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FPSC Comments on proposed
CSA Rule and CFP®

FROM THE PRESIDENT...
CSA RULE OR NOT, CFP REMAINS THE CLEAREST DISTINCTION OF EXCELLENCE
       EXCERPTED FROM WINTER 2001 ISSUE OF CFP REPORT

To all CFP professionals:

The Ontario Securities Commission, on behalf of the CSA, has published on their web site the latest version of Multilateral Instrument 33-107.

As we were confident would be the case, it includes grandfathering provisions that effectively exempt all current CFP professionals from proving all over again that you are proficient in financial planning. Regardless of in which jurisdiction and to what extent this Instrument is implemented as rules and policies governing securities and life insurance registrants, you will not have to write the proposed CSA financial planning proficiency examination (FPPE) to hold yourself out as financial planners.

You will continue to be able to distinguish yourselves as financial planners who have voluntarily met the highest internationally recognized professional standards in financial planning in an environment that is soon to become more confusing than ever. Why? Because this Instrument will not be implemented uniformly nor unilaterally across all jurisdictions.

British Columbia, Manitoba and Alberta have different ideas about how the securities registrants should or should not be regulated, and the acceptance of the Instrument among insurance regulators across Canada (with the exception of in Ontario) remains uncertain.

This is probably because nothing of substance in the Instrument has changed from its draft version published in December 1999. And, therefore, few of the concerns expressed by so many organizations representing thousands of planners have been allayed.

Chief among our immediate concerns is that, in Ontario students entering many educational programs this fall that lead to the CFP and who will subsequently pass the CFP Exam and earn the CFP designation, are not exempt from having to write the FPPE under the grandfathering provisions of the current version of the Instrument. I believe this is an unacceptable treatment of individuals who are choosing to earn a distinction that sets them apart in Canada and around the world as professionals. Our voice will be heard.

I remain confident in the ability of all 13,000 of you to continue to represent the CFP with professional excellence, and not merely minimum proficiency. And I remain confident in the industry's continued recognition of the integrity of the CFP certification process. I know it is deserving of such recognition. For these reasons, and because we will continue our efforts to ensure all Canadians understand the difference between the CFP professional and a CSA licensed planner, I remain certain FPSC will continue to expand the profession with individuals such as you who have the proficiency and commitment to ethical behaviour Canadians expect of their financial planners.

Don Johnston, President

Our concerns about the Instrument remain that:

  • Grandfathering allows licensing of individuals who will not have written and passed the CFP nor the new FPPE exam, or earned the CFP designation.
  • the level of proficiency at which the FPPE will test is still unclear
  • the integrity of an examination development process that has the educational bodies preparing individuals for the exam also submitting questions for it remains questionable
  • the lack of educational prerequisites and the implementation of a filtering exam is not the most effective means by which to regulate proficiency standards.

In addition to our old concerns, the lack of overwhelming support of it in all the provinces is cause for new ones:

  • The likely uneven implementation and application of the specifics of the Instrument across Canada suggest a general failure of the Instrument to accomplish that which it was developed to do.
  • The likely uneven implementation creates discrepancies in the levels of proficiency expected of licensed planners from province to province that are invisible to the public.
  • The fact that the Instrument does not regulate standards for fee-only-planners also creates a possible discrepancy in proficiency levels of those planners who are and those who are not registered to sell products that is invisible to the public.


 

 

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