Response to proposed multilateral instrument 33-107

December 6, 1999 (Toronto) - The CSA proposed instrument 33-107 'Proficiency Requirements for Registrants Holding Themselves Out As Providing Financial Planning Advice.' may go far enough for the interests supporting this initiative, but Financial Planners Standards Council (FPSC) wants Canadians to know that there are planners committed to professional standards that exceed the basic requirements outlined in this document. They are professionals with the designation Certified Financial Planners® (CFP®).

CSA states they "prefer to regulate financial planning as an activity" rather than as a distinct profession. FPSC considers this to be a step backwards in the establishment of financial planning as a profession. "This instrument may represent the minimum proficiency required. The CFP remains the highest standard of professionalism in financial planning in Canada and in the World. The public deserves to know the difference," says FPSC President Don Johnston.

Issues of Concern

Grandfathering

* The CSA cites grandfathering as a reason the CBA and the IDA left the FPSC. The instrument allows for the grandfathering of more than 50,000 people by conservative estimates, most of whom come from the banking and brokerage sectors. Many of these new financial planners would never have considered calling themselves financial planners were it not for this automatic distinction. And none will ever have to write a national proficiency exam that the CSA says is the cornerstone of this instrument.
* When FPSC grandfathered for the CFP designation approximately 5,000 practicing professionals were deemed to meet its high standard.

Educational Requirements

* The FPPE exam will be used as a filter with no specific requirement for financial planning education preceding the examination.
* To attain the CFP designation, candidates must complete an approved educational program specific to financial planning.

Examination

* The instrument institutes a national standard examination as the sole filter.
* For next three years the only national proficiency examination there will be, is that set by FPSC and written by CFP candidates.
* The examination instituted by the instrument will be developed by education providers who stand to benefit from offering courses that prepare individuals to successfully write the exam
* The CFP professional proficiency examination is set by an independent panel of practitioners from all segments of the financial services industry

Continuing Education Requirements

* Many assumptions are made in the instrument about commitments to continuing education. Yet no clear standard has been set. The organization responsible for setting and regulating the proficiency standards has chosen not to monitor the continuing education requirements.
* To maintain their designation, CFP licensees must commit to at least 30 hours of continuing education a year to ensure that they are staying abreast of changes in their field. CFP licensees are subject to random CE audits by FPSC.

Code of Ethics

* The instrument contains no specific code of ethics which is one of the cornerstones of a profession.
* The FPSC Code of Ethics encompasses the following principals: integrity, objectivity, competence, fairness, confidentiality, professionalism and diligence and while it does not exempt anyone from the standards of any of the other designations that individuals may hold, it deals specifically with financial planning activities.

The CFP continues to be the mark of the professional in virtually every segment of the financial services industry. There are more than 10,000 CFP licensees working in every discipline and organization involved in financial planning in Canada today. FPSC will continue its commitment to benefiting the Canadian public by establishing and enforcing standards for the professional financial planner and expanding recognition of the CFP designation globally. There are currently 12 countries endorsing CFP as the financial planning profession's highest standard.

FPSC is supported by seven organizations whose members deal with the personal finances of individuals they are:

* The Canadian Association of Financial Planners (CAFP)
* Canadian Association of Insurance and Financial Advisors (CAIFA)
* The Canadian institute of Chartered Accountants (CICA)
* The Canadian Institute of Financial Planning (CIFP)
* Certified General Accountants Association of Canada (CGA)
* Credit Union Institute of Canada (CUIC)
* The Society of Management Accountants of Canada (CMA)

To learn more about FPSC and the CFP designation please visit the FPSC website at www.cfp-ca.org .

Phyllise Gelfand
Tel: (416) 368-8998
Fax: (416) 368-8669
E-mail: pgelfand@opsis.ca