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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