them in their efforts to become the best planner they can
be in that area.
Increasing the rigor and scrutiny on CE providers I believe is a good choice as it helps ensure that the information
®
covered is consistent with the highest standards that CFP practitioners are held to. This same rational holds true with
®
the other areas the the CFP board is considering addressing (pro bono work, increasing the # of CE hours, etc.).
Thomas Simpson, CLU,
®
ChFC, CFP ,CFS, RFC
CE
I disagree with the new requirements. I believe what we have in place is sufficient. The on going demands of the
workplace and other regulatory requirements provide and place more than enough training and oversight. The
progression of more and more requirements detracts from the time available to serve clients well.
Why not increase it to 50 or 100 hours of CE? Why stop at 40?? Would it not be better??? I suggest you think of the
course you are taking and see where it goes...If you believe we MUST increase the requirement then make it more
difficult and challenging through required courses not just more hours...
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Anita Brite, CFP
®
Page 274 of 379
Subject
Comment
Increasing CE Requirement
to 40 Hours - Not in Favor
I am not in favor of increasing the CE hours from 30 to 40. I am not in favor of increasing restrictions or increasing costs
either.
In my opinion, forty hours increases not only the time but the cost as well to maintaining the CFP designation without a
good reason, other than “we have not changed it” in a long time. Hours given up for CE eliminates a paid working hour
for independent planners. It will likely be a consideration in discouraging a “younger” generation to enter our field as the
cost is already very high dollar wise and time wise. I suspect our industry has already been “weeded” out enough over
the last few years due to the economics alone. Many young people entering our field do so under a very time “
managed” program already with many requirements to be met over a short period of time.
Also, although the CFP has not changed the 30 hours education requirement, I have always thought that it was more
than enough if not too much when compared to other professional licenses. The continuing education has changed in
other areas of our expertise that when added up is duplication of efforts in similar courses, increased costs and
luncheon fees, etc.. For instance, a practicing CFP will already most likely have continuing education requirements to be
met by their broker dealer which have increased substantially over the last few years in time and price. If that CFP also
has more than one license as many do, such as a life and health insurance license, a real estate license, a CFP
designation, a broker dealer with education requirements for their securities licenses and RIA designations, then much
time each year is already being spent in the “classroom” to maintain the various licenses with exams, luncheons, and
class time.
I rather think, we are becoming more like “professional students” taking the same educational courses over and over...
I am quite satisfied that the 30 hour education requirement is quite enough to keep us informed, educated, ethical and
current.
Jonathan S Merckens,
®
CFP
comments on proposed
changes
I am in favor of most of the proposed changes with the exception of increasing the required hours from 30 to 40.
Between continuing education requirements for CFP and insurance, which most do NOT overlap (which I do not have a
problem with), I feel I spend more time attending CE then meeting with clients.
I’m also concerned that an increase of hours will only bring additional CE providers with “watered” down programs that
will ultimately be a waste of our time versus enhancing our knowledge base.
I’d rather see an increase on the quality of CE events available to us versus an across the board “increase their CE
hours” mantra from the CFP Board.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Douglas R. Conoway
®
CFP ChFC
Proposed CE changes
Page 275 of 379
Comment
The changes in CE requirements are generally satisfactory. My concerns about specific new requirements are below:
Increasing the Ethics CE requirement from 2 hours to 4 hours:
I am OK with this change, but you need to do a much better job of offering approved courses in convenient and costeffective ways. Currently the choices for ethics courses are much too limited, and in some cases course content not
very compelling.
Eliminating CE credit for completing professional licenses and designation
Examinations:
This is an unfortunate change. Anything that encourages further designations should be encouraged.
Encouraging increased rigor and quality of all CE program delivery methods:
The largest problem with the CE requirement is the challenge of finding acceptable courses. While increased rigor is
probably a good thing, I am concerned this will increase the difficulty in finding sufficient courses. I am concerned the
greater rigor will tend to eliminate those courses or presentations which have offered me the greatest value. This feels
like a way to force greater attendance at FPA and other conferences.
Jim Sprout, CFP
®
®
Richard F Baker, CFP ,
CPCU, CLU
Continuing Education
Increasing the CE requirements for new CFPs is probably not a bad idea but those of us who have been doing this for
30+years it doesn’t seem reasonable. Possibly consider a waiver of CE credits like the lawyers do after a certain age.
A lot of CE education is repeat and really a waste of time and money. Not much really changes.
CFP Continuing Education
Proposed Changes
I received your notice of proposed changes to the continuing education requirements for CFP certificants with great
interest. While I think the intentions of the Board, and the measures it has taken to date, are lofty goals, they need to be
undertaken very carefully.
In particular, the Board needs to make sure that it is looking out for the public's interest, and the Certificant's interest,
and not it's own. In my view, all too often, the Board makes decisions that "justifies it's own existence" rather than
accomplishing the latter goals. And the Board needs to be careful not to create a bigger and more expensive (both in
time and money) bureaucracy without due cause.
First, it should be noted that most CFP certificants are already highly motivated people, who must, and do, educate
themselves "on their own" to remain competitive professionally, to serve their clients, and because of their interest in,
and commitment to, financial planning. We do not need Board provided continuing education unless it is very relevant
and with proper testing procedures.
Education and testing problems begin with the CFP exam process in order to become certified. As I understand it, the
Board sets a "pass rate" for the exam, which I believe is around 50%. This is intended to make the CFP mark more
difficult to achieve, and therefore "more valuable". The pass rate is accomplished by creating exams which often bear
little resemblance to the study materials (CFP instructors routinely state this to be true), through utilization of arcane and
ambiguous questions and answers, by over emphasis on lesser used financial planning tools, and by a moving pass/file
line. A far better approach is to create a body of knowledge a CFP certificant needs to know; create exam materials that,
if learned, will result in exam success;create exams whereby the test taker doesn't have to guess the meaning of the
questions and answers; and an exam without an artificial pass rate. I have known many highly educated, highly tested
individuals who have walked away from the CFP exam saying they had no idea whether they passed or failed. That's
simply not right.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 276 of 379
Comment
Taking this thought process to continuing education, may I suggest the following:
1. C.E. classes and materials should be reviewed by CFP certificants active in daily financial planning to determine their
importance and relevance.
2. C.E. examinations should be reviewed by CFP certificants active in daily financial planning to determine their fairness
and level of ambiguity. Also, exams should allow online participants to proceed directly to the examination if they know
the material!!! Stop the ridiculous practice of making participants go through every section of the support materials
before taking an exam.
3. Continue to allow CE credit for professional licenses and designations so long as they comply with reasonable CFP
standards. Not to allow these additional sources of education is unreasonable.
4. Make CFP Ethics courses relevant! All too often the material and exams are dry, arcane, and without application.
Often ethics explores topics that do not come close to impacting the average financial planning practitioner.
In addition to the thoughts above, may I suggest that the Board try to keep courses and exams concise so they don't
take away valuable time from busy financial planning practitioners. Also, the Board should make sure that the proposed
changes don't increase it's size, scope, and cost unless there is strong justification. Before expanding the current CE
program to include more hours, there is much work to be done to make the existing course and exam process more
meaningful.
While I very much appreciate the intent of the Board's proposed changes, I think each change must be rigorously
examined, and carefully administered. Most financial planners have felt the burden of increased regulation brought on
with the best of intentions, but creating unnecessary, burdensome, time consuming tests and procedures. Let's not have
CFP continuing education take the same path.
Claudia Jacques-Soto ,
®
CFP
Proposed increase in CE
requirements
I don’t believe that increasing the credit requirements by 10 credit hours will make the practitioner any more competent.
I don’t believe that increasing the ethics component from 2 to 4 hours will make the ethical planner any more ethical or
the unethical any less unethical. I don’t believe that requiring knowledge be spread around to various artificial
categories benefits the planner who wants to focus in a given area in any particular year. I believe the individual
practitioner who is serious about their business continually strives to enhance their skills and broaden their knowledge
for the benefit of their clients and their business, regardless of CE requirements. I believe the current requirements are
ample and require a commitment and diligence without being excessively burdensome or unmanageable. The serious
planner seeks knowledge and advice from many sources to stay current in their field from study groups, independent
reading and research, peer discussions, etc., none of which qualify as CE but are vital and time consuming. Additional
credit hours would detract from the time available to spend on client issues and practice management and not add to the
quality of services provided.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jaco Jordaan, CFP
Subject
®
Comment on Proposed
Changes to CFP Board CE
Requirements
Page 277 of 379
Comment
Regarding proposal to increase CE requirement to 40 hours
I am absolutely NOT in favor of increasing the requirement to 40 hours. As a professional in the industry, I take it upon
myself to be educated and keep up to date. However, many of the activities to keep up to date no longer offer continuing
education credit because of changes the board made a couple of years ago which have made it more difficult and
expensive for non-CE specific providers (like mutual fund distributors) to get content approved. The result is that we
have to do BOTH the education that we feel is most worthy to keep up to date on financial planning issues, AND the
less-worthy but qualified courses offered through a CE approved provider. I suspect that for many certificants this adds
up to several hundred hours of non-approved CE per two-year period, plus the additional requirement of approved CE.
We are required to be ethical and to put the best interests of our clients first, as we should be, yet the Board does not
trust us to maintain our own levels of education, and instead requires us to submit “homework,” and then ransoms the
right to offer that CE to certain providers.
Regarding proposal to increase Ethics requirement to 4 hours.
I am NOT in favor of the increase. Either someone will behave ethically towards clients and knows the difference
between right and wrong, or they won’t and they don’t. Every certificant that ever has been admonished for an ethics
violation previously took the various ethics courses. Adding two hours to the requirement won’t change the thought
process of someone who does not put the client first.
50% cap rule
I am NOT in favor of the cap rule. Various certificants have built specialties as estate planners, as insurance planners,
etc. Keeping up to date in their area of specialty is likely hard enough, specifically because they specialize. Requiring
additional education in a non-relevant area places an undue burden on those who specialize.
Richard P. Beebe,
®
CFP
CE Change Comments
Before you increase the CE requirements to be consistent with other professions make the designation
consistent with those other professions. Of our 360 households we did not acquire one of them because
they were looking for “a good CFP”. On the other hand we are often asked if we know “a good CPA”.
The TV ads you did were good. Do more of that and if we have to pay more ourselves I’d be willing to
to that. A higher CE requirement won’t improve our “brand” in my opinion.
The not more than 50% topic rule is tricky. You’re going to have to give us some kind of tool so when we
are getting close to meeting the overall requirement we can be assured that we won’t be exceeding
the 50% rule. Otherwise you’re going to have a lot of unhappy campers who will meet the overall
credit but violate the 50% rule potentially at the last minute. If you’re not going to certify someone
because of this you need to help us know where we are unequivocally.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Regina McCann Hess,
®
CFP , CDFA™
CE Comments
Page 278 of 379
Comment
I am writing to express my opinion on 2 of the potential CFP CE guideline changes.
I disagree with implementing the following updates:
• Implementing a “50% cap rule” – I understand the concept of what you are trying to do here but at the same time I think
it’s a mistake. As professionals running our own practices, we need to be able to make our own decisions about which
CE’s will help us in our own businesses. If I need more education in annuities (or another topic), then I should take
more CE’s in annuities. Or if most of my time is spent on income tax planning, then it makes sense for me to take as
many CE credits on tax planning as possible. As professionals, we are not looking for the easy out by taking these
classes. Most times, we are covering our butts. Information is overwhelming and sometimes CE credits help us
decipher what is the proper approach for our clients. While we need to be aware of the surrounding information, say
interpersonal communication, we can read that article on the internet on our own time.
• Eliminating CE credit for completing professional licenses & designation examinations - this is a great way to obtain
CE credits and expand your knowledge base. This not only helps the professional but also the clients. When the CFP
expands her knowledge level, she brings that new information and energy to her client base. This is a win/win for the
client. I would think that the CFP board would think this a benefit to their membership base as well as the general
public. This helps everyone. I would find this a much better use of my time than just signing up for a computer class in
order to get my CE’s completed. As a CFP, I want to further promote people’s careers, not stifle them. Not allowing
them to use the CE credits from professional designations is a step backward for the CFP organization.
Jannet S. Carpien,
®
CFP
Lon LeBlanc, CFP
®
Susan L. Kent-Esken,
®
CFP
Why????
Please explain to me the purpose of the increase in CE for recertification.
There are those of us who have been in practice for over 30 years with never a compliance issue and we are considered
professionals, aren't we? We continue to learn something new every day despite not receiving a CE for each "pearl" of
knowledge we attain.
. Along with all the FINRA requirements and insurance requirements, we are laden with all these new regulations which
are time consuming and costly to the individuals and their firms. Is there a risk benefit analysis that has been done to
demand these new requirements. What do you think we will accomplish? Are these required regulations by government,
or by the CFP board?
I think this must be reconsidered.
Proposal for Additional CE
Hours for License Renewal
While I would support the increase from 30 hours to 40 hours of required CE training for CFP license renewals during
each renewal period, I am strongly in favor of allowing excess hours for any reporting period to be credited to the
following reporting period. This seems to be the standard for most other types of licensing and would allow any final few
hour overages for a particular period to not go wasting, simply to satisfy a last few hours, or even a single hour, for the
current reporting period.
CE Requirement Changes
I vote no. Thanks.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Bart Metzler CFP ,
®
CRPC
comments on proposed
changes
Page 279 of 379
Comment
I have a few comments regarding the potential changes on the CE credits.
First, I strongly disagree with not being able to apply CE credits when I take a class toward another professional
designation. That simply makes no sense that I am trying to expand my education background in areas such as life
insurance for the CLU and it doesn’t count toward CFP credits.
Especially if you stick with the proposed rule above, then absolutely can’t justify the addition of more credits needed
every year. We have to have some time to meet clients and run a business remember and that gets more difficult if we
want to expand our knowledge by getting other designations AND get 40 CE credits for CFP.
I would add the options for pro bona work, etc regardless if you are increasing or not the CE requirements.
Dan Dwyer, CFP
®
CE Changes
I have no problem with increasing the number of hours from 30 to 40 but I do have a problem with increasing the ethics
portion from 2 to 4. Increasing to 4 seems to be self serving to the public and preaching to us, the choir. In addition
these courses tend to be extraordinarily boring! I cannot believe any good practicing CFP does not view these courses
other than a penalty for being a CFP. We know what is right and what is wrong, so stop banging us over the head. If a
member does not have a moral compass, no amount of ethics courses will change the way they practice. The two
credits on the CFP rules and regulations are enough to remind all of us that our first duty is to our clients, and not to
ourselves or to our family. THINK OUPUT, NOT INPUT, and do not burden good CFPs any more than they are already
burdened.
Furthermore, to increase the hours from 2 to 4 would suggest to the public that CFPs need more ethics training because
they are such bad people. Is that what we want to project? I believe the vast majority of CFPs are good and decent
people. 2 ethics credits, SI. 4 ethics credits, NO.
®
Michael F. Burke, CFP ,
®
CTFA, AEP
Changes
Please accept this e-mail as my vote not to support the increase from 30-40 hours of continuing ed. Also, not to support
the increase in ethics from 2-4 hours.
I do, however, support 50% limitation in one particular category.
Thank you.
®
Linda Saylor, CFP
CE
I am absolutely, categorically, totally opposed to the proposed changes!
30 hours is enough!!
No way.
No how.
Absolutely NOT!!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 280 of 379
Subject
Brian S. Moore, CFP
®
CE education requirements
feedback
Comment
Thank you for your commitment to raising the competency bar for financial professionals in the industry.
®
I would ask the board to be mindful of the many education requirements that are required of the CFP professionals in
the field. In addition to the Board’s requirements, many individuals have CE requirements from Insurance licenses as
well as firm regulatory element training. All the training and education as a whole can be very burdensome to the
individual certificants.
Please be sympathetic to these other required training courses as the Board considers new CE requirements.
David Rouse, CPA,
®
CFP
CE Requirements
I totally disagree with the proposed changes to the CE requirements. This is an unnecessary increase in the CE burden
on us. I am a CPA and have to have 40 hours per year there plus now you want increase the hours required for the
®
CFP [professional].
®
It also is ridiculous that there can’t be a coordination of the required ETHICS courses between the CPA and CFP
[certification].where once course would satisfy both. Ethics are ethics and an ethics course is not going to make people
ethical.
Either they are or they are not.
Every professional board has gotten out of control as far as cost, requirements, etc.
Paul S. Baker, CFP
®
Adding more CE requirements will not improve the quality of the services provided by CFP [professionals]. The 30
credit requirement is more than sufficient for professionals who are actually performing the CFP role in the normal
course of business. Expanding the number of Ethics related credits will not improve the quality of advice or ethical
®
practices of a CFP [professional]. Either you conduct your business ethically or you don't. No amount of Ethics credits
will transform an unethical practitioner into an ethical one,
CE credit increase
comments
It is my opinion that 30 hours every 2 years is more than enough. The knowledge that is picked up from the classes is
minor compared to the experience of dealing with events day to day.
It is as if every industry is competing with each other about the amount of CE that they require. Too me the only reason
you will increase the number of hours is to make money for the businesses that provide CE credits.
®
CE Changes
I believe the current requirements for CFP CFP [certification] CE are quite good right now. I don’t think an increase in
®
the number of hours required is going to help anything but put a larger burden on CFP [professionals’] time
management.
®
change in continuing
educations
Given the exams/hours required to maintain the finra 3,7,9,10,66 and ce credits required for state insurance
requirements
®
®
Adding an add’l 10 hrs plus 2 hrs (ethics) for the CFP certification is NOT needed at this time. Not all your CFP
[professional] designations
®
Are CFP [professionals] only. The additional burden is not needed.
Ce Requirement
I think the Ce requirement increases for those working for broker dealers should be waived due to the fact we have
®
numerous ce requirements already at the firms on top of the CFP [certification] requirements already.
®
Robert T. Steck, CFP ,
CRPC
Joe Kreck, CFP
Vic Lunka, CFP
®
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Thomas Dias, CFP
®
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 281 of 379
Subject
®
Adam Miller, CFP
Comments on CFP CE
Changes.
Comment
®
I am opposed to the proposed changes to CFP [professional] CE credit requirements. I would support keeping the CE
Credit requirements the same. I am sure I will reach 40 credits and I am constantly engaged in Continuing Education but
making requirements more stringent doesn’t serve CFP holders well. Ethics course work that I have participated in has
been a bland restatement and an obligation rather than a joy. Instead of requiring twice the course work in a already
neglected subject, why don’t you try to serve up interesting and relevant ethics info using multimedia. I can see an
entertaining quarterly video from the CFP [Board] on ethics that actually gets to the heart of the subject. Serving up two
times the coursework in this area won’t help. Serving up good content in a digestible fashion will. Please reconsider the
direction you are taking on Ethics and on the CE Credit issue as a hole.
Again, I do not support these changes. Don’t hesitate to call if you have questions.
®
Eric R. Stevens, CFP ,
®
CIMA
Continuing Education
Credits
®
I think increasing the hours needed is unnecessary. You should continue to be focused on CFP [professionals]
providing quality and transparent advice. I see more clients locked into indexed annuities and other illiquid investments
without being provided any information about their HORRIBLE surrender charges.
CFPS are supposed to provide all material information and these products DON’T. They have no prospectuses that list
pertinent information , like standard annuities. They provide HUGE commissions in exchange for locking up clients at
close to 20% surrender fees , sometimes forever. I have had numerous clients taken advantage of these products that
no wirehouse will sell. They feel that they can’t justify the expenses or lockup periods. It seems to me that these
products break every rule that I read while taking CE courses yet The Board seems to look the other way.
Shane M. Cason, CFP
®
CRPC
®
®
Arthur Rosen, CFP
Russell G. Lowry, CFP
®
CRPC CWM™
®
Proposed CE Comments
I disagree with the increase in CE requirements. Please consider that 30 hours is anywhere from half to a full work
week for some. Moving to 40 will take away from client priorities. If you aren’t keeping up with rules and changes, then
you’ll lose out in the market anyway. Plenty of educational events happen without the CE credit attached to it. If
someone needs 2 more hours of Ethics in order to get what’s right and wrong, they probably don’t deserve to be a part
of this anyway and you should kick them out.
suggestions
I have been a CFP [professional] since 1988, almost 25 years. I never understood the requirement, the force feeding of
CE credits to enhance one's ability to be the best he/she can be. This should be a desire by the professional to improve
®
and keep up with the changes. As a CPA, CFP [professional], RIA and insurance representative I find it to be extremely
expensive to be forced to pay thousands of dollars annually on CE courses, much of which is simply not necessary to
maintain my abilities. It makes one wonder if there is perhaps other reasons for lining other pockets of money to
purchase courses. Ongoing learning to maintain competency should be my desire rather than my requirement. Lastly, I
have always conducted myself as ethical as I can, always performing my job with utmost integrity regardless of how
many CE credits I take in ethics and increasing to four credits would only result in additional expense to me for no valid
reason (to me) not making me any more ethical. The economy is not doing well, my clients aren't doing well, income is
®
down for almost all (including CFP [professionals]), and you want our opinion to increase CE requitrements. Please!
ce comment
I agreed as proposed.
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Barry Brauchi, CFP
Subject
®
Page 282 of 379
Comment
®
CE updates
Our team includes 3 CFP Professionals, and it is our feeling that there needs to be some understandings along with the
proposed changes. We are not against an increased CE requirement or more rigorous standards for the CE process,
but it does place a certain amount of strain on our practice. We are in a smaller market city that is not near any major
market venues that offer a lot of CE opportunities. There are also no accredited class providers nearby. This means we
are left with the option to do most of this CE online, or we have to travel a lot to go to CE events in bigger market
venues. This places a good deal of added effort and expense to maintain our certification, and we would appreciate if
these types of scenarios are discussed in relation to the proposed program changes.
Robert W. Davidson,
®
CFP
Proposed new CE
requirement
I would like to encourage the CFP Board to reject the proposed increase from 30 to 40 CE hours and 2 to 4 hours of
Ethics. While I understand the Board's rationale, I feel that the current requirements are sufficient to keep us at the top
level of our profession as Financial Advisors.
Mary S Shrode, CFA,
®
CFP
Comment on changes to
CE
I am against any further CE requirement. I am already having to do too much with my insurance and securities
requirements. Also my job has many requirements, money laundering, etc, etc. Please do not add to your CE
requirements. I suspect it is a way for you to enhance your own revenue. Sorry.
Re: Comments
The proposals are good for practicing certificants. I am still hopeful that as a large group of us approach retirement that
®
there will be a new category such as "CFP ret" so that we can still refer to ourselves as such even though we are no
longer practicing. (Like doctors, lawyers and CPAs do) and do not have to keep up with CEU and high annual fees
(which includes advertising to attract clients after retirement). After becoming inactive, I would still like to continue to
have access to the good information and keep current on happenings in the profession and occasionally attend selected
events where I could network with old friends. Retirees might also be useful in promoting the value of attaining the
designation to others still working. I worked hard for the designation and kept up all requirements and paid fees for over
30 years. I would hate to have to lose all status after I stop working.
Your proposal to increase
CE requirements
I am against the CFP Board increasing my CE requirements. The board has to recognize that this CE is not all the
®
advisors that hold the CFP [professional] designation are doing. My employer, ML requires annual firm element CE
requirements that have deadlines for completion. My Texas state insurance license requires 30 hrs. every two years,
®
along with the CFP [certification]. In addition, I just completed my every 2-3 years FINRA firm element requirement,
which is always conducted offsite at an outside testing center. Now for people that are trying to make a living advising
clients, there is not enough time currently for all the challenges we are facing just navigating these crazy markets. No,
there is no more need for yet even more CE requirements. Please find something else to work on that will add value.
Example: Increase the difficulty/exclusiveness to be eligible to sit for the exam based on completion of college
coursework, degrees, etc. (I can’t tell you how many accountants and attorneys out there that think they are investment
gurus, just because they hold an accounting or law degree many of them believe they invented investing).
Carol Sandstrom, CFP
Brant R. Newman,
®
CFP
®
Bottom Line: CE is like taxes, it never seems to decrease and the entire world is CE “happy” right now, the everincreasing regulation pendulum has swung about as far as it can possibly go
Roderick F. Coffin II,
®
CFP
CE Hours Increased
Requirements
Because of CE required for various licenses and internal CE requirements I believe the proposed increase from 30 to 40
hours of CE requirement is superfluous. I currently have close to 45 hours of regulatory license requirements per year in
®
addition to CFP [certification] CE requirements so if the Board is concerned about the fast moving pace for financial
planning there is more than enough already required by various regulators.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
John T. McPherson,
®
CFP
CPE Requirements
Page 283 of 379
Comment
I think the current requirements are sufficient. Between state insurance, annual VA training, broker-dealer face-to-face,
®
B-D compliance manuals, and AML, I don’t see how adding additional CFP [professional] CPE helps.
I would recommend the current requirements and dialing in specific topics and continue recommending places to obtain
the CE.
®
If someone becomes a CFP [professional], aren’t they committing to be a cut above the average advisor as well as
conducting business using the FP process? Isn't that worth something?
®
Mark S. Young, CFP ,
CPA
Comments regarding
change in CE
There seems to be a trend toward increasing CE requirements for professionals. This seems to be a reaction to the
threat of government oversight; by self imposing stricter requirements, perhaps we will keep the government out of our
profession. I think this proposal is an over-reaction to this threat.
I'm also a CPA and we continually increase our CE requirements, including forcing us to take classes in areas where we
spend very little time. We now have more CE required hours than Attorney's and Doctors. Is this really necessary?
I would like to propose that the CE requirements be kept to 30 hours. I don't think that we need to increase our hours to
40 hours. Most of us continually study issues that are relevant to our profession, such as reading articles in magazines.
As such, I believe that most practitioners are spending far more than the required 30 hours already. Increasing the
number of CE hours simply helps CE companies make more profits!
The increase to 4 hours for ethics in unnecessary. The truth is most of us know right from wrong and spending 2 more
hours studying ethics rules isn't going to change how we manage our practices. This is an unnecessary change.
Please keep this at 2 hours.
Please do not impose a 50% cap in one area of practice. Most of us find that we practice in one or two areas. By
imposing a 50% cap, you will force us to study in areas that will have no benefit to us. This happened for CPA's. As a
CPA, if I have one bookkeeping client, I'm required to take 32 hours of CE in accounting. This forces me to spend more
time in an area with NO benefit to my clients and take me away from CE hours, such as Tax, that would really benefit
my clients.
Please seriously consider my comments and I hope you change your proposed CE requirements.
Stephen T. Jones CPA,
®
CFP
CE Proposed Change 50% Cap Rule
®
Many CFP [professionals] concentrate their practices in specific areas of financial planning. To continue to gain
knowledge in their specific areas of practice, CFPs should not have to take ce in areas unrelated to their specific
practices. This is counterproductive to their valuable time.
I am very much opposed to the proposed “50% Cap Rule” on CE.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Paul Evans, CFP
®
Page 284 of 379
Subject
Comment
Increased CE requirements
I do not feel it is necessary to increase the requirements in addition to the state insurance and the FINRA requirements.
I also do not agree with having CE satisfied by Pro Bono work. We all so a lot of free consulting which is just a part of
our professional obligation to the public.
Continually increasing the CE requirements will make it for impossible to justify continuing the CFP designation due to
the time required for all the various CE requirements. I have a number of other financial professionals that have
®
dropped the CFP [certification] because they felt that there is not enough recognition of the degree to justify the
®
continuing increased obstacles. You make these changes and I will have to seriously analyze if I continue as a CFP
[professional].
David R. Petry, CFA,
®
CFP
CE Requirement changes
It is my opinion that 30 CE hours is sufficient to demonstrate that a professional is remaining up to date with changes in
the industry. Anyone working actively in the profession is maintaining his base of knowledge with numerous activities
®
that are not counted towards official CE credits. I have discussed with many other CFP [professional] colleagues that
the primary purpose may be to generate income for companies that provide a forum for obtaining credits. Given the
difficult economic environment today, many companies are eliminating from their budgets reimbursements of this type.
®
This makes it very difficult for CFP [professional] employees to obtain credits.
Thank you for your consideration.
Robin A. Oliver, CFP
®
Comment Period
These are excellent ideas, however, should not be implemented until AFTER the de-leveraging of the European debt
crisis, since the challenge today for the average American investor (especially “Baby Boomers”) is taxing their ability to
understand the complex market “rigging” through monetary policy manipulation.
The veracity of the statement, “this is not your father’s market” is disconcerting enough whereby many middle class
investors not only choose to not remain engaged with their finances, but are either “sticking their head in the sand” and /
or are substantially increasing their level of risk.
®
This is parallel to the mortgage market pre-2008 and each and every CFP [professional] should proceed according to
the high ethical standards set-out by the respected designation.
Andrew C. Bambeck III,
®
AAMS, CFP
CE Comments
®
I do not agree that expanding CE hours (from 30 to 40 hours) every 2 years improves competency for all CFP
®
[professionals]. Indeed, many CFP [professionals] have participated in this industry for multiple years and are subject
®
to a myriad of CE, including brokerage FIRM Elements, State Insurance requirements, as well as CFP [certification]
mandated CE hours. In addition, most brokerage firms require an Ethics CE course AND our state (Ohio) Insurance
Department requires Ethics CE hours. Finally, insurance agents licensed to sell Long-Term-Care have increased CE
hours to complete each year.
If the new CFP Board required 2-hr Ethics results in fees collected (now OR in the future), I would believe this to be a
®
conflict of interest by the CFP Board and against it. In general, adding more Ethics hours will not make more CFP
[professionals] ethical and I am against the additional requirement without giving credit for any FINA Firm element CE
®
ethics completed. This is excessive “regulation” of our industry and I am opposed to it. Note: CFP [professionals] were
®
“up charged” on their current fees (for CFP [Board] advertising) and many CFP [professionals] don’t want continued
increases in our annual membership costs.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 285 of 379
Comment
®
In general, no CFP [professional], who has other annual CE to complete (be it brokerage or insurance), should have
®
excess hours placed on him/her by the CFP Board. If you are targeting those CFP [professionals] who do not have
®
other such affiliations, perhaps additional hours would be prudent for them-not for the majority of CFP [professional]
associated with FINRA Firms and State Insurance Departments, both of whom carrier their own annual requirements.
Michael F. Gannon,
®
CFP
Increased CE Requirement
I am opposed to increasing this requirement.
I have a business to run, and that does not include financing CE providers.
Catherine Turner, CFP
®
Proposed Changes to
Continuing Education
Requirement
®
As it stands now, I need 30 hours plus a CFP [certification] approved 2 hour Ethics class (total 32 hours). The cost of
®
CFP Ethics is more expensive (usually $50) than non-CFP [certification] ethic classes ($15).
I am understanding from the e-mail that the proposed 4 ethic hours would include the option of 2 of those hours being
obtained by completing a general ethics class, such as one offered that would count towards state insurance CE credit?
I would hope so.
Also, if the proposed increase in CE hours moves up to 40 + 4 ethic hours = combined total of 44 hours. I would like to
propose that the combined total requirement does not exceed 40 hours.
Currently , the 30 hours can be obtained in a variety of ways and in a variety of venues – and all are approved through
the CFP Board. I noted the proposal to “increase the rigor and quality of CE delivery methods. The Journal of FP should
have more articles in it and offer the opportunity to obtain as much as 2 CE hours in each publication, free of charge to
the CFP professional in good standing. This would allow the CFP Board to effectively address two issues identified as
having a need for: increased ethics training and increased rigor and quality. Many advisors have difficulty in pulling
away from the office for several days and also affording the cost of conference fees and travel. I utilize and seek
obtaining CE hours from reading the various industry-related magazines (Investment Advisor, Financial Planning, etc) is
very user-friendly and cost-efficient. I also attend several events throughout the year. I typically end up with 50-70 CEs
over the course of the 2 yr period. The main reason I will not join NAPFA is because they insist that most CEs come
from national conferences and they require al heavy weighting in CE on topics that can only be found through expensive
®
commercial channels. So after paying the annual membership fee plus CE fees, the total expense to the CFP
[professional] is well over $1200 per year. It would be very disappointing if the CFP Board moved in this same direction!
I don’t have an objection in getting the credits, but I do believe that credits should be able to be obtained in a cost
®
effective and efficient way. One year the local FPA held an event and offered free CFP [certification] Ethics credit; that
was a great idea!
Thank you for listening!
Bruce Carlsten, CFP
®
Proposed CE requirement
changes
I feel that the 30 credits every 2 yrs. is enough. Between these CE activities and all the professional journals & literature
that I read, I feel that I maintain my competency in the field.
Also, I strongly disagree with increasing the Ethics requirement. I think that the currently required exposure every 2
years is quite sufficient and keeps us knowledgeable of its requirements.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Mark D. Richards,
®
®
CFP , CIMA
Subject
CE Comments
Page 286 of 379
Comment
®
Please find responses in red below. The general impression I have about CE and the CFP [certification] is CE and
®
ethics help build credibility to the CFP [certification]. However when the association requirement becomes so onerous,
the burden of completion overtake the time commitment that I should deliver to my clients. Further, I would like to
continue focusing on my specialty rather than areas I outsource to another professional. To date, I have never had a
®
prospect / client / other professional tell me that my CFP [certification] credentials are not rigorous enough.
I support actions that expand the avenues for completion and increased quality / rigor of the programs themselves..
Thank you
Mark Richards
Increasing total CE hours required each renewal period (every 2 years) from 30 to
40 hours.
No – this requirement further inhibits business development and is contrary to expanding growth through other
®
certifications in complementary fields in which CFP [professionals] are developing an authority
• Granting CE credit for practice management programs and/or pro bono activities,
up to 4 hours (total combined) per renewal period.
- Practice management CE programs. Defined as programs focused on the
®
planning, development and management of a CFP professional’s business
operations, office management, business model design, budgeting processes,
and leadership.
- Pro Bono (volunteer personal delivery of financial planning) services.
These activities must be supervised by a registered CE Sponsor organization
and will be accepted for 1 hour CE credit per 4 hours pro bono service.
Rationale: Recognize the importance practice management plays in the delivery of
competent and ethical professional financial planning services to clients. Encourage pro
bono service for the public benefit.
Yes
• Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include
a mandatory CFP Board-produced Ethics program (2 hours) plus 2 hours of ethics
programming, which is expanded to include both pre-approved programs on CFP
Board’s Standards of Professional Conduct and general ethics-related content.
Rationale: Results from CFP Board’s 2009 Job Analysis Study, which is the basis for
®
CFP Board’s CFP Examination and Education curriculum, reflect an increased
emphasis on ethics knowledge.
No – this also adds additional burden, especially when aggregated with SEC, FINRA, State Insurance , AML
requirements, and additional certification requirements – if you haven’t figured out how to be ethical after all that is
required already – adding more isn’t going to help.
• Expanding the professional activities that qualify for CE credit (currently accepted
professional activities are teaching and authorship) with the following:
- Participation in Registered Program Financial Planning Development
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 287 of 379
Comment
(“capstone”) course grading panels. These activities must be verified with
documentation of active participation, written assessments and qualitative
feedback;
- Study Group Activities that meet certain guidelines;
- Research. Research may address future trends in financial planning beyond
CFP Board’s current lists of Job Task Domains and Principal Topics.
Rationale: Encourage body of knowledge expansion and no cost CE opportunities.
Yes
• Implementing a “50% cap rule,” which will limit CE credit for any single topic area
or professional activity to 50% of total required CE hours. For example, if 40 hours
required, then “cap” would be 20 hours. Topic areas are: General Principles, Insurance,
Investments, Income Tax, Retirement and Estate Planning, Interpersonal
Communication, Professional Conduct and Fiduciary Responsibility. Conferences,
which are comprised of individual educational sessions, will not be subject to the “50%
cap rule.”
Rationale: Ensure diversity of learning experiences across breadth of planning topics.
3
No – again this would prohibit development of a practice niche or authority.
• Eliminating CE credit for completing professional licenses and designation
examinations.
Rationale: Inconsistent with professional certification program best practices. Program
content or coursework may be eligible if consistent with CE topic and other
requirements. Exam prep or review courses remain ineligible.
No – again this prohibits constructive practice building and required learning.
• Reviewing online courses for academic credit (with grading) delivered by
regionally accredited colleges or universities as “live” CE programs, rather than
“self study.”
Rationale: Recognize the quality control measures that regionally accredited institutions
are required to incorporate in the development and delivery of self-study courses offered
for academic credit.
Yes
• Encouraging increased rigor and quality of all CE program delivery methods.
®
Rationale: Help ensure that CE programs available to CFP professionals contribute to
their professional competency.
Yes
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Donna Goldman, CFP
®
Page 288 of 379
Comment
CE Credits
I believe adding more CE required credits is not productive and in fact makes me angry . Many of us in the industry are
facing trememndous pressures. For those in practice day to day, it is difficult enough to manage clients portfolio’s, deal
with firms reducing pay outs (common complaint at all firms that friends talk about) and the stress of having to be out of
the office to complete education. I usually will attend all day seminars to complete my required continuing ed
requirements. For most of us in the business for a long time being out of the office becomes very expensive. In addition
for those at brokerage firms we also have testing and continue ed requirements, it becomes way too much.
Michael A. Carretta,
®
CFP , MBA
CE requirement
I do not agree with increasing CE requirements for CFP [professionals] . 30 hours is already a large amount of CE to
deliver on with all of the other compliance related requirements of our business. Please reconsider.
Angel C. McClarey,
®
CFP , CDFA™
Comments on CFP Board's
Continuing Education
Requirement
Most of the proposed changes are good and well thought out proposals. I would be in support of most of them, except
the increased of CE hours from 30 to 40. I believe my implementing the other proposed changes, it will increase the
rigor and quality of the CE requirements as well as the diversity of learning materials and experience. It is not necessary
to increase the number of hours of CE.
Terry J Niedfeldt,
®
CFP ,CLU,ChFC,LUTC
F,FIC
CE Requirements
After reviewing the listed possible changes for CE, I would like to point out that the current requirements are suitable for
the current practice of financial planning. As a financial professional, it is my requirement to keep up on changes in the
financial industry and to practice this knowledge on a daily basis. I am required to do this for all of my state licensing
renewals and other designations that I have attained. Most CE cannot be doubled up, so my annual CE can be a
burden at times. Adding additional requirements and limits on types of CE will not help the industry. In fact it will hurt.
®
More financial professionals will find that they can continue in the financial services field without using the CFP marks
and will rely only on their other designations and licensing CE requirements. This will hurt the general public, not help
them. If the 30 hours was good for the last 2 decades with all the changes that have taken place, why is it now
necessary to change to 40 hours and risk losing more CFP certificants? The public should have well educated
®
representation, but the CFP mark is not the only game in town. By adding these additional requirements, I believe that
®
we will see a decrease in the CFP [professional] population. This would be a bad thing.
CE Proposals
I would like to congratulate the Board and offer my support to increase the hours from 30 to 40. I honestly would like to
see 40 per year as we have with my CPA license. However, I do think raising the CE on Ethics to 4 hours is ridiculous.
Have you ever listened to the poor quality and subpar presentations offered by many groups on the Ethics? You can get
this by simply listening to a 2 hour phone call or just having the computer or phone on but not even listening. With the
many fields of study for us to track, you either have or don’t have ethics and the “ivory tower debates” on the Board are
beyond my need or concern on what is accepted or not. A broad overview is much better than the detail minutia the
Board is usually discussing.
Neil Brown CPA, CFP
®
®
However, I do support the increased overall CE hours.
®
Jim Moerkerke, CFP ,
®
CWS
CE Requirements
I feel that the current level of CE (30 hours) is more than sufficient to stay abreast of the changes in the financial
planning arena. If you have multiple designations and are insurance licensed, you are already doing 50 -60 hours every
reporting period and gaining knowledge that will assist you in the planning process. Adding additional required hours for
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the CFP [professional] continuing education is not necessary.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Robin Standlee
Subject
revisions
Page 289 of 379
Comment
®
As a background, I’ve been a CFP [professional] for many years and have even taught one of your tax courses at FAU
in Boca Raton previously. I am also a CPA in Florida, which as you know has had a similar CE requirement as your
proposed 40 hours. I left bigger accounting firms to have a smaller consulting practice which specializes in tax work
®
and some part-time CFO work. When I chose to become a CFP [professional], I was mostly motivated for the
education so I could become a better CPA.
I find the move from 2 to 4 hours of ethics to be unnecessary. For the most part, this is a redundant course that has to
be taken every two years. Instead of making it 4 hours, add a 2 hour update course to choose from for those who have
already taken the basic ethics course many times. The CPA profession has the same problem with its ethics
courses….too much of my time to review the same things over and over.
Secondly, I see nothing in your CE changes that addresses the issue of paying an extra fee for approving CE courses
that are already vetted by nationally recognized CE providers such as the AICPA or others who are registered with the
National State Boards of Accountancy and that clearly meet the subject requirements. It’s very frustrating and makes the
renewal cost higher than it needs to be.
®
Although I understand the reasoning behind your 50% cap limit for any one subject, I would guess that many CFP
[professionals] have a chosen specialty - mine is restricted mostly to income tax for individuals, businesses and
®
foundations, I may find it easier to give up my CFP [professional] designation. Keeping up with income tax rules for
each type of entity requires at least 4-5 courses per year or renewal period (individual, corporation, partnership/LLC,
trusts/estates and nonprofit). Conversely,I have no desire to spend time learning more about investment planning or
insurance when I have a solid understanding of the principles and a network of qualified advisors (most of whom are
®
also CFP [professionals]) in which to call upon and refer clients to for advice in their area of expertise. I’ve taken many
courses over the years on interpersonal communication as it is used in the workplace…I’m sure none of those courses
were on your list of approved CE. The 50% rule seems to be an arbitrary number and puts an onerous obligation of
time and money on many CFPs who specialize in one area. Something like a General Principles Update / Review
course of 4-6 hours every renewal period might address the issue in an acceptable way especially if it is an option to
combine it with 2 hours on ethics.
Thanks for asking for my opinion.
Jon C. Snare, CFA,
®
CFP
Increased CE
Requirements
I am responding to the request for comments on the proposed new CE requirements for certification renewal. If the
requirements are increased, I will most likely not renew my license any longer. I have multiple professional
designations/certifications. Combined with working 60+ hours per week, I cannot continue to meet additional continuing
education requirements. I have already given up one designation (CIMA) not only because of the CE requirements, but
primarily because of the poor quality of their conferences that they required attendance at. Additionally, I realize that
with the scandals in the financial industry over the last few years, additional ethics CE hours seems like a good idea.
However, is there any evidence regarding the efficacy of ethics courses actually making any difference? Would the subprime crisis not have happened if the people at AIG and Lehman Brothers had taken two extra hours of ethics training?
I think the existing CE requirements are more than adequate, especially for people that are engaged in the business on
a daily basis.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jeremy David, CFP
Zach Smith CFP
®
®
Todd M. Schwartz, CFP
Page 290 of 379
Subject
Comment
Opposition of Increased CE
Requirement
I am writing this comment on hopes that you will take into consideration the amount of CE currently required by all CFP
certificants. Many of us have multiple licenses and practice in different areas including insurance and securities. In
addition, over the last few years the increased regulation by FINRA has required that we take additional CE for annuities
certification. When you consider most states require 30 hours per every 2 years for insurance, annuity certification and
compliance are 2-4 hours, and now CFP Board is considering adding additional hours. I feel that this it too much. I do
not take issue with increasing the rigor of the CE because I believe one must be proficient in what they do.
CFP CE
I do not like the proposed CE changes. I agree with some of the rationale- but I do not think CE is the tool for achieving
this. If a planner is licensed thru FINRA/SEC, state insurance and working for almost any broker dealer- there is a
constant CE requirement to keep up with. It is ridiculous. I would vote for a reduction. More self-accountability. I am all
®
for the high initial standards. Many of my CFP [professional] colleagues agree with this.
Questions regarding
proposed CE changes
These changes seem a bit extreme.
®
®
I hold the CFP [professional] designation in very high regard. The sheer time, knowledge and cost to achieve the
designation is exceptional relative to the most premier designations available, so why is it necessary to significantly
increase the CE requirements now?
Is the review panel assuming practitioners aren’t doing planning on a daily basis, or regularly working with CPA’s and
Attorney’s and other professionals, or having multiple other licenses and designations are not interconnected with the
®
vast required knowledge base of the CFP [professional], or attending educational or situational meetings, conferences
and calls, or webcasts to better provide and advise our customers doesn’t account for training and education?
On the ethics front, all my other designations and firm’s compliance require continuous ethics training. How is an
additional 2 hours going to change my practice, except for adding more cost?
The CE classes over the past decade have evolved with our changing financial environment. It currently takes significant
time to complete the CE requirements, so why is the panel recommending even a more rigorous CE mandate? If what I
®
have read is correct, the CFP [professional] designation has achieved superior notoriety with in the financial services
industry as well as the investing public and you have not changed the CE requirements since the early 90’s, again so
why now?
If this is a revenue concern, then why not just charge us more for our renewal?
Timothy W. Leveroni
(none)
I do not want to have more continuing education requirements. I am already spending too much time dealing with
regulatory requirements with my broker dealer and advisory firm LPL.
For example, LPL requires annual compliance meetings, Firm Element courses and CE requirements. I also have to do
Know Your Customer Questionnaires and Advisory Account Documentation Forms for every client account.
In addition I have to take a FINRA principal exam every two years.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Barry Zimney
®
George A. Baird, CFP ,
®
CRPC
Page 291 of 379
Comment
CE Hours
I am against any increase in CE hours required for re-certification every two years. What problems have arisen that an
increase in hours would solve? What problems have arisen that doubling the Ethics hourly requirement would solve?
What evidence do you have that the profession is suffering due to ineffective CE requirements? Don’t need to make
changes just because they haven’t been revised for some arbitrary period of time. Maybe changes to CE should be
directed at course offerings, more in-depth on-line course study, more variety on applicable subject matters, for
examples. Ethics are ethics, it is really a short topic of rules and regulations, which are finite and not up for debate,
philosophical license or strategic insights. You can only ask so many questions and seems that what we have is
covered more than adequately. Idiots and crooks don’t give two hoots about CE and ethics whether it be two or four
hour course. My thoughts!
CE requirements
As a working financial planner (and a CFP [professional] since 1989), who serves a client base scattered across many
states, I would like to remind the CFP Board that they are only one of many organizations who require that working
financial planners meet a constantly changing array of CE requirements. CE is rapidly becoming a problem for those of
us who hold both securities licenses and insurance licenses.
®
I would suggest that you not increase the ethics requirement (courses don't make people more ethical), not increase the
total hours and not impose any other restrictions which make meeting the CE requirement more difficult.
LISA C. WRIGHT,
®
®
®
CFP , CWS , CPM
CE propsed revisions to
requirements
Thank you for the opportunity to weigh in. I wholeheartedly agree with the proposals to increase the requirements and
add more rigor to the CE process, especially in the ethics portion. Keep up the great work you do to expand the
integrity of the profession. THANKS!
Lisa A. Kelly CPA/PFS,
®
CFP
comments: CFP CE
requirement
I understand the rationale for increasing the CPE requirement to 40 from 30 hours but am against the proposal to
mandate a cap of 50% on single topic areas in a given period. I believe that although the goal of diversified learning
experiences is commendable I believe that that it is too restrictive and will unnecessarily add to the increasing financial
burden of maintaining multiple professional licenses.
Luke Einerson
Proposed Revisions to CE
Requirments
I just wanted to express my support for nearly all of the proposed changes to the CE requirements—especially the piece
regarding pro-bono work—if we are to be regarded as a distinct profession we must do pro-bono work as other
professions do. This is a great incentive.
One concern I do have is the increased hours from 30 to 40 hours per year: I am not concerned with the idea of
additional credits required if I thought it would increase the competency at a constant rate per credit. Instead I wonder if
the quality of the CE requirement should be increased instead of the quantity. The 50% cap rule and reviewing online
CE courses will help, however it seems to me that more is not always better and this may be the case in this
circumstance. An example may be limiting the amount of test retakes to one and require those who fail a second time to
retake the course material for the area being tested.
There are plenty of “CE mills” around (more than I think we can monitor); 10 additional credits do not mean a whole lot
to me….I’m more interested in true quality and not just a future marketing tagline (not saying this is the boards motive
but I worry this would be the result).
Just some thoughts!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Mark D. McCombs,
CFP(R), MSFS
®
Jon Dayton, CFP ,
®
®
ChFC , CLU
Page 292 of 379
Comment
CE Comments
I would like to see a 2-5 hour “Standardized” requirement for all of us. This could just be a webinar or conference call
done by the CFP Board or FPA. This would include information deemed appropriate.
By having this requirement, and since all of us would have this same exposure, it would serve to tie us together as
professionals.
Continuing education
requirement
I recommend retaining the current 30 hours per 2 year certification period including the 2 hours of ethics. If you look at
my designations it is obvious that I take the educational component of our business very seriously. I have more
designations and do more CE than anyone in my branch of 50 advisors. An extra 10 hours per period is unnecessary.
If you want to change to 30 hours with 4 hours of it being ethics that would be acceptable but asking a
practitioner/business owner to do more CE and take more time away from the business encroaches on our ability to
service clients and adds expense to our practice (on top of the certification rate hikes last year).
Kevin B. Mashburn,
®
CFP
Comments: AGAINST
Proposed CE Changes
Against ALL PROPOSED CHANGES.
Increasing from 30-40 hours, and adding Pro-Bono, and practice management requirements are one-in-the-same….one
move because the original 30 hours are largely unchanged. This makes no sense to me because any practitioner that is
®
serious enough about his practice to earn and maintain the CFP [professional] designation, is probably working on
practice management already. BUT, we’ll have to go through the red tape of which courses are approved, not approved,
etc. etc. etc. The business and regulatory complexes are already increasing quickly enough. Please don’t feel like you
need to keep pace. Let those who don’t work on these areas wean themselves out.
Karen L Jeske
CE hours
Since I am also a CPA and need 120 hours every 3 years; have an insurance license and need 24 hours every 2 years,
®
and my investment registration requires 10 hours every yr, do any of these overlap and count towards the CFP
[certification] required hours? I am already taking 77 hours/year to meet all my requirements. Also, 4 hours of ethics
are required as part of the CPA renewal and additional insurance ethics hours are required. Do any of the ethics count
for the 2 hour increase in ethics?
Caleb Brown, MBA,
®
CFP
Comments regarding CE
Requirements
Thanks for asking for input on your recent proposal to adjust the CE requirements. I have reviewed the proposed
changes and don't have any objections to the suggestions presented. I think these changes will more closely align us
with other established professions and should be enacted.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Dennis DeYoung, CFP
®
Page 293 of 379
Subject
Comment
Request for Comment:
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I hereby wish to convey my lack of support and disappointment in the CFP Board’s misguided attempt to make any
®
changes to the Continuing Education requirement for CFP certification. I strongly recommend that the CFP Board put
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these onerous and expensive modifications to the vote of all CFP [professional] licensees, rather than enacting these
®
measures unilaterally. Without a doubt these measures will result in a further reduction of the number of CFP
®
licensees, will alienate current CFP [professional] licensees and thwart thousands of individuals from considering
®
obtaining the CFP certification.
®
At the end of 2009 there were 126,016 CFP Professionals. As of 8/31/2012 that number had declined by nearly half, to
®
just 66,798. In less than three years our CFP Board has wiped out 47% of all CFP certificants by increasing fees,
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regulations and now by adding onerous and unjustified additional CE requirements. Almost 60,000 former CFP
®
[professionals] have already voted on the value of the CFP [professional] designation by giving it up at a time when
financial planners are more necessary and in demand than ever.
There is no evidence that increasing total CE hours required each renewal period will accomplish any goal other than
®
®
further alienating CFP [professional] licensees from the CFP Board and increasing the numbers of CFP [professional]
licensees electing to discontinue the designation. The claim from the CFP Board that the proposed increase in required
hours remains consistent with or below similar requirements for established professions and comparable designations is
pure hogwash. Here’s proof:
Designation
®
CFP
CPA, Enrolled Agent
California Insurance Life/Health
California Real Estate Broker
California Notary Public
Renewal Period
Every 2 Years
Annual
Every 2 Years
Every 4 Years
Every 4 Years
CE Hours Per Year
15 Proposing 20
15
12
11.25
1.5
®
Is being a CFP [professional] the same as being a brain surgeon ? We would all agree that keeping up with the Internal
Revenue Code is much more complicated than personal financial planning, yet the annual hours of CE required by the
IRS for CPA’s, EA’s and tax preparers is just 15 hours. The CFP Board is totally off base and out of sync with reality to
make the claim that more hours of CE are required because they believe that the competency requirements are higher
®
for CFP [professionals] than for CPA’s and other tax professionals. This is absurd and not based in fact and an
®
example of a CFP Board gone rogue. In my opinion, the number of hours required for CFP certificants should be about
half of what the IRS requires.
®
®
Let’s compare CFP [certification] CE to Real Estate Broker CE. In California, where I have been a CFP [professional]
since 1992 and a real estate broker, insurance licensee and FINRA registered since 1987, the number of hours required
by the Department of Real Estate is 45 hours every four years or 11.25 per year. The California Department of
Insurance requires 24 hours every two years (12 hours per year). Yet the CFP Board claims that the increase in
required hours remains consistent with or below similar requirements for established professions and comparable
designations. Really ?
To be very clear, here is my vote on the CFP Board changes to Continuing Education:
Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours.
No. It is a fact that increasing hours does nothing to increase competency; additional CE is unnecessary, a nuisance
®
®
and adds expense to CFP [professional] licensees. It also will lead to more CFP [professionals] giving up their license
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 294 of 379
Comment
®
and will further impede and reduce the number of financial planners from obtaining the CFP [professional] designation.
Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board's Standards of Professional Conduct and general ethics-related content.
No. The Ethics program is the most expensive hours of CE to obtain and the CFP Board has a near monopoly on
providing this requirement and charges commensurately. There is no evidence to support the claim that increasing
®
Ethics CE hours makes CFP [professionals] more ethical. This provision is nothing more than an attempt by the CFP
Board to get more revenue from licensees by increasing the hours and expense of Ethics CE.
Implementing a "50% cap rule," which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours.
®
No. Again, this only adds to the expense and hassle of maintaining CFP certification. All unused CE credits should be
eligible to be rolled over into future years similar to other licenses.
Eliminating CE credit for completing professional licenses and designation examinations.
No. Obtaining a professional license and designations is much more intensive and time consuming than taking CE
courses. There should be credit towards CE for obtaining a professional license; this is common sense. In addition, CE
from other related professions, such as accounting, law, real estate, insurance and securities should also apply
®
concurrently towards CFP [certification] CE.
In summary, piling on additional CE requirements and expense is contrary to the CFP Board’s mission. Their mission is
®
to benefit the public by granting the CFP certification and upholding it as the recognized standard of excellence for
personal financial planning. Yet by implementing additional fees, regulations and now CE requirements, the CFP Board
has forced out ½ of all CFP licensees in less than three years. If the unwritten goal of the CFP Board is to make the
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CFP [professional] club more exclusive, then certainly they have succeeded.
®
®
The CFP Board has built walls around the CFP [professional]designation, and it is no surprise that 60,000 CFP
®
[professionals] have raised the white flag and not renewed. Tens of thousands have already decided that the CFP
[professional] designation is not worth the hassle or the expense to obtain and maintain the marks. The mission of the
CFP Board should be providing the public more access to personal financial planning, not less.
®
Joseph D. Matza, CFP ,
CFS
Changes to CFP CE
®
As a CFP [professional] myself, I am vehemently opposed to ALL the changes proposed regarding CE. The current
requirements are more than sufficient. This seems to me to be an example of a group trying to justify its existence by
fixing something that’s not the least bit broken.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Monica R. Wenstrup,
®
CFP
Page 295 of 379
Subject
Comment
comments on the proposal
I do not agree with the increased hours required of CE credit for the reason to be similar to other designations. It seems
to me you are trying to be equivalent to the CPA designation. The CPA designation is a much more stringent test and
®
requires in depth knowledge of an area where a CPA designee is held liable for signing off on tax returns. The CFP
[professional] designation has no type of legal exercise for authorizing either tax or law documents.
Secondly, the CE required for an attorney is 30 hours for every 2 years.
®
In addition, I truly believe a CFP [professional] learns more from his daily practice than from obtaining these credit
®
hours. Do you really think the CFP certificant will be that much smarter with an additional 10 hours of study per 2
years?
As well, the additional requirement of 2 hours of ethics is unfounded. I do not believe someone will become more ethical
by taking an additional 1 hour of ethics every year.
®
I think the CFP [certification] requirement is sufficient where it stands.
Thank you for including us in the discussion.
Charlie Lucas, CFP
(none)
Please keep the CE requirements, including ethics, as is.
Harold Thomas Leonard
®
Jr, CFP ,MBA, FIC
CFP CE changes
I do not concur with the changes. I think 30 hours of CE every two years is sufficient. This in my opinion will be
sufficient to keep us up to date, since a lot of our learning is not just courses work and currently does not count but adds
to our knowledge base.
Two hours of ethics training is sufficient. Most professionals have additional training for our companies and states.
®
50 % cap is reasonable since as CFP [professional] we need to keep up in all areas.
Our current methods of getting CE credit are sufficient and it looks like we are adding other methods to get us to 40
hours.
Overall I am against the changes.
Cont Ed potential changes
I am full on board with the recommended changes with the exception of the designations.
®
Julie Kinney CFP ,
CRPC, CRPS
If the studying for the designation counts but the passing of the designation is not the only way to get the CE, I can see
that, but how do you verify the studying if not by the test?
If there is a cap at 50% of hours, that would take care of the the concentrated study. If the designation is approved for
CE credit it would not be a conflict.
®
There should be, and are, designations that are compatible and complement the CFP [mark].
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Scott Vincini
Page 296 of 379
Subject
New CE Proposal
Comment
It is very disappointing to see the board looking to improve the appearance of continuing education rather than focusing
solely on the quality of the education. The board's proposal increasing CE requirements to 40 hours is completely
unnecessary and presents an undue burden of form over substance. Despite spending 100-200 hours staying current
on ethics, practice management, products, legislation, etc, I struggle as a sole practioner to obtain 30 hours of certified
continuing education. The answer to everything in this profession seems to be to spend more money.
As someone who spent many years with a product provider, I know there are deep flaws in all continuing education
®
systems for insurance and CFP [professional] credits. Most of the CE participants want the credits with as little effort
on their part as possible. However, more hours does not solve the problem. The quality of the course work and the
delivery system is awful. Internet courses are easy and rarely change much between cycles. Product providers do the
minimum to meet requirements. True current event continuing education is almost impossible to get because of the
®
filing requirements needed to get new courses recognized. CFP [professionals] that keep incredibly current are not
getting credit for most of their efforts.
®
I believe the board should recognize that most CFP [professionals] are getting tons of education and some are getting
almost none. If the goal is to make sure that noone slides by, make the CE count. Here is my proposal:
• Change the biennial requirement to 24 hours and require at least 8 hours in each year so it can't be completed in a
short session. The 2 hour ethic requirement is plenty. More ethic hours does not lead to more ethical practices, it only
gives the appearance that we would be more ethical as a profession.
• Consider having a capstone course designed like the ethics course that must be taken each biennium with live
instruction.
• The best CE credits are probably provided by the trade magazines as we are at least getting current events covered.
®
• Dramatically improve the quality of CE that is approved for credit. Perhaps, think of CE as preparing the CFP
[professional] for a 2 hour update test to show that they are current.
• Consider having an actual test. The securities regulators have a test that reviews current practices and is heavy on
ethics. This test can not be failed, but the participant gets to see correct answers to all the questions missed with the
rationale behind it. They can’t help but learn from it. I believe this method is quality over quantity and can't be
circumvented by having a product wholesaler give free credits or taking the same basics of annuities course for 8 credits
every 2 years.
• Eliminate the ability to take the same course within a 4 year period. Many do not change enough to be of value.
• I like all the ideas for granting credit for pro bono work and other industry related work that betters the profession.
I have been the educator and the student and I don't see increasing the hours as beneficial to anyone but those that get
paid to offer courses. I see a lot of benefit in making sure the credits that are earned are worthwhile. Lowering the
hours and improving the quality and delivery system would make CE more beneficial to the profession.
Good luck with your research,
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Jeff Fang, CFP
Subject
®
Comment on revised CE
Page 297 of 379
Comment
I just read the Aug 17, 2012 Request for Comment: proposed revisions to CFP Board’s Continuing Education
Requirement. In general, I like nearly all the items except one. The one I question is the Eliminating CE credit for other
professional licenses. I strongly believe that other top notch licenses (such as CFA) that have a direct bearing on the
®
CFP [professional] subject area should be counted as CE. At the same time, I agree that professional licenses not
directly related to subject areas should not be included such as JD, MBA, or lower quality designations such as all the
“senior” designations.
The Board should encourage the development of professional “planners” to get other designations that increase the
scope of the knowledge of its designees. Alternatively, offer additional subject areas or deeper levels of competences in
existing ones. Some examples are CIMA, CFA, CIPM, PRM, FRM, ASA, and FSA.
Martin Beard
50% Cap rule
I have a question regarding the flexibility of the cap rule.
If the CE credit course is a mixed bag of retirement, investment and tax.
How will the cap rule be applied and monitored? Will the 50% rule be strictly enforced without exception?
Vic Sandham, CFP
®
Requested Comments
I object to all the changes proposed except those dealing with:
• 50% cap rule
• Eliminating CE credit for licensing activity
• Reviewing online courses
• Encouraging increased rigor of all CE program delivery
More requirements like those proposed mean more staff, increased membership fees and less time spent with clients.
Lance D. Perkins, CFP
®
Re: Your Input Requested:
CFP Board Proposes
Changes to Appeal Rules,
Disciplinary Rules, CE
Requirement
I am not in favor of the increased CFP Board ce requirement proposals.
Currently I am required to complete 24 ce credits for state license renewal every 2 years as well as complete the firm
element requirement and mandatory compliance attendance which must be completed each year for my broker dealer.
®
That with the 30 hours CFP [certification] requirement every 2 years I believe is sufficient. Why is it that people not in
daily practice continually come up with ideas for expanding their turf?
I am the only person currently running my practice. I am not going to hire additional people to meet new requirements
because managing them is not something that I do well. With regulatory supervision requirements and current BD
reporting and your new add-ons, I can see myself running out of time to properly service client needs AND create new
business so that I can stay in business.
CFP Board should be looking for ways to simplify practice management, not increase requirements for practitioners.
®
Tony Pondel, CFP ,
ChFC
Proposals
I vote NO on all three. Leave things as is.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Mark Mundt, CFP
Subject
®
David Iommarini
Candy Wood, CFP
®
Page 298 of 379
Comment
No change to CE
requirements
No Change to CE requirements.
CEU's
I am not a practicing CFP [professional], but want to remain knowledgeable. Perhaps there should be different
®
requirements for practicing and non-practicing CFP [professionals].
comment on increased
continuing education
I have been a CFP [professional] since 1992 and have watched it evolve over the years. I am a supporter of continuing
education. As a CPA since 1988, I must achieve annual requirements as well.
®
It is a natural progression of overlap for many courses I take for my CPA and CFP [certification] however lately, I have
noticed CFP [Board] will only accept what is on their list which is very driven on the investment broker side.
I do not wish to pick classes based on the offerings of the CFP [Board] organization and be forced to pay extra when the
classes are not on the list but are nationally accepted by the CPA organizations. Additionally, I do not see any reason to
add hours to the ethics requirement. In this world unfortunately people will try to beat the system no matter how much
education is forced on them. For those of us who chose to be honest, I resent being forced to go over the same material
and pay for it to satisfy a belief that more is better. I have spoken to a number of CE educators who believe the actions
of the CFP Board are revenue driven. I would hate to think this might be true, but based on how much extra I had to pay
®
last year, I wonder. This newest action only firms up that opinion. I want to maintain my CFP [certification] even if only
to know I use it to have a more rounded view for my clients even if I don’t do financial plans any more. But I am finding
®
these new rules very imposing and I may have to give up my CFP [marks] because of it. I worked so hard to get those
marks years ago and have been proud to carry them next to my name.
®
®
I hope the CFP Board looks closely at what they are really trying to achieve and stop adding extra requirements and
costs to bolster up their appearance. Maybe they could follow the IRS policy of accepting the CPA CE standard for their
tax prep practitioners as that has a proven record. For me to have to take more courses on top of my CPA and pay
more just because it is not on your list seems very unfair.
Aaron S. Archambo,
®
CFP
CE proposals
Overall I support the recommendations for the change to our current CE requirements. However, I do have one
suggestion:
I would prefer to see 2 hours credited for every 4 hours of pro bono service. In my opinion, this serves to encourage
such practice over only accepting 1 hour for every 4 served. This is a vital part of our industry and needs to be
rewarded and encouraged.
Other than my comment above I fully support the proposed CE recommendations.
RICHARD A. HILLIARD,
CFP
FW: Your Input Requested:
CFP Board Proposes
Changes to Appeal Rules,
Disciplinary Rules, CE
Requirement
Looking for time to complete.. it general.. the 32 hours is more than enough and 40 hours is not an important in light of
other CE required by other organizations.. and the credit up to 4 hours for other items makes great sense.. are my
thoughts..
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 299 of 379
Comment
James A. Ardaiolo,
®
CFP
FW: Your Input Requested:
CFP Board Proposes
Changes to Appeal Rules,
Disciplinary Rules, CE
Requirement
Regarding the CE changes, I am against them. It is hard enough now getting requirements in much less increasing
them. All these changes simply put more burden on certificants when they have already proven themselves. CE does
nothing to catch "bad guys" and I suspect that is what may be behind some of these proposals.
Christopher R. Cadieux,
®
CFA, CFP
increasing ce requirements
I have been a CFP [professional] certificate holder for over fifteen years. I also hold the AIF and CFA designations am
insurance licensed and hold a series 7 in addition to a series 24.
®
At 30 hours per two year period I believe the current level is more than adequate. To assume that the only continuing
education person in my profession like myself perform is 30 hours is ludicrous.
Each week I literally spend 4-5 hours in research, education and planning topics including webinars, conference call and
®
articles. The fact that the majority of the above mentioned do not qualify for CE credit for the CFP [professional]
designation is not my fault. Submitting for review such material to the CFP Board is costly and time consuming.
®
I am proud of my accomplishment in completing me CFP certification but certainly do not need it. If the requirement is
raised and no accommodations are made to expand dramatically what is considered for CE credit I will no longer
®
continue my registration. I am aware of others who feel this way and individuals who have already dropped the CFP
[professional] designation for this reason.
Al Brown
Lou mohlman, CFP
®
John D. Mitchell, CFP
®
Comments
Increasing the number of hours only continues to increase the cost without improving the quality. The proposal is far
more complex that necessary. More ethics is an example. All available courses are similar and add nothing to
expanding ethical behavior by increasing the CE requirement.
Ce comments
The CFP Board have been limiting what qualifeids for financial planning ce which makes it hard for fpa and our company
wells fargro advisors get the amount of ce each 2 years at 15 hours let along 20 hours. I have had 10 ce this year for
wells fargro advisor and not one quailified for ce.
Continuing ed
I am not a fan of increasing the hourly requirement. I would be much more enthusiastic about improving the quality of
the CE. I agree that good CE requirements are needed, but don't believe more of what we currently have is an
improvement.
Many of us are also licensed as insurance and securities practitioners. It seems everyone is increasing the hourly
requirement to give the appearance of quality. Also, there are very few reciprocity programs, so many of these
requirements "stack". The amount of hours required pushes practitioners to find the easiest way to get the credits, not
focus on quality.
I don't believe it produces the outcome we want.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Malcolm Trevillian CFP
Continuing Ed Proposal
Page 300 of 379
Comment
I oppose increasing the requirement to 40 hours. 40 hours IS NOT consistent with other comparable designations. The
CFA does not currently require 30 hours of CE. Neither does the CMT (Chartered Market Technician) designation.
I oppose adding pro bono activities for CE. Pro bono activities are not learning opportunities and don’t make us more
knowledgeable.
I oppose adding practice management to CE. Practice management has little to do with providing planning to clients.
I agree with making Ethics a larger requirement than 2 hours.
I agree with expanding CE to include professional activities such as teaching and research. I’ve taught investment
®
planning to CFP [professional] candidates and it does force one to learn the material thoroughly.
I oppose implementing a 50% cap rule to any single program area. My specialty is retirement planning. I work with
CPAs, estate planners and insurance professionals to deliver those services. I prefer to concentrate on what I do best
and what my clients hire me for.
®
If the CE requirement is increased to 40 hours every two years, I will drop my CFP [professional] designation.
Donald L. Haisman,
®
CFP
®
Tim Catron, CFP ,
®
CRPS
®
Proposed Changes to
Continuing Education
Requirement
I have been a CFP [professional] since 1987.
I strongly support the proposed changes to the continuing education requirement.
Comments about Proposed
Changes to CE
Requirements
Regarding the new proposed CE requirements:
®
Please note that I am completely against adding any additional CE requirements for the renewal of CFP [certification]
license. I feel strongly about this for the following reasons:
1) I have rarely ever benefited by taking any CE class. Most of the information that is taught in those programs is either
information I do not need to know to conduct my business or information I already know. Bottom line is this: My
occupation requires me to learn new things on a daily basis and forces me to learn exactly what I need to know in order
to conduct business. In essence, the best continuing education I could possibly have is staying at work and conducting
my business. Any CE class pulls me away from that vital task and ends up wasting my time!
2) Requiring more CE for Ethics is another waste of time and money. Taking any ethics class will not make a person
more ethical. Either they are ethical or they are not.
3) The other new proposed requirements merely complicate a process that is already time consuming, a racket, and a
waste of time. The Board needs to stop trying to add layers of minutia to Certificant’s lives. In this outrageous
environment of regulation we all need far less minutia and bureaucracy in our lives, not more!
4) These proposed CE requirements may give the Board a good feeling and may sound good on the surface but these
actions will only raise costs for everyone, waste valuable time, and do absolutely no good! Mark my words: If these new
rules go into effect the renewal fees will go up not to mention the cost of time and money for each Certificant in order to
complete the additional requirements.
®
5) If these CE rules go into effect then I will need to seriously consider giving up the CFP [professional] designation.
PLEASE DO NOT CHANGE ANY OF THE CE REQUIREMENTS!!!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Gary Gauthier, CFP
Subject
®
Oscar N. Alvarez, M.S.,
CLTC
James R. Brown, CFP
®
Stephen W. Roberts,
®
CFM, CFP
®
Robert A. Kokol, CFP ,
®
CDFA ™, AEP , MBA
Page 301 of 379
Comment
®
Proposed Changes
I do not agree with increasing the total CE hours from 30 to 40 or the ethics component from 2 to 4 hours. Most CFP
[professionals] are also business owners who are already stretched in meeting the demands of running a businesscontinued education on new products, technology, broker-dealer required training, keeping up with tax law changes,
compliance policies/procedures, etc, etc., etc.. I, as well as others I've discussed this with, see very little value derived
from the hours already dedicated towards the existing 30 hour CE requirement. Adding more hours will have no direct
impact or benefit to clients. Yes, it may "sound" better to them since 30 is more than 40 and 4 is more than 2, but let's
®
look at the reality of the situation- have CFP certificants truly gained additional knowledge that makes a difference in
the lives of our clients? I honestly do not see that happening and therefore recommend maintaining the current
requirements.,
CE credits
As a new certificant I do not have a problem with increasing the CE requirements. I do not agree with the rationale for
not accepting CE credits from other institutions that develop programs/certifications for financial advisors, such as the
American College. It will require significantly more courses to be taken each two year period at significantly more cost to
®
the Certificant. I estimate I will be spending an additional $3000-$4000 per renewal period to maintain my CFP
[professional] designation. Thank you.
Changes to CE
requirements
I have no problem with any of the changes except I think it is unnecessary to require classroom attendance to receive
credit. This would impose a time and financial hardship on me. Please consider removing this aspect from the proposed
changes.
Please do NOT increase
the continuing education
requirement.
We are swamped with mandatory continuing education requirements at the major firms already. Also, please note, you
cannot teach ethical behavior.
CE requirements
Please send the recap of the requirements of other designations that determined 40 hours was appropriate. On what
basis was this changed? Who else is required to complete 40 hours of education?
Also, as many of us have multiple designations, will there be any greater flexibility in allowing education for say the
®
CDFA or family law mediation certification for divorce work to count towards the CE for CFP [certification]? It is not the
40 hours of CFP that is the issue, but the total hours of all CE for all designation that we hold. (see below) that is
becoming more and more complicated. As for doing these in person, will the FPA produce a longer annual conference
in each market to accommodate the 40 hour requirement?
Chad H. Carlson, CFP
Janet K. Poppen
®
feedback regarding
proposed CE requirement
I’m writing in support of the increased CE requirement and provisions. In addition, I would propose for review that in lieu
of an additional 2 hour “ethics” requirement, consider a 2 hour “practice standards” requirement. Thank you, Board of
Standards, for your fine leadership of our profession.
Comment on Revised CE
provisions
Requiring 4 hours of Ethics and inserting a 50% cap limit - seems to be a redundancy here. General Principles = Ethics
= 10%; then Practice Development vs actual knowledge courses must be included.
®
I would suggest requiring the Ethics and let the remaining 90% be allocated by the CFP [professional’s] personal
assessment for additional knowledge in the other fields.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Grant A. Blasdell, CFP
Subject
CE Credit opinions
Page 302 of 379
Comment
Below are my personal opinions on the proposed changes by the CFP board for CE credits:
• I have no dispute with increasing the number of CE hours to 40 every two years. The way this business has expanded
in scope and complexity over the past 30 years, this is to be expected.
• I have no dispute over the proposal to grant CE credit for Practice Management programs, but pro bono work should
not be credited. First, the principle of pro bono is that you do not expect to be compensated in any way, so crediting CE
for this function is wrong! In addition, unless the pro bono work is well documented, CE credits could be abused by
some. I know I seldom copy pro bono work for my files because I do pro bono work away from the office and the
required copy/fax/printing equipment is not available. I just think this category for pro bono credit could be abused.
• I have no dispute with increasing the Ethics CE to 4 hours, but I would expect the board to allow credit for
Broker/Dealer Firm Element training now required by FINRA for credit, as well as the ethics training required for licensed
tax preparers are required to complete. I personally attend annual training for tax preparers from the University of Illinois
Tax School. This training should count towards the ethics CE requirement. I also feel that credit should be given to
Branch Managers for Broker-Dealers as we have to complete additional ethics training to supervise Registered
Representatives. This is intensive training both on the computer, as well as attending annual Compliance Meeting with
our B/D's. This is all mandated by FINRA, and should be recognized by the CFP Board for CE credit. Our principals are
being reinforced in every one of these required courses and classes, and the CFP Board should recognize that!
• I have no knowledge of the "capstone" program so I am not qualified to comment. I think that granting CE credits for
Study Group Activities should but closely monitored, and meet strict guidelines to prevent abuse.
• I disagree with limiting CE credit to 50% for any single topic. In the past 20 years I have up to 60% of my CE credits
from Tax School training. This is an arduous and detailed topic that changes constantly, and to study it in class for 18 to
24 hours, study the manual even more after the classes and then have the CFP Board not recognize my effort towards
®
®
improving myself as a CFP [professional] is unacceptable. CFP [professionals] deserve the full recognition for all CE
no matter what the topic. Please do not create a cap of 50% on my CE hours. Please note: The University of Illinois
expanded the Tax School curriculum from a 2 day event to a 3 day event for 2012 due to the complexity of the tax code,
®
and the additional competency required to be a registered tax preparer and a CFP [professional]. There are many of us
out here!
• I dispute your logic to eliminate CE for the training and testing required for completing professional licensing. Anyone
®
that has taken a FINRA test for Series 7, 24, 63, etc. has had the basic principles of the CFP [certification] curriculum
(i.e. know your client, ethics, portfolio construction, risk tolerance and risk management, etc.) beaten into us with every
test. For the CFP Board to ignore this training and testing of CFP principles by not granting CE credit is unacceptable.
Grant the credit if the applicant has passed the test. Logically, they are better qualified to represent the profession, so
they deserve the CE.
• The online CE credit for academic courses is appropriate. I applaud your recognition of the type of self-study program
and testing. On-line is the direction of all training.
• Encouraging increased rigor and quality of all CE programs is a nice way to say, "You folks have to do your jobs and
do them more diligently!" I agree with that premise!
•
Thank you for your consideration!
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Richard C. Perkins
Subject
Comments
Page 303 of 379
Comment
The increase from 30 to 40 hours is ridiculous. It is time consuming and expensive and with all the additional paperwork
required by FINRA, SEC and Broker –Dealers the incursion on time for financially rewarding productivity is shrinking
rapidly. Your rationalization for doing this is very bureaucratic and unjustified. No matter how many hours your put on
®
the backs of CFP [professionals] you will never eliminate the Madoff’s, Stanford’s, Global’s and Peregrine’s of the
world.
I am totally against this increase for what it is worth.
George W. Hunter III,
®
CFP
CE requirement comments
I understand the requirement of CE for the continued development and honing of our practice skills. I believe that we
should ensure that the available CE is of high quality and is current. I do not agree with increasing the requirements
from 30 to 40 hours. I think that we should work to ensure that the available training is good training that will help us
stay current and competent.
I am not clear on how the 50% rule would apply and be implemented. The categories seem to be a bit arbitrary and
somewhat cobbled together. I would like to propose that we as professionals would be able to decide where we need to
hone our skills or where the changes in the market may require substantial refreshment on our part. Obviously within
the last year there have been more development in the Retirement and Estate topic than in the interpersonal
communication area. I do not want to be in a position to cram in 20 or more hours in an area because someone has
decided for me that I need 10 more hours in something and that something can’t be what I believe I need to develop.
These rules can have unintended consequences. We may be encouraging cramming and not encouraging lifetime
practice management and yearning for learning.
Howard Kite, CLU,
®
ChFC, CFP
Ongoing CE requirements
I strongly object to increasing the hourly requirement for training, not because I am opposed to training, but rather your
process for getting approval for courses offered by legitimate providers of ongoing education is cumbersome, antiquated
and frankly too difficult to deal with. Unless you do something about making it easier for coursework to be approved for
eligible credits you should not institute a process that makes it harder on the vast majority of members to get their
credits. Many of us who hold multiple licenses and designations go to plenty of continuing education courses, yet there
is not a lot of crossover of courses because of this organizations highly frustrating process. Frankly, when I have talked
with some providers of CE from investment companies or insurance companies, many have just stopped filing.
In my former position with my broker dealer, Genworth Financial Securities, formerly Terra Securities Corp, I oversaw
the education program providing ongoing education to over 2000 registered representatives/advisers. Our requirement
up until the last several years of my tenure as COO and National Sales Manager was to require 20 hours of in person
training. We ran over 200 meetings throughout the country that were scheduled and outlined. Additionally he held a
national convention that attracted between 600 and 1000 representatives. On top of that there were hundreds of other
mini meetings of groups of 10 or less for advisers throughout the country. We did not rely on wholesalers for majority of
the training but rather developed much of the curriculum in house.
An example of how difficult you made the process could be best illustrated in that we offered a 3 day National
Convention, offering up to 6 tracks of training over 5 hours each day, plus main stage speakers. When we applied for
CE credits we were very rarely granted over 6 hours for the sessions. It is interesting that in many cases I was selecting
topics that were also offered at the FPA National that you were giving full credits for. Additionally, because you would be
so behind in reviewing materials, often months, we couldn’t even publish which sessions were granted hours so that
attendees could make a selection. Frankly, because of your inadequacies, we the provider were made to look bad. So,
it was often I would make a statement from the main stage that it was your (our) organization, the FPA, that was less
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 304 of 379
Comment
than a satisfactory service provider.
There should be enough staff so that providers of CE should be able to get approval for any presentation within a 30 day
period. It should be a revenue source for the organization to get the filings done. In fact to make up for you slowness
you could offer a fast track fee to get an approval in a shorter period of time. Why not offer a lesser fee and fast track if
the coursework was already approved buy some other legitimate regulatory body (state insurance commissioners, CPA,
PFS, bar associations, NAIFA).
®
Annually, I get many more than 40 hours of ongoing CE to validate my licenses, yet very little is crossover to CFP
[certification]. I don’t object to getting education, in fact I am a strong proponent, however it is really a waste of energy
at the end of the year to scramble for credits. Please consider cleaning up your own process and making a broader
public statement to providers that you have streamlined that process (or at least attempt to do so), before you make
changes to the requirement.
Philip Overton, CLU,
ChFC, CFP (R)
Continuing Education
Requirements
I would like to see the continuing education requirements stay the same as I feel
that it is more than adequate. I am overloaded with CE as it is as I hold multiple designations
and insurance licenses, as many of us do. I also continually need to do company sponsored CE,
which is required by FINRA. The 30 hours every two years with 2 hours of ethics is right.
Thank you for your consideration.
Nicholas D'Ambrosio,
®
CFP
CE
I am not in favor of formally adding 10 hours to the CE requirement, nor to the ethics hours. Currently most of us are
reading many journals containing useful information for which we receive no additional credit. Also, those of us to attend
regular study groups to share knowledge and get problem solving help receive no credit for those hours.
I agree with the need to limit the number of hours for one topic area to 50%.
I am not in favor of providing CE credit for Pro Bono work nor Practice Management skills. Neither fits the definition of
CE. If the former did, then all financial planning work should receive CE credits.
Overall, many of the planners I know are probably achieving more than 30 and close to 40 hours at this time but I do not
wish it to be mandated.
Dave Oakley CFP©
CE Ethics requirement
I think doubling the ethics requirement for maintaining our designation is not going to improve ethics in the practices. It
is the most boring class I am required to take every two years.
Either a certificate is going to be ethical and honest or not, regardless of how many classes he attends.
As a registered rep and licensed insurance professional I am required to take [end of message]
Lisa Sappenfield Boyer,
CFP
FW: Your Input Requested:
CFP Board Proposes
Changes to Appeal Rules,
Disciplinary Rules, CE
Requirement
I think some of the ideas like more ethics, diversifying subjects, and practice management credits are good, but I DON’T
®
NEED ANOTHER 10 HOURS TO COMPLETE. We now have CFP CFP [certification, FINRA, STATE INSURANCE,
BROKER DEALER, and PRODUCT SPECIFIC continuing education to do. Why are we spending so much time and
money on all these different trainings instead of helping clients? Keep hours at 30 and spread among items mentioned.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 305 of 379
Comment
®
Royden A. Grimm,
®
CFP
(none)
I strongly recommend an increase in quality/rigor to CE requirements(and by extension the CFP [certification] itself).
Quantity, especially the way some practioners rush through it, does not increase , and can in fact decrease the quality
that you are trying to achieve.
Alexander G. Kondeas,
®
CFP
Proposed Elimination of CE
Credit for obtaining other
Designations
The proposal to eliminate CE credit for obtaining other quality designations seems self-conflicting, at least the way it is
currently written.
The proposal would still grant CE credit for taking a course of study towards passing a designation examination, but not
for passing the designation examination itself.
With all due respect, I would like to argue that taking a course of study does not prove the Certificant learned the course
material. Passing the examination is a better indicator of the Certificant’s skill level. For instance, passing a CFA Level
exam is more indicative of the Certificant’s skills than completing a course in Investments or Financial Management. If
anything should earn CE credits, it should be the evidence of passing a rigorous examination on material relevant to the
®
CFP [certification] curriculum.
If taking a course of study is a greater accomplishment than passing the designation examination (that the course of
®
study is leading to), then the CFP Board should consider eliminating the CFP examination requirement altogether, and
®
grant the CFP [professional] designation based on completion of a course of study.
Theodore F. Poatsy, Jr.
CFP
®
Mark N. Stubbs, CFP
40 Credit Hours
I oppose increasing the number of credit hours from 30 for 2 years to 40 credit hours as proposed. As professionals, we
do stay abreast of current trends and changes to our industry and we do not need big brother demanding another 10
hours of our time for continuing education. Thirty hours is plenty. Please do not change the requirement.
Continuing Education
Proposals
I am against increasing the number of required hours of continuing education hours from 30 to 40.
My reasons for this include the following:
®
1. Through completing the firm element requirement for CE the CFP Practitioner is already getting far more than the
currently required 30 hours of CE.
2. So many of the insurance products such as Medicare Supplement and Disability Insurance already require annual CE
to be able to place clients in these products.
3. Adding additional CE requirements will take away from important “face time” with our clients.
®
4. Requiring more CE in ethics is not going to make any CFP practitioner more ethical. Ethics is something a person
either has or does not have when he becomes an adult; no amount of classroom instruction on ethics is going to make
one more ethical.
5. The academics and CE providers recommending that we be required to have more CE have a vested monetary
conflict of interest in recommending this. They receive compensation when we sign up and take their courses. My
guess is that if the courses were free they would not be making this recommendation.
®
6. Regarding Number 5 above, requiring more CE will place an additional financial burden on CFP practitioners at a
time when the economy is still recovering from the Great Recession of 2008 and 2009. Many of us are still in the
process of building back assets under management to replace lost compensation and we do not need more educational
requirements thrown our way during this very fragile economic time.
®
7. Requiring 10 hours of additional CE is a 33% increase, which may deter new professionals from pursuing the CFP
[professional] designation at a time when we are as a profession trying to increase the number of Americans having the
®
availability of working with a CFP Professional Certificant. Furthermore, increasing this requirement may encourage
some current certificants not to renew their designations, continuing to lower the number of certificants available to work
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 306 of 379
Comment
with the public.
8. Finally, enough is enough. Where do you draw the line on something like this. Will it go to 50 hours five years from
now, and 60 hours again five years later. One has to draw the line somewhere. There is already so many variables
taking time away from face time with clients that we do not need to add any more.
Tina Anders, Certified
Financial Planner ™
ethics rqmt
I think 4 hours of Ethics is too much. i just took an approved 2-hour course and I feel that it was comprehensive enough
to give me the education necessary to conduct myself and my business within the ethical standards of the CFP Board.
Jack B. Mace, CFP ,
®
®
CLU , ChFC
CE Requirements
I do not agree with the Proposed Changes to Continuing Education Requirement
Bill Wixon, CFP(R),
AWMA(R), MBA
CE chgs.
I like the add'l ethics hours.
®
I like the restrictions on one single topic.
I am not sure about the need to expand to 10 more hours every 2 years.
I kind of assume that you are paying attention to the lawyers and CPA's and what they require. I think that they should
both serve as a model for our profession and we should align ourselves with their CE regimen.
®
I am the founder of my firm 23 years ago. I have quite active in the MN FPA . In my 11 years as a CFP [professional] it
has greatly changed the way I do
business . . . for the better. I am grateful for the leadership
in my profession. Thank you!
Monica Storm
Proposed CE changes
I do not agree with changes to the CE hour requirements. Many of the
®
CFP professionals carry other related licenses that require CE hours,
also. I am insurance and securities licensed. I must maintain firm
element CE for my Securities license, Insurance CE for my resident state. In addition, I must complete product specific
training for insurance/annuities and many states do not maintain reciprocity. I could spend a full month each year
completing CE hours.
I understand the desire to make sure certificate holders are getting the required training, but I would like to think that
those of us that are working in a thriving practice are seeking CE courses in areas that are related to how we practice
and that are beneficial to the clients we serve.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Brian Scanlon
CE Changes
Page 307 of 379
Comment
I see your ideas on the continuing Ed and wanted to comment.
- I agree with the increased number of hours
-that being said, I do not think you should take away flexibility to earn those hours in ways we deem sufficient for our
business I.e., not allowing other designation's training to count for credits and limiting the areas of credit to 50%
I also agree with the addition of practice management and pro bono work counting for credit.
I do think they should be their own category for 4 hours each as a limit
I do not agree with more business ethics hours, if the current level is not enough, you should not be in this business. The
®
ethics course should serve as a refresher. I believe that the large majority of CFP certificants are ethical. Adding more
hours to the requirement is not going to change a few bad apples and takes away form learning what truly helps our
clients.
Thank you for taking our thoughts into consideration.
John M. Brantner, CFP
®
Comments on propsed
revisions to CFP Board's
Continuing Education
Requirement
®
®
Based on the 2011 CFP Professionals Survey, most CFP professionals are involved in financial occupations which
require multiple licenses from national or state level licensing authorities, including, but not limited to, Series 7 and
Series 66 licenses, and life and health insurance licenses. Each of these licenses requires a significant amount of
®
continuing education hours (all of which are highly pertinent to the CFP [certification] job task domains and focus areas
®
of knowledge) every two years. In addition to this, the employing firms of many CFP professionals impose large
additional CE requirements on their employees to maintain and enhance competency in financial planning and financial
management practices. The 30 hours of CE requirement every two years imposed by the CFP Board is therefore in
®
addition to as many as 40 plus hours per year of required continuing education already imposed on CFP professional
working in the field of investment management and financial planning. As an example, the State of Alaska requires 24
hours of CE every two years, of which at least three must be dedicated to ethics training, just to maintain an insurance
license.
While we recognize that the field of financial planning comprises a rapidly changing body of knowledge, I would contend
®
that the average CFP professional is adequately updating their knowledge through the large amount of CE hours
already required for their various licenses and by their employer, in addition to the 30 more hours already required by
®
the CFP Board. An additional 10 hours of CE is perhaps not too great a burden on the CFP professional operating
their own business (therefore eliminating the large number of additional CE hours required by many employing firms in
the financial services industry) and practicing only financial planning without additional securities or insurance licenses
®
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with their own CFP [certification] pertinent CE requirements. However, for the majority of CFP professionals, the
number of CE hours already required to keep current in the fields of investments, insurance, ethics, and general
financial planning principles is more than sufficient and already a significant commitment of time. Moreover, I would
contend that when you combine the financial planning related CE hours already imposed by the CFP board and the
®
financial planning related CE hours imposed by regulators and employers, the average CFP professional is already
completing significantly more pertinent continuing education hours than required for similar established professions and
comparable designations.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Jim Welch
Todd D. Shepard, CFP
John Chapman
®
Page 308 of 379
Comment
CE Changes
I think that the CE requirements are already too rigorous. I have four designations all with some form of continuing
education requirements. I also teach two graduate school classes per year in addition to my full time job at a private
bank. As part of my full time job, I have ongoing compliance commitments which are not accepted as continuing
®
education credits by any of the organizations of which I am a member. I think if these changes to CFP [certification] CE
requirements were open to a vote, members would vote against them. Our lives are busy enough already, why make
them busier.
CE Requirements
I support nearly all the recommendations. My only objection is the 50% limitation in any one subject area. I think 6075% would be a more reasonable requirement as many planners focus or specialize and it may be appropriate to go
deeper in subject areas vs. wider across many areas.
Proposed Rule changes
With regard to the proposed rule changes:
Proposed Revisions to Appeal Rules
Oppose
Proposed Revisions to Disciplinary Rules
Oppose
Proposed Changes to Continuing Education Requirement
Oppose;
I'm already required to complete 30 hrs bi-annum for Insurance & 30 hrs
bi-annum for Securities How many more hours do you think I need?
Your efforts do not help the cause but rather hinder the debate.
Michael Arnold MBA
®
CFP
FW: Your Input Requested:
CFP Board Proposes
Changes to Appeal Rules,
Disciplinary Rules, CE
Requirement
®
Straight to the point you are creating additional expense to maintaining a CFP [certification] and you are increasing the
amount of time I spend on meeting CE credit requirements.
You, as a board, and as a designation recognized by the public, have to provide us (advisors) with more VALUE in order
to justify the continued increasing cost to maintain the designation.
The best thing you can do in junction with this, is help reduce the cost of earning CE credits and do something to
actually help advisory practices take on more clients. Education and earning CE does not bring people in the door. You
need consider how you are going to provide more value to us(Advisors) to justify your annually increasing costs.
Steve McHale, CFP
®
CE Comment
The current CE program is fine.
Don’t Break / “Try to Fix” things that are working well.
Frank W. Bagrier, CFP
FW: Your Input Requested:
CFP Board Proposes
Changes to Appeal Rules,
Disciplinary Rules, CE
Requirement
I believe that increasing the CE requirement to 40 hours every 2 years is not necessary. It takes significant time away
from actually assisting clients with financial planning, making us less productive as planners. The most meaningful
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information and learning for me, since being a CFP [professional] in 1985, has been in meetings, readings and
programs that do not even qualify for CE.
Also, adding to ethics is redundant and unnecessary. Major firms, such as the one I work for, have their own ethics
programs. Again, most of the ethics courses I have do not even qualify for CE credit. So, overall, I do not agree with
these recommendations.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Joe Saskiewicz, CFP
Subject
®
Proposed new
requirements 50% CE cap
rule
Page 309 of 379
Comment
I am not in agreement with the proposed 50% CE cap rule.I think this could cause registrants problems in keeping track
of their allocations to satisfy the proposed rule. This could also create a situation where one is taking a course solely to
satisfy a certain area to be in compliance. If a practitioner is specializing in a limited areas than he/she could be
concentrating their CE efforts to be the best in these areas.As a professional you realize you often seek help from allied
professionals or fellow colleagues in those areas where we may not have the skill or interest.We already satisfied
competency in a very broad area of topics for our designation.
Let's promote more education not stating the mandatory areas we must satisfy to continue our currency of the CFP
mark.
William H. Kirby, CFP
Comments
®
Is there any evidence to indicate that 40 hours will make us better practitioners than 30 hours. The rationale given here
suggest we are adding a burden because the other guys are.
It seems to me that supervision by a registered CE sponsor will discourage Pro Bono work. Can't the work be certified
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by a CFP supervisor or independent CFP professional? What deliverable is required for certification?
• Increasing the Ethics CE requirement from 2 hours to 4 hours:
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Why does this make a CFP [professional] more ethical? If four hours is good, why not 8 or 12?
What are the deliverables to certify Study Group Activities and Research?
Derek G. Fuelling, CFP
Rachel O'Shia
®
®
CE increase hours
I am a CFP [professional] and do not approve the increase. I am also licensed for insurance and as a Tax preparer
going for Enrolled Agent. All these require CE, and the effort to maintain the requirements is getting to be extreme, don't
you agree. I have better things to do and the 30 hours is more than enough plus the increase in fees. Stop the madness,
Please.
Go back to shuffling papers and leave the working folks alone.
Eliminating Credit for
Completing Professional
Licenses or Designations
I am opposed to the elimination of credit for completing professional licenses or designations. I am a Level II CFA
candidate. I spent approximately 300 hours studying for the Level I exam, and expect to allocate additional study time
for the more difficult, remaining exams. If the professional license or designation is focused on a deeper understanding
®
®
of one of the CFP [certification] principal topics than is offered through the CFP [certification] program, it seems a bit
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petty to suggest that the additional license or designation training isn't worthy of CFP [certification] CE credit.
Requiring 2 ethics hours to be completed through the CFP Board appears self-serving, unless it is provided at no cost
as a benefit of the annual dues.
While I agree that financial planning practices are fast-changing and require diligent study, I have to believe that most
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CFP certificants currently practicing in any related field receive sufficent on-going updates through employer sponsored
presentations or various vendors that generally aren't submitted for CE credit. On average, I spend 3 hours a week on
employer-provided conference calls discussing changes in tax laws, economic conditions, the effect of politics on the
economy, tactical asset allocation recommendations, etc. In addition, my firm subscribes to three major economic
research providers who send a dozen emails per day on various topics and host periodic conference calls, as well as
receiving emails and conference call invitations from vendors such as iShares. In my opinion, the value of required CE
credit is in having a small portion of the true time spent on continuing education recognized. I am opposed to increasing
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 310 of 379
Comment
the requirement by 10 hours.
Donald G. Terns
Pro bono
My partners and I believe 40 hours of CE would be fine as long as we are
given credit for hours that are required for our other licenses such as securities,
insurance, real estate, CPA and other areas of related expertise. In addition,
the related industry that tracks the hours and credits them accordingly
should be accepted at face value rather than be put through additional
scrutiny by the board. The CFP Board should accept these hours that
regulatory agencies at the state and federal level require.
®
In the past 28 years of being a CFP [professional] I have contributed thousands of hours
to various individuals who were referred by various religious and non-profit
organizations. How could this be supervised by a registered CE Sponsor
organization? I would suggest a letter signed by the referring organization
to whom the services were referred should be sufficient.
Pro Bono (volunteer personal delivery of financial planning) services.
These activities must be supervised by a registered CE Sponsor organization
and will be accepted for 1 hour CE credit per 4 hours pro bono service
I look forward to your response.
Stefan Williams, CFP
®
Paul Hilliard
CE changes
I support all of the proposed changes to the CE requirements.
CE
I think the requirements are enough where they are now.
We have practices to run and clients to serve.
Marian M Deering,CFP
Jordan Edwards, CFP
®
®
Proposed CE
Requirements
I believe that CE should be required to maintain professional licensing and currently participate in continuing education
®
for my Series 7, California State Insurance, CFP [certification], as well as the many hours of internal CE that is required
by my employer, UBS Financial Services. It is incorrect to believe that requiring more coursework in Ethics will make
people more ethical - we are either ethical or not. I support having a standard Ethics course, but not requiring an
additional course. I support requiring a diversification of disciplines studied. I do not support increasing the time or
restricting online courses.
CE hour increase
I am of the opinion that continuing to increase the CE requirements is a bit onerous. I fully understand the
need for CE, but considering that the CFA program doesn’t require any CE at all to maintain that designation, 30 hours
every two years should be plenty to keep advisors informed and up to date. The more time we as advisors are required
doing CE, the less time we have to devote to our clients which is clearly has a point at which it stops being beneficial to
them. My experience has been that 15 hours every year is more than enough to make sure that we as advisors are
keeping up our knowledge, but is already on the edge of being too much. I think adding more hours will push us over
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that edge and will probably over time provide disincentives towards maintaining the CFP marks.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 311 of 379
Comment
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Ann Marie McLaughlin
comments on increasing
CE hours for CFP
I think CE hours for CFP [certification] should remain at 30 hours every 2 years. I am also a Registered Tax Preparer
and now required to get 15 CE hours every year for this . This is time taken away from dealing with clients who are
getting more and more demanding.
Christine Stewart
FPA Phila.
As the administrator of the FPA Philadelphia Tri-State Area Chapter, I had the opportunity to speak to several of our
members at our annual Fall Retreat yesterday about these proposed changes. As I suspected, they were not at all
happy with these proposals. These proposals, combined with the recent increase in dues, is not sitting well with the
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members. So much so that all 3 of them actually said they would drop their membership and CFP [professional]
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designations. A lot of these members are older with established clientele. Their clients have no clue what a CFP
[professional] is and could care less if their advisor holds the designation or not. And most of these members hold many
other (more well-known) designations. These members perceive the recent dues increase as lining the pockets of the
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senior staff of the CFP Board and that the whole "Marketing Campaign" to increase public awareness of the CFP mark
was a total waste of resources.
®
As the admin. of an FPA chapter, with more than half our membership holding the CFP [professional] designation, I
fear these changes are going to result in a decrease in our membership as well. One member stated the only reason
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they belong to FPA is to get their CFP [certification] CE's through our chapter. Thus, when he drops his CFP
[certification], he will also drop FPA. People are struggling just trying to keep their businesses afloat, and now have to
spend 10 more hours on CE as well as more money to obtains these credits.
As a chapter, we will now have to increase our offerings to accommodate these proposed additional CE requirements,
resulting in more money the chapter has to spend on administrative services to execute these offerings.
®
For many, many years, I personally was a strong proponent of adding practice management to the list of approved CFP
[certification] CE offerings and never understood the resistance from the CFP Board. I see that is now part of your
proposal, but it comes with many strings attached. What is should have been (and still could be) is a SIMPLE addition
to the list of offerings. A fair proposal would be to allow 2 practice management hours as part of the 30 required.
The members I spoke to were also extremely skeptical, as am I, with regard to this solicitation of comments. They feel
that this is a "done deal" and that no matter what the members say, it will not change a thing.
Ralph H. Barringer,
CLU, CLTC, ChFC,
®
CFP
Russell K. Achzet, CFP
Jo Ann Stone CFP
®
FW: Your Input Requested:
CFP Board Proposes
Changes to Appeal Rules,
Disciplinary Rules, CE
Requirement
Do not agree with increasing CE from 30 to 40 hours and “cap” provisions. Individual practices will emphasize certain
aspects of planning to a greater degree than others, we as a governing body should embrace diversity of our body’s
individual autonomies while being sure that practices do not abuse their fiduciary standards. We should not dictate our
body’s pursuit of serving the public by limiting an individual’s pursuit of expertise.
CE
I would vote against this change as a large share of CFP [professional] registrants hold other designations and licenses
that require their own CE that is not accepted by the Board and via-versa. Our current requirements are more than
adequate.
CE Changes
Please include a rollover for excess credits to the following 2 year period.
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Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Samir K. Shah, CFP
Subject
®
Comments re: proposed
CE changes
Page 312 of 379
Comment
I would like to share my thoughts regarding the revised CE changes you are proposing. I do understand we are living in
a time where fraud and unethical practices seem to be a regular occurrence however, I do not believe additional
regulations or additional CE requirements will help mitigate the folks who commit this criminal actions.
®
In my situation, I have the CFP [certification] CE requirements, my broker dealer requirements and my FINRA
requirements. In aggregate these are many days of educational/information/compliance I am committed which is time I
am not spending doing market research, financial planning research, time getting to know the clients needs better etc...
In affect, this effects our relationship with your clients. Although clients like hearing we are maintaining our professional
status, this isn't the thing they want to hear.
There is a point where CE requirements (in addition to other requirements) can be overwhelming and possibly
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discouraging to many CFP practitioners and I hope the additional requirements you propose it not it.
I hope this has been useful and I will be happy to answer any question the board may have. Thank you for reading this.
®
Roxanne Witmer®
DeWitt, CFP , EA
Proposed CE Requirement
Changes
I want to comment and raise my objection to some of the proposed CFP [certification] CE requirements that are being
reviewed. I strongly object to increasing the CE requirements from 30 to 40 hours every two years. I would agree with
increasing the hours from 30 to 32 hours. I strongly object to the 50% rule, limiting the allowable CE credit for one topic
area or activity.
®
It will be very burdensome to CFP professionals who have practices focused on one or two areas of the financial
planning field to obtain 50% of their specialty and then have to find another 50% of ‘other’ financial planning CE topics.
Travel costs, seminar fees and time out of the office are a financial expense burden on the small, hourly, fee-only
financial planners such as myself. Expanding the CE requirements will cause practioners such as myself to be less able
to work with middle-income clients who need a financial planner but cannot afford the high-fees of large RIA firms or
fee-based advisors. I will have to raise my fees to maintain my revenue and this will cause even more middle-income
clients to be priced out of affordable financial planning services.
I do agree that going from 2 to 4 hours of required Ethics CE is a good idea.
Thank you for your consideration with regard to my comments.
David A. Hemler
Request for
Comment:Proposed
Revisions Cont. Ed
My thoughts are as follows: We already have a burden of responsibility that seems adequate as compared to similar
professionals and certainly our review board maintains a strict compliance system with regard to capture and validation
of any CE a practitioner receives. Given the intent to "keep pace..." I guess I would ask, "are we as a profession having
an inordinate amount of failure as evidenced by client complaints in regard to our professionals not doing a good job in
their areas of practice"? If yes, then I'm in favor of reacting to the individuals who are not keeping up with things and
doing a poor job as evidenced by any means and reportability mechanisms already in place. Increasing the required
hours is not overly burdensome, I agree. However in my humble opinion either a practitioner is dedicated to learning or
they aren't, either they are ethical or they are not. Requiring 4 hours of ethics versus 2 hours will not change this
component of a practitioners behavior. I believe we have enough education requirement to facilitate a good ongoing
educational updating. If anything I would like to see methods improved for obtaining CE without costing as much to the
practitioner. In my 14 years of practice as a financial professional I find that accountability from the CFP Board is of
highest quality. I also believe learning occurs more because of the participant's desire to learn then by way of
mandatory requirements. In my State you must have 24 hours of Continuing Ed to renew your insurance license, of
which half must be face to face from an approved instructor. I have found these "face to face" components to be
woefully inadequate to actual learning and more likely simply filling a requirement mandated by an individual or
insurance review board who perceives this learning to be "higher quality" than say online CE. Just my thoughts. Thank
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 313 of 379
Comment
you for your effort and hard work.
Nick Ignatowski, CFP
®
®
CRPS CFS
®
Proposed Revisions to CFP
Board's Continuing
Education Requirement
®
1) Automatically accept state approved insurance ethics CE for CFP [certification] ethics credit.
2) Grant board members of industry associations 10 hours of general CE earned for their service on the board.
®
I understand your desire to ensure everyone with a CFP [professional] designation stays current. I like the idea of a
CFP Board produced ethics program. Finding a reasonable ethics CE program is challenging. I would urge you to pre
approve any CE program that is accepted by the state insurance commissioner as an acceptable CE class to fulfill the
balance of the board CE requirement for ethics. My state, like most states, require 3 hours of insurance CE. I have been
®
unable to find an ethics program that is approved for both my CFP [certification] and my insurance requirement. This
would move the requirement to 5 hours of ethics CE, 2 from the board and 3 from a state approved program.
I am the current president of our local NAIFA chapter. We have about 400 members and I spend 8 hours a month on
industry related material for this role. You may want to consider a board position with an industry group an automatic 10
hours of CE. It does not matter if it is NAIFA, FPA, CFA, GAMA, FIFE, or any number of other associations. If we are
giving back to the industry and educating or providing programs that educate others in our industry a valid way of
meeting the boards goal of ongoing learning to maintain competency. I would assume as board members, you realize
the ongoing learning you experience as you prep for your board meeting or prepare programs for your membership.
Please give me a call if you would like to discuss my rationale. Thanks!
WILLIAM B. REEVE,
®
MBA, CFA, CFP
CE Credit changes
I have reviewed all of the proposed changes and the only issue I feel makes no sense whatsoever is eliminating CE
credit for completing professional licenses and designation exams. It was rather nice obtaining CE credit for my CFA
exams, as well as my current endeavor which is completing the EA exams. I just don’t see how obtaining professional
licenses and designations is “inconsistent with professional program best practices”. In my opinion, expanding one’s
professional licenses and designations are the best and most significant way to obtain continuing education.
Cheryl Kurkowski, CPA,
CFP, LLC
CE Change Comments
The CFP Board needs to consider this problem when I implementing any future changes in annual CE requirements.
Increasing the amount from 15 to 20 will cause additional expenses for those who need to use the same sessions for
different CE requirements. Please make the reporting process easy for all involved.
Timothy J. Garrett
Not in favor of increasing
CE requirements to 40
hours
I am not in favor of increasing the hours of CE given the dramatic increase of the hours of mandates and CE required by
FINRA that I now have to complete.
Mark W. Thorndyke,
®
®
CFP CIMA
Changing the CE
Requirements
I strongly oppose your proposal to change the CE requirements.
®
In today’s world we spend more and more time on continuing education requirements besides the CFP [certification]
requirements. This only takes away from the time we should be spending looking after our client’s financial futures. To
add more hours and complicate the process with a 50% rule would only add to the problem…
Please feel free to call me if you would like to further discuss.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Mark Tepper, CFP
Subject
®
CE Requirements
Page 314 of 379
Comment
I agree that in order to remain proficient at financial planning, it requires much more time than 30 hours every 2 years.
However, I spend a lot of time keeping abreast of economic and investment strategy changes that in the past would
have been awarded no credit.
As an example, I read BCA Research reports every week. These research reports help us to make sure that our
portfolios are properly positioned for our clients. The weekly reports take an hour or 2 to read. The monthly
comprehensive report takes 3-5 hours to read. There are also quarterly reports that take 3-5 hours to read. I want to
make sure I'm able to receive credit for that time.
Also, my entire team has engaged with a consulting firm that has taught us how to hold more meaningful discovery
meetings with prospective clients, drafting transparent investment plans for prospective clients, holding better review
meetings for current clients, etc. I will invest over 100 hours of my time this year in learning how to provide my clients
and prospective clients with a better experience. I should be awarded credit for that time as well.
I've read multiple books this year on exit planning for business owners, value investing, etc. and feel I should be
awarded credit for that time. I've recently signed on with a publisher to author a book. I'm sure my total investment in
that project will amount to hundreds of hours — but I wonder how much credit I'll get for that.
I'd like to take the CFA Level 1 exam next year. I'm no longer eligible to receive CE credits for that?
So, as you can see, I spend hundreds of hours a year continuing my education as I feel it is extremely important. I want
to be the best financial planner I can possibly be. I'm all for increasing the hours. I'd love to see the requirement be 100
hours every 2 years. However, I feel like a lot of the things that I do won't fit in your "box" for approved CE, yet it would
definitely be considered continuing education by any layperson's standards. I think that should be addressed. If
somebody has read a book on a topic and can submit a 1-page synopsis of the book, why shouldn't they be able to
receive 10 credit hours for their time?
You should increase the number of hours that are required — but also widen the parameters on what's approved. It's
not fair that I spend so much time furthering my career and bettering the lives of my clients without being held to any
requirement; yet I have to take a "Basics of Life Insurance" class at the end of the year to meet my CE requirements.
That seems backwards to me.
Thanks for your time.
Robert Lagonegro, CFP
Proposed CE requirements
from 30 to 40 hours
To whom it may concern, thank you for the opportunity to comment on this proposal. Currently my daily reading of
financial topics and regular research is already significant. I don’t believe increasing the CE hours from 30 to 40 hours
will improve anything, particularly for individuals already striving for excellence in this field of work. Thank you.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Page 315 of 379
Comment
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Ken McQuirter, CFP ,
®
ChFC , FIC
CE changes
I would definitely oppose any increase to the CE requirements for the CFP [certification]. Currently, one American
College course takes 40 to 50 hours of study to earn 10 CE units for the CFP. Four courses require over a month of
study! I know there are other options for CE but this is an example of the time requirements. In addition there are
FINRA requirements, firm element requirements, state insurance requirements, and company specific requirements. I
realize that some of the CE can apply to more than one requirement but many don’t. I have commented numerous
times to coworkers and friends that I am spending more and more time taking courses and less time actually helping
clients. I am aware that continuing education is important but there is a limit. It seems that our society has decided that
when there is a problem, that it can be fixed by further training. It isn’t! Regarding ethics training – no matter how much
CE is required there are going to be some that don’t play by the rules. Why should those of us who do have to suffer
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with more ethics training. Again, in addition to CFP [certification] requirements there is required company specific
ethics training and if you broker with numerous companies they each have their own ethics training requirements.
Enough is enough. Having said all of this, in addition I do spend time reading trade magazines and attending
professional gatherings. On top of all these reasons there is the financial one. I encourage the board to vote no on any
increase in CE requirements. If anything I would advocate a decrease in requirements.
Eileen J. Trott, CFP
Continuing Education
changes
Thank you for your continued efforts to keep the CFP [professional] designation a current and relevant designation!
Below are a few random thoughts after reading your announcement of the proposed changes:
®
1. I thoroughly welcome the addition of Practice Management CE courses. I believe that they are long over-due. We
cannot provide the services that are clients need if we cannot run our practices efficiently.
®
2. It is my opinion that too many of the other designations were pursued because they would qualify for CFP
[certification] credit.
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3. If regionally accredited colleges & universities are qualified to teach for the CFP [professional] designation, then they
should be the provider of choice for continuing education courses. This should assist the faculty in staying up to date on
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the current knowledge needed to be a practicing CFP [professional].
4. I do not understand the necessity of TWO ethics courses. One or the other should fill the need; otherwise one of the
two is not meeting the standards and is simply being maintained to appease certain parties.
®
Jana M Plaisier CFP
CE Comments
I am opposed to increasing the continuing education requirement for maintenance of my designation. I am like many
®
CFP professionals and am also licensed in securities and insurance as well as anticipating RTRP designation wiht the
IRS within the year. Each of these licensing entities require continuing education as well as ethics courses. In addition,
I hold a Series 24 supervisory license. It is increasingly difficult to find the time to meet the licensing requirement for
these various licenses and the added cost to my practice is prohibitive. I am spending an inordinate amount of time
meeting the requirements and in addition, view many webinars, attend seminars, etc. to stay up to date on changes. In
the area of ethics, I am overloaded with the requirements - and in my opinion, ethical practices are not necessarily
learned through these courses. Either we operate in an ethical manner or we don't. If there is a requirement to increase
these hours, then I would like to have more crossover between the licensing entities so that one course can cover both
or several licensing entity requirements.
®
As an alternative, CFP practitioners with multiple licenses could be subject to the current education requirements while
those without other licenses or registrations could be subject to the higher requirement.
Kevin C. Rakers
proposed changes to CE
credit
Please note that I am opposed to increasing the CE credit requirement from 30 hours to 40 hours. Thank you.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Stephen R. Hample,
CFP
Subject
Proposed CE changes
Page 316 of 379
Comment
Increasing from 30 to 40 hours: Opposed. Many of the various courses are not particularly worthwhile and 95% of
them cannot compare to the quality of the estate planning group in which I have participated with senior CPAs,
Attorneys, Trust officers, Insurance agents and other financial planners / brokers / investment advisors. When the CFP
Board quit allowing self reported participation in that group and turned largely in the direction of standardized quizzes,
that seemed to me to be a wrong turn.
Allowing credit for certain professional activities and services: Undecided. The problem would be in the mechanics of
reporting. Our estate planning group is not going to pay a fee to register its monthly programs or have anyone report
attendance. Pro bono activities are good and almost all my professional colleagues in this and related professions are
involved in service organizations (five of the approximately 15 people in the estate planning group have been president
of the local rotary club and two of those also served as treasurer, etc…. In addition, I and others have met with nonprofit boards to explain charitable giving techniques. The concept of recognizing pro bono work is great. How to do it in
a no cost / non burdensome manner seems a likely problem. Suggestion: Keep the current 30 hour requirement as is
and encourage / require self reported hours for such professional and pro bono activities.
Increasing Ethics requirements: In favor, with a caveat. “Can ethics be taught?” is something I’ve pondered in relation
to teaching college level courses. My answer would be this: “No, ethics are basically learned by age six. We are
fooling ourselves if we think we are teaching ethics to adults. Crooks would cheat on ethics exams. However, what we
can do is to help alert the vast majority who are ethical to gray areas that could later turn from seemingly harmless
situations into bad conditions. I.e., a subtle distinction of don’t teach ethics; instead assist good people in their own
seeking of acting in ethical ways.” A good example was an NASD/FINRA video series for investment advisors on ways
that a sophisticated crook might ask for small favors leading to money laundering; a problem was that meeting that
requirement meant in my case driving at least 100 miles to the nearest PLATO or similar continuing ed center. State
securities commissioners have used settlement funds to create videos warning consumers about investment scams
such as Ponzi schemes, but although most Ponzi promotions probably did not intentionally start out as such, I’m not
aware of any similar videos about how good advisors / planners went bad.
The goal of encouraging ethics is great and new technology should allow great advances. Good luck.
Larry Hansen CPA,
CFP
NEW REQUIREMENTS
®
I don't know how may CFP [professionals] have other professions that they make a living at, but I am a CPA in addition
®
to being a CFP [professional]. I don't handle investments, and do very little financial planning each year. If you are
going to increase the CE hours to 40, please accept the CE from other professions. Our state insurance board accepts
all CFP CE. Or have less hours for those who use the CFP mark, but don't do any formal plans. A CPA that works for a
company and does not practice public accounting can still have the CPA mark after his name, but doesn't have to have
all the CE.
I don't see the need to increase ethics to 4 hours. You are either honest or you are not. Two more hours isn't going to
change that for the majority of people.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
William T. Ward, Jr.,
CFB Board - CE
Requirements
Page 317 of 379
Comment
In my view, the Board should focus more on the quality of continuing education than on increasing the number of hours
required. Though there is some valuable CE available, in my experience, many of the approved courses are very basic
®
review courses of core topics. In fact, it would have been impossible to pass the CFP exam without having already
mastered this material. While such courses allow the certificant to check the box on their CE requirement, nothing new
or valuable is learned.
Additionally, the CE Requirement Proposal states that “The proposed increase in required hours remains consistent with
or below similar requirements for established professions with comparable designations. “ Elsewhere in the Proposal,
the fields of law and architecture are specifically mentioned as fields from which CE advice was sought. In the State of
California, where I live, attorneys are required to complete 25 hours of CE every 3 years. Also in the State of California,
®
architects are required to complete 5 hours of CE every 2 years. In California, the existing CE requirement for CFP
[professionals] is already far greater than for lawyers or architects. If you are truly interested in furthering the profession,
I believe that ensuring that continuing education is time well spent will be a much more effective approach than simply
increasing the time requirement on already busy professionals.
Paula Rogala CFP
®
CE credits
Let me preface this by saying I believe it is important to keep learning and growing in this business.
I have read the proposed changes to CE requirements and I believe that it is excessive to raise the credits needed to 40.
As a Certified Financial Planner, I also carry a life, health and annuity license, which I imagine most advisors hold. The
requirement to keep that license is 18 CE every two years. There is also a firm element required by most brokerages as
well as Series 7 computer test every two years as well. I cannot believe that all of these different requirements do not
add up to enough continuing ongoing receipt of knowledge. I hope you will rethink this increase.
®
Teresa L. Denner, CFM,
®
®
CRPC , CFP
CE's
I am finding it increasing difficult to keep up with all the CE’s for CFP [certification], CPA, CRPC. I am just happy my
MBA does not require any CE’s. I know that CE’s are a money making business, but as a consumer I am on the other
side of the deal. My vote is to keep the requirements as is.
Robert Oliver
CE Changes
I reviewed the proposed changes to the CFP [certification] CE requirements. I'm fine with them all except the additional
ethics requirement. I feel that the two hours currently required are sufficient. While I agree that our profession needs to
promote ethics and show dedication to it through a CE requirement, I don't think additional time is going to make anyone
more or less ethical. In addition, the two hour requirement is in-line with NAPFA's ethics requirement.
Ryan Lloyd
Eliminating CE credit for
completing professional
licenses and designation
CEU.com is an online CE provider for insurance licensees and has a number of courses approved by the Board to meet
®
the general CFP [certification] CE requirements. The CEU courses are completed by licensed agents/adjuster to renew
their licenses. I want to verify that the below proposed rule will not eliminate CEU being able to support the CE
®
requirements for our customers that are also CFP [professionals].
®
Eliminating CE credit for completing professional licenses and designation examinations.
Rationale: Inconsistent with professional certification program best practices. Program content or coursework may be
eligible if consistent with CE topic and other
requirements. Exam prep or review courses remain ineligible.
You response is greatly appreciated.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Norbert N. Oses, CFP,
ChFC
Joe B. Stallings, Jr.,
®
CFP
Subject
®
Page 318 of 379
Comment
(none)
I guess I must be getting old. I have been a member ofthe F.P.A since it was the International Association for Financial
Planning in 1985. I have seen the association grow to what it is today, thanks to the due diligence of its members and
the service they provide to the public.
Some has grown into large firms and provide services that I do not, nor do I wish to provide, such as buying and selling
®
stocks or doing their income taxes. Today some CFP certificants are J.D's and CPA's.
But when I see that "Government Regulations" increase for the small firms like mine (because of investment fraud) and
now the F.P.A would like to increase also their regulations for me to keep the title of CERTIFIED FINANCIAL
PLANNER™ [professional], after more than 25 years I must say hold on.
Let us review:
1.- No; to increasing from 30 to 40 the CE hours needed to maintain the certification, at least to us that have been 15 to
20 years or more in this business.
2.- When it comes to ethics, you either have it or you do not, you are either honest or dishonest, increasing the hours will
not help. Mr. Madoff and many others like him "passed" their ethics courses.
3.- I do agree in granting credits for pro bono or practice management.
4.- I do have concerns for expansion ofprofessional activities, but, it is not a major issue.
5.- Implementing the 50% cap rule, yes, go for it!
6.- I do not quite understand the rationale of negating or eliminating the C.B. credits of other similar professional
licensing & designations. Are the 12 hours per year of a lawyer not to be counted or the 40 hours per year of a CPA?
We are starting to do more and more time doing upkeep, maintenance and practice management due to new and
increased regulations than helping people. On the last two reviewing and increase rigor and quality I also have no
problems with.
(none)
I wish to comment on the proposed CE requirement revisions. I oppose three of the revisions under consideration. The
proposed revisions and my objections follow:
First, I oppose increasing the nunnber of required CE hours to 40. The rationale that 40 hours is consistent or still below
the hours required of other professions or designations is irrelevant. We should be tnaking changes based on what is
practical, or what makes sense, not based on what other organizations are doing. Some items in the planning world are
fast-changing, but I find that 30 hours are sufficient. If the profession were going to suffer a significant degradation of
quality if the hours were not raised, I would be in favor of it; that clearly is not the case.
Second, I oppose increasing the required ethics hours to four. I do not see any purpose here. The more ethics hours you
require nnennbers to take, the more it reflects that the profession has an ethics problenn. Certainly everything that would
be covered in four hours can be covered in two.
Third, I oppose the 50% cap rule. It is certainly possible for an individual, for a
variety of legitimate reasons, to need to spend time brushing up in one area rather than others.
The CFP Board needs to be realistic, practical, and exercise common sense. If an institution or organization creates
nnore rules and less flexible rules, then the rules becomee of less value and only serve to perpetuate their own
existence, at the expense of the overall purpose they are meant to serve.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Page 319 of 379
Subject
Comment
Proposed Revisions to CFP
Board's Continuing
Education Requirement
I am a new CFP [professional] after having completed the March 2012 exam. I strongly disagree with the increase in
the number of CE hours from 30 to 40. I just studied 700 hours for this exam so I feel that I have put in enough book
time and now I need to focus on my practice! While I understand that this is a fast changing area; we are practicing and
learning every day by doing our jobs and I do not see the added value from 10 additional hours of course study. I am
concerned that the underlying reason for the proposed increase has to do with increasing the amount of $’s generated
from CE courses sold. I am ok with the other proposed changes but I think a more detailed explanation is in order rather
than just being faced paced and consistency with other designations. Thank you for considering my comments.
Christopher Heaven,
®
CFP
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Do not increase the Continuing Education Requirement. It would be meaningless to the population we serve and would
take away the time we have to devote to our clients.
John Podleski
Comments
I do not agree with the 50/50 rule and believe other ethics courses should qualify towards the CFP [certification] ethics
requirement**. I am also a CPA that has to meet NY State CE plus I am also an insurance professional that has to meet
CE for my NY and other state licenses. In addition, I have to meet FINRA and other Financial Industry CE training
through our brioker dealer.
Kevin W. Calvert, CFP
®
®
®
®
(**Example the course Ethics&Professional Conduct NYS CPA- by CPA Foundation does not qualify for CFP
[certification] ethics requirement. )
NYS Professional Education/Licensing Department for CPAs is very strict with providers and as such many companies
®
will provide CE for my CFP [certification] but not for NY CPA license- reason NYS reporting and fees make it too
cumbersome and costly.
®
In addition the insurance courses may or may not qualify for CFP [certification] and/or CPA.
®
My FINRA and other Financial Industry CE training do not appear to qualify for CFP [certification] credits. I do mostly
self-study courses. When I find a provider, such As Professional Education Services, that has some courses that
®
®
qualify for CPA and CFP [certification], the credited hours for the CFP [certification] are 50% of credits for CPA.
So restricting my courses to meet a 50/50 rule will become even more combursome. It could end up requiring me to
have 120 CE hours per year to meet my three licenses/certifications.
In conclusion there should be more flexability for CE in the case of multiple accreditations.
David L. Greger, CFP
®
Comment submission
I have read of the Certified Financial Planner Board of Standards proposal to revise the present CE requirements
®
necessary to renew the CFP [professional] designation from 36 hours to 40 hours.
I would ask you and the committee to consider that online CE courses and CE self-study courses require well more
hours to complete than the number of hours credited. That is my experience with the Kaplan CE curriculum. Although
CE hours are derived from a number of sources such as conferences and online lectures, we inevitably need to fulfill
our CE obligation with some self-study or on-line course work. This kind of study typically provides the necessary hours
®
of credit but only after significantly more hours of study and examination time. Effectively, many, if not most, CFP
practitioners are already spending upwards of 40 hours to achieve the 36 hour requirement.
I hope your deliberations will consider this reality which we face in fulfilling our CE requirements
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Gregory F. Marshall,
®
CFP
Comments regarding
proposed CE requirement
changes
Page 320 of 379
Comment
I have comments regarding two aspects of the proposed Continuing Education (CE) requirement changes:
(1) Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming. I disagree with the proposal to raise the renewal-period
®
ethics requirements to 4 hours from 2 hours and including a CFP-Board produced ethics course. If the ethics of a CFP
practitioner hinge on receiving 2 hours--or 4 hours--of ethics training in a 24-month period, there is already a problem.
Thus needing any CE training in ethics is questionable, but if there is to be an ethics CE requirement, leave it at 2 hours
and have it be the satisfactory completion of a CFP-Board produced ethics course, so that all practitioners receive the
same ethics training. That makes more sense to me.
(2) Eliminating CE credit for completing professional licenses and designation examinations. Not accepting such
completions unless they meet additional requirements is okay, but if the examination coursework is consistent with CE
topic and other requirements, the completion should definitely still be acceptable for CE credit.
®
Paul Benesch, CFP
®
Thomas Burk, CFP ,
CFA
CE
Hi with respect to increasing the CE, I think you need to just stop. More is not by nature better. Finra, Company,
State(s) and other designations each require separate CE. Much cannot be counted "twice". You need to stop this!!!! I
do actually have to have time to run my practice and take care of my clients and family. I have an Idea, stop wasting
®
time on how to make it harder to keep the CFP [marks] and go out and see what it is really like to make a living as one.
Perhaps less of our huge fees would be wasted on people who could never make it in the real world, but just suck us for
more more and still more!!! Just Stop It!!!
Comment on the proposed
revisions to CE
requirements
Some of us have other designations and professional requirements that recommend or require continuing education. In
®
addition to the 30 hours every two years for CFP [certification], Colorado requires 24 hours every two years for my
insurance license, and the IRS now requires 15 every year as a tax preparer. CFA only recommends (not currently
required) 20 hours per year. Ten additional hours of CE isn’t going to make me a better planner. What makes me a
better planner is my desire to be better. Don’t change the requirements.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 321 of 379
Comment
Jeff Farrar
feedback on changes
1) Increasing total CE hours required each renewal period (every 2 years) from 30 to 40 hours. What is everyone on the
board a Democrat who thinks more regulation is the answer!? only 42% kidding. What is the problem you are trying to
solve? This just increases costs and time spent by practioniers. If I need to learn more about a topic I'm going to do it
regardless of CPE requirements or how much time it takes. In another suggested change you talk about increasing the
QUALITY of the time spent which is great, but here you are only talking about QUANTITY--time spent. As w. Edwards
Deming said "the most important things cant be measured." Nix this one.
2) Granting CE credit for practice management programs and/or pro bono activities, up to 4 hours (total combined) per
renewal period. fine good idea.
3) Increasing the Ethics CE requirement from 2 hours to 4 hours, which shall include a mandatory CFP Board-produced
Ethics program (2 hours) plus 2 hours of ethics programming, which is expanded to include both pre-approved programs
on CFP Board’s Standards of Professional Conduct and general ethics-related content. Show me the problem with the
®
®
CFP [professional] force and I'll consider this. Otherwise I'd suggest that the CFP [professional] subset of all advisors
is more ethical so I'm not sure what this does? Nixed also.
4) Expanding the professional activities that qualify for CE credit (currently accepted professional activities are teaching
and authorship) with the following: fine the more choices the better.
5) Implementing a “50% cap rule,” which will limit CE credit for any single topic area or professional activity to 50% of
total required CE hours. Are you solving a problem that doesn't exist here? what do you gain for the added complexity?
What if a certificant specializes in one area and wants to get better in that area? Does an orthopedic surgeon worry
about the latest in the cardiac field? No. when they encounter something outside their area of chosen expertise they
refer to another professional as the code requires. This seems an unnecessary.
6) Eliminating CE credit for completing professional licenses and designation
examinations. This seems ill-advised and more parochial in nature. NIH. If a certificant expends significant time on a
high quality program why should it not count?
7) Reviewing online courses for academic credit (with grading) delivered by
regionally accredited colleges or universities as “live” CE programs, rather than “self study.” Fine
8) Encouraging increased rigor and quality of all CE program delivery methods. This seems to fall under the "World
Peace" type of a wish. Who could be against quality programs but what are you doing here?
Donald D. Duncan
®
MBA CPA CFA™ CFP
Proposed Revisions to CFP
Board's Continuing
Education Requirement
Eliminating CE credit for completing professional licenses and designation
examinations.
If someone is taking courses for a professional designation (i.e. CIMA), will there be a process whereby that person can
apply to the CFP Board for CE credit?
Scott C. Cashman
®
Donald Calcagni, CFP ,
MST, ERPA
®
Fee Increase
The fee increase to maintain the CFP [professional] credential is outrageous.
CE Requirements
I strongly support the CFP [professional] designation and the CFP [certification] program. I am proud of my fiduciary
role. However, I personally think the CE requirements are suitable as they stand now. I personally object to increasing
the CE requirements and I am not in support of what is proposed. The CFP Board is increasingly becoming nothing
more than an inconvenience for those of overworked advisors servicing our already time starved clients. The last thing
our profession needs it yet another regulatory body creating yet even more hurdles for advisors to deal with. I
emphatically vote “NO”.
®
®
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Keith Maier
Subject
Proposed Changes to CE
Requirements
Page 322 of 379
Comment
I strongly disagree with the proposed CE changes and believe that they should remain the same.
I still strongly disagree with the increased fee for the CFP [Board] marketing campaign. I believe that it has been a
complete failure and a total waste of our additional investment.
Please feel free to contact me if you wish to discuss either of these items further.
Kenneth Clamurro
Your Input Requested: CFP
Board Proposes Changes
to Appeal Rules,
Disciplinary Rules, CE
Requirement
I've reviewed the proposed changes contained herein and generally they look very acceptable to me.
I see no reason to increase the number of required hours of CE from 30 to 40. However, the quality of the hours
required should be reviewed. I believe that 30 hours is enough as long as every course qualifying for CE is reviewed in
depth by the CFP Board for quality of content, and relevancy. In other words, no "basket weaving" courses or credit
hours. Required hours for Ethics training and review might be increased, but 30 to 34 seems to be plenty for purposes
of maintaining competence.
Personally, in my own planning activities, I make extensive use of available resources to insure that all information I
convey is up to date, accurate, and relevant to the situation. Just producing a high quality plan requires moderate to
extensive research and by its very nature, helps me stay up to date with changes, in regulations, tax issues, investment
issues, etc. etc. However, there is no CE credit for doing that, nor should there be. But I believe it supports my own
case for retaining the 30 (or even 35) hour bi-annual requirement.
Cindi Turoski,
®
CPA/PFS, CFP
Comment Re: Proposed
changes to CE
I do not believe that Practice Management should be an allowable topic area for CE. All professions grapple with
practice management issues, but that subject area is not usually accepted for continuing education that I know of (i.e.
CPA CPE). The continuing ed is to keep us sharp and educated on the financial planning issues so we can better advise
our clients and for the benefit of the client.
The purpose is to “maintain and enhance competency in financial planning principles and practices” as stated by the
CFP Board.
®
Theoretically, if a CFP professional were independently wealthy and chose to advise people on financial planning
issues solely pro bono, there would be no practice management issues, but he/she should still maintain and enhance
his/her competency for the benefit of the individuals he/she advises. That’s what CE is for.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
®
Steve Odegaard, CFP ,
®
®
ChFC , CLU
CFP CE Comments
Page 323 of 379
Comment
I have the following comments about the proposed new CE rules:
®
1. In addition to the CFP [professional] designation, I hold an insurance license and CLU and ChFC designations.
Insurance CE requirements are 36 hrs. every 3 years. CLU/ChFC requirements are 30 hrs. every 2 years. None of the
CE time periods are the same, and not all CE credits count toward more than one requirement, so it is a real juggling act
®
to fulfill all the requirements. I suspect most CFP certificants hold at least one additional license and/or designation that
requires CE and are probably getting in excess of 20 CE per year already.
2. I am a board member of the Financial Planning Association (FPA) of Eastern Iowa. We had an awful time getting our
Ethics course approved by the CFP Board. We made numerous submissions with very little feedback on what was
wrong with our course. Our impression was the approval process was arbitrary, capricious and not designed for the
benefit of the members. We cancelled and rescheduled a couple FPA membership meetings because this
review/approval process was so unreasonable. You will have to substantially improve your CE review/approval process,
especially if you increase the number of required CE’s.
3. To execute on my business model, I need to have an IAR and an insurance license. I am proud of my designations,
®
but maintaining CFP [certification], CLU and ChFC are optional to my business model. As costs and requirements
increase, I have given up one membership in a professional organization. You have already substantially increased the
cost of maintaining a CFP designation. If you now increase the CE requirements and make them more complex (adding
the 50% rule) and more difficult to get, I am sure you will lose some good people who just decide the extra hassle and
expense are not worth it.
4. I am a big proponent of lifetime learning, but I believe you have to be careful and thoughtful about implementing
additional requirements.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Amy Panici, CPA/CFP
Subject
®
Please don't implement
50% cap rule for CE to a
single topic
Page 324 of 379
Comment
I would like provide comment on the following proposed CE change:
Implementing a “50% cap rule,” which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours.
®
I believe that most CFP [professional] have one or two areas they excel at and are passionate about. The areas in
®
which a CFP [professional] does not excel are usually the areas where we network with those professionals who do
excel in that area. For example, I am great at taxes, investments, and estate planning but I am not good at insurance.
When I need to use insurance products or evaluate insurance, I use my network of professionals to assist me. No
®
additional amount of CPE in the insurance area is going to make me a better CFP [professional] because it's just not
what I do well.
®
Implementing a 50% cap rule in a single topic area could have a negative impact in that the CFP [professional] is no
longer really good at one or two things and now are just mediocre at several. My clients understand that I do not have
all the answers in all areas and are happy that I can introduce and partner with other professionals who can provide
them better service in the areas I don't excel at.
Another consideration is that topic changes often dictate where we get our CE. For example, new tax laws generally
require many hours of CE to be able to understand the impact on our clients and so it may just happen that I would
spend more than 50% of my CE learning about new tax laws. This is true as new retirement ideas are created or
investment and/or insurance products are introduced. We know that estate planning could change dramatically in 2013
®
and many CFP [professionals] may desire to have more than20 hours of CE in this area due to changes.
®
Please don't limit CPE in one area because you think we will be better CFP [professionals] by forcing us to be educated
in areas we have no desire to be less than excellent at. As you are proposing an additional 10 hours of CPE
(increasing from 30 - 40 hours), maybe you could revise the 50% cap rule to: no more than 30 hours in any single topic
area - thereby requiring the additional 10 hours to be in other areas.
Thank you for considering my comments and proposal. I am happy to discuss this further should you have questions.
Deborah J. Fritsche, JD,
CFP(R)
input
Why not have a carry-over provision rather than a cap for "excess" hours? And why not have a carry-over provision for
the total hours? Texas CLE has such a provision. Also, I have been frustrated with the lack of "dual" credit for estate
planning topics. There should be credit for both CE and CLE, particularly for this area. Practice management and
development (compliance and ethics issue are probably best addressed in this context) should get credit but just limit
the amount.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Erica J. Feldick, CFP
Subject
®
CFP Proposed CE
Requirements
Page 325 of 379
Comment
®
The following are comments regarding proposed changes to CFP [certification] CE requirements:
®
1. In addition to the CFP [professional] designation, I hold an insurance license and Series 7 and 66 licenses.
Insurance CE requirements are 36 hrs. every 3 years and I have additional annual/bi-annual requirements to meet for
the Series 7 and 66 licenses. None of the CE time periods are the same, and not all CE credits count toward more than
®
one requirement, so it is a real juggling act to fulfill all the requirements. I suspect most CFP certificants hold at least
one additional license and/or designation that requires CE and are probably getting in excess of 20 CE per year already.
2. I am a board member of the Financial Planning Association (FPA) of Eastern Iowa. We had an awful time getting our
Ethics course approved by the CFP Board. We made numerous submissions with very little feedback on what was
wrong with our course. Our impression was the approval process was arbitrary, capricious and not designed for the
benefit of the members. We cancelled and rescheduled a couple FPA membership meetings because this
review/approval process was so unreasonable. It was very disappointing. You will have to substantially improve your
CE review/approval process, especially if you increase the number of required CE’s.
3. To execute on my business model, I need to have Series 7 and 66 licenses and an insurance license. I am proud of
®
my designations, but maintaining the CFP [professional] designation is optional to my business model. As costs and
requirements increase, I may need to give up a membership in a professional organization. I am a young planner (31
years old) and simply don’t generate the commissions yet to accommodate much more of an increase in cost. You have
®
already substantially increased the cost of maintaining a CFP [professional] designation. If you now increase the CE
requirements and make them more complex (adding the 50% rule) and more difficult to get, I am sure you will lose some
good people who just decide the extra hassle and expense are not worth it.
4. I am a big proponent of lifetime learning, but I believe you have to be careful and thoughtful about implementing
additional requirements.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Mark R Engblom, CFP
Subject
Continuing education
requirements and other
issues
Page 326 of 379
Comment
®
I have been a CFP [professional] since 1987 and this is my first email correspondence to you (other than maintaining
my certification) about your proposals.
I have a mature practice and still take referrals on a select basis but no longer do any mass marketing or seminars.
Your public awareness campaign is underwhelming. I have seen two ads since the campaign started and I do not see
the a pickup of awareness in the general public or even a mention from my clients. I do not feel this is a most efficient
use of resources (our annual fees to you).
As a result, I find it very hard to justify why you almost doubled our fees, now paying $325 per year as a result.
With the regulatory environment being more complex, burdensome, and cumbersome, I do not need organizations
where I hold professional affiliations (which are optional for my practice) to pile on with more requirements in continuing
education. I am spending over 50 hours a year in classroom, online, or meetings that are required by Finra, my broker /
dealer, and various vendors / industries. I strongly insist you keep the current requirement at 30 hours every two years
(which includes the 2 hours ethics course).
I do not have a problem with changes in the appeals process or having no more than half your credits in one subject
matter (continuing education).
I feel that lobbying to congress/regulators on OUR (independent representatives who have a CPF designation) behalf is
very important (I am a member of FSI) and I am told you do so also on our behalf. You should focus much more on this
than the public awareness campaign).
I do not have a need for more brochures / tool kits / or online store.
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I have not received one referral through your search tools or organization in the 25 years I have held my CFP
[certification].
Therefore, you should be able to see a reason for my debating the proposed increased continuing education
requirements, increased fees, and continued association with your organization.
In summary, 1) do not increase the continuing education hour requirement; 2) focus more on lobbying
congress/regulators on our behalf rather than the public awareness campaign; and 3) lower fees to senior members who
do not need all your services.
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Sorry this is not an inspiring correspondence but I feel I must vent and I am not the only CFP [professional] that feels
this way.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Brian T. Jones, CFP
Subject
Proposed revision to CFP
Board's CE Requirement
Page 327 of 379
Comment
The proposed change in CE from 30 hours to 40 hours is yet another sad example in the regulatory environment that
MORE “best practices” are clearly better. Rather than refining the standards and principles, we’ll just increase the
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overall amount of compliance (by 33%) in an effort to make a CFP certificant more ethical. This will not make CFP
certificants more ethical or competent.
Studying longer does not necessarily equate to better grades. The course material itself is what matters more and if it is
flawed in some manner than it does not matter how much studying the student performs….the end result will always be
less than “ideal”. Make the 30 hours of material more intense, more focused, more whatever but increasing the amount
of hours required is not going to make a bad financial planner (yes they do exist, head to your local FPA chapter for
proof) a good financial planner.
This proposed revision is a mistake, a complete waste of time, and ill thought out and if it goes through it is just another
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example of why I probably don’t want to keep my CFP [certification] license in the future (PS->I’m 39 this year and have
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had my CFP [certification] license since 2000). I’ll just pay someone else on my staff to do the financial planning work
and I’ll stay out of it if these are the types of asinine on-going requirements that I can expect to be levied against me in
the future with no clear “benefit” to the public.
JOHN J. SCHOFF,
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CFP
Comments regarding the
proposed CFP CE
requirements
I just have a few comment that I would like to make:
• Please recognize/allow credit for Firm, FINRA CE requirements that Series 7,9,10,24 holders have to complete on a
regular basis. A good example is the ethics portion. There is a lot of duplication among the various regulatory bodies
including state insurance licensing requirements. It sure would save some time as well as costs.
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• Also take into consideration time requirements for meeting the new standards. CFP [certification] CE’s are only a
portion of the actual industry CE requirements for the average practitioner.
Just a personal foot note: You can’t legislate integrity. Unfortunately there will always be a few bad apples in any
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industry. I am proud to wear the CFP [professional] designation so please continue to keep the standard high.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Denise Wasilewski
Subject
CEP Feedback Request on
Proposed Changes
Page 328 of 379
Comment
Hello, just wanted to provide a bit of informal feedback, as requested on proposed changes. While I agree with most of
the enhancements, I would like to comment on the proposal below:
Implementing a “50% cap rule,” which will limit CE credit for any single topic area or professional activity to 50% of total
required CE hours. For example, if 40 hours required, then “cap” would be 20 hours. Topic areas are: General
Principles, Insurance, Investments, Income Tax, Retirement and Estate Planning, Interpersonal Communication,
Professional Conduct and Fiduciary Responsibility. Conferences, which are comprised of individual educational
sessions, will not be subject to the “50% cap rule.”
Rationale: Ensure diversity of learning experiences across breadth of planning topics.
Particularly given CFP [Board] is planning to raise requirements from 30 to 40 hours annually, I don't believe putting a
50% cap on a single topical area supports an efficient & effective use of members' educational time. Requiring
members to potentially attend up to 20 hours (which is 2/3 the current total annual hour requirement!) on courses that
may have no direct or indirect impact on their industry or area of business seems wasteful & an attempt to bolster
attendance numbers across less popular topic areas. Perhaps consider switching this cap to say a 75% or 80% cap
rate. (That would still be 8-10 hrs or (20-25%) of "alternative" topics to meet your stated rationale.)
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I would also argue that most materials I've seen advertising being CFP [certification] CE credit eligible don't indicate
what category the credit applies in prior to registration/attendance, which would make it very hard for members to know
whether or not what they are attending will even fulfill what is, in essence, a 50% 'outside-of-cap' rule requirements.
William E. Fox, CFP
CE Requirements
I don’t believe increasing the number of hours to 40 is the appropriate change. An increase in the quality of the CE
requirements would have a greater impact than just the number of hours. Hours can be obtained in many ways today,
some meeting the spirit of the requirement and others meeting the definition but providing little education. I hope you
can reconsider the hours requirement and focus on quality rather than quantity.
Andrea Wilkinson
Your Input Requested: CFP
Board Proposes Changes
to Appeal Rules, Discipl...
If the Ethics CE hours requirement is increased, then accept CPA ethics courses for the additional ethics hours not
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required to be CFP [certification] ethics.
Lynda J. Mahorter,
®
CFP
Proposed CEU changes
Unfortunately, proposals like this only fuel the feelings of a growing number of advisors that this is a ploy to increase
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revenues for CEU providers vs. increase the knowledge base of CFP [professionals]. If the Board is truly concerned
about advisors staying current, it would mandate an annual CEU requirement. Additionally, the ethics course content
has been poor since I received my certificate in 1992. More of the same is a waste of time. Perhaps the Board should
focus on developing quality 2 hour ethic courses. Not granting credit for completing licensing exams is ridiculous. If
someone passes a CFA exam, I would suggest that they have greatly increased their knowledge of investments and the
investment selection process. Perhaps, this is just professional jealousy?
As for ethics, perhaps the Board should look at how it and the FPA dealt with advisors and Katrina survivors after
Hurricane Katrina. It seems that help is only sincerely offered to victims who expect to receive large windfalls from
disasters like 9/11.
Comments on Proposed Revisions to CFP Board’s Continuing Education Requirement
Name
Subject
Page 329 of 379
Comment
Tom Schneberger
Comment on Ne CE
requirements
I agree with the changes that are proposed. I especially like the increase in the number of hours required. Most
professions require even more that those proposed. I would also like to see more cooperation with other licensing
boards so that the CE that we do which qualifies for more than one certificate are more transparent. I am a CPA and
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CFP professional, the NJSCPA offers programs that are eligible for CE credit for both credentials. I would like to see
more of this.
Chris Dardaman, CPA,
®
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CFP , CIMA , CAIA
Proposed Changes on CFP
continuting education
policies
Thank you for the opportunity to share my thoughts on the proposed changes. Overall they seem to be reasonable and
well thought out with a few exceptions:
1. Most Ethics classes I have taken over the la