Comment Letter, CFP Board's Competency Standards

RE: Proposed Changes to the CFP Board’s Competency Standards

From: Adam Gana, President Public Investor Advocate Bar Association
To:Certified Financial Planners Board of Standards, Inc.
Date: February 27, 2025
Comment Letter Link: Final Letter

February 28, 2025

Via online submission

Certified Financial Planners Board of Standards, Inc.

1425 K. Street NW, #800

Washington, DC 2005

RE: Proposed Changes to the CFP Board’s Competency Standards

To Whom it May Concern:

I write on behalf of the Public Investors Advocate Bar Association (“PIABA”), an international bar association comprised of attorneys who represent investors in disputes with the securities industry. Since its formation in 1990, PIABA has promoted the interests of the public investor in all securities and commodities arbitration forums, while also advocating for public education regarding investment fraud and industry misconduct. Our members and their clients have a strong interest in rules promulgated by the CFP Board relating to both investor protection and disclosure.

PIABA appreciates the opportunity to comment on the proposed changes to the Competency Standards developed by the CFP Board’s Competency Standards Commission. PIABA generally supports the proposals and hopes that these will strengthen investor protection for clients of CFP professionals. Our support is rooted in the belief that consumers deserve financial advice that is in their best interest and is delivered by a competent financial professional.

PIABA strongly supports the revised standards relating to maintain the CFP Board certification including, but not limited to, the minimum CE requirement of 40 hours every two years. These requirements are essential in the financial services industry where products continue to become more complex and regulations are frequently changing.

While the ethical standard of always working in the client’s best interest is fundamental to any client-adviser relationship, we believe it is equally important that the financial adviser demonstrate competency in their field. PIABA supports the CFP Board’s requirements for certification — education, experience and a comprehensive knowledge exam. These requirements assist financial professionals to stay current on products, practices, rules and regulations. This is essential in the financial services industry.

In sum, PIABA supports the CFP Board and the recommendations of the Competency Commission. PIABA thanks the CFP Board for the opportunity to comment on this proposal.

Respectfully submitted,

Adam Gana, President

Public Investors Advocate Bar Association

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Meyer Wilson

Courtney M. Werning, Esq. | Principal

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STEINER & LIBO

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Gana Weinstein

Adam J. Gana | Managing Partner

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Michael C. Bixby

Bixby Law PLLC | Founder & Managing Attorney