Protecting Who?

[Harold1]

In late December I sent a note about the problem State Farm had with the fiduciary standard proposed by the CFP Board. The saga continues.
 
There is a great deal of talk today about revisiting the regulatory environment for financial advice. The position of most large financial services organizations (i.e., broker dealers and insurance companies) is that the regulatory structure reflected by FINRA is superior to the less formalized regulatory environment for Registered Investment Advisors.  To the extent I understand the argument; the premise is that the detailed, proscriptive rules and regulations of FINRA provide greater consumer protection than the fiduciary based standards that are applied to RIAs.  Furthermore, there is a parallel argument that there should be a "level playing field," i.e., anyone providing financial services or advice should be held to the same standards. Both of these arguments sound good on the surface. Unfortunately, it's only on the surface.
 
Ignoring the reality that the vast majority of problems and scandals during the last decade have been attributable to organizations regulated by FINRA (and the NASD), not RIAs, the fatal flaw in the argument is that it ignores the fundamental issue of responsibility. FINRA firms are held to a business standard and RIAs to a fiduciary standard. If the real concern is protection of the consumer, not protection of the selling firm, the simple solution to the "level playing field" would be to make all financial services firms subject to fiduciary standards. Fat chance.
 
A striking example of this difference is the final response of State Farm to the CFP Board's requirement that CFP licensees act in a fiduciary capacity *.  It's clear that the concern is protecting the firm, not the client. I can only hope Congress pays attention to this difference when it addresses revision of investment regulation.

Harold Evensky,

Evensky & Katz

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SUMMARY
After an extensive effort to resolve some significant differences with the Certified Financial Planner™ (CFP®) Board of Standards over its new Code of Ethics, we were unable to reach an agreement. This is not the outcome we desired, and we are very disappointed. Consequently, we find ourselves with little or no choice, but to share some very difficult decisions and program changes.

Regretfully, State Farm® will no longer support agent use of the CFP® mark, or any representation or recognition as to holding the CFP certification.

As a result, you are asked to voluntarily relinquish your CFP certification by December 31, 2008. You will soon receive details about how to do this.

In addition, you will not be able to use the mark on business cards, advertisements, and any correspondence with customers.

Effective January 1, 2009, we will temporarily suspend the Personal Financial Planning (PFP) program as it currently exists until appropriate changes are made.

We will hold a video conference to help explain these decisions on December 11th and 16th. Please watch for an invitation. During the conference, you will have the opportunity to ask questions and provide input for the future of the PFP program.

CHRONOLOGY OF EVENTS
On October 20, 2008, all agents and field leadership participating in the PFP program received an e-mail about the three main issues we have with the new CFP Board of Standard's Code of Ethics. The new Code:

1. Extends fiduciary obligation owed to financial planning customers to product purchases made after the formal financial planning engagement has been terminated.

2. Creates fiduciary obligation for non-planning customers through "material elements" of financial planning by the use of one or more sales tools similar to the State Farm Insurance and Financial Review® (IFR) reports.

3. Requires specific disclosures for all customers. The primary concern relates to detailed compensation disclosures.
State Farm has made every effort to resolve these concerns with the CFP Board.
· We met with representatives of the CFP Board on three separate occasions:
1. In Bloomington with Michael Shaw, CFP Director of Public Policy and Legal
2. At an American College Large Firm meeting in Bryn Mawr, Penn., with Kevin Keller, CEO of the CFP Board
3. In Chicago at a CFP Compliance Workshop with representatives from other large firms along with Michael Shaw and Kevin Keller

• A letter was sent to the CFP Board identifying specific areas where we hoped to receive a favorable interpretation. This included the issues that concerned us, as well as presented everyday scenarios State Farm agents encounter. These scenarios were provided to the Board's Disciplinary Committee for their review and interpretation.

• We have had discussions with outside counsel concerning the potential impact of the new CFP Code on the industry and State Farm.

• We discussed the impact of these changes with representatives of the American College, the Financial Planning Association, and with individual compliance officers attending the Chicago CFP Compliance Workshop. At the workshop, most of these firms expressed strong concerns about the same issues we have with the new interpretation of the code. They also questioned the necessity of using the term "fiduciary." One representative of a large broker/dealer commented that many of her registered representatives were already giving up their CFP certification due to the new liability exposure.

In late November, we received the CFP Board's response to our letter. It did not give us the relief we had hoped. The Board's response included these messages:

• The Board considers the sale of auto and homeowner's insurance a financial planning subject area (Risk Management). If a financial plan is presented and implemented, and the customer subsequently purchases an auto or homeowner's policy, the auto or homeowner's policy is considered part of the financial planning process. The fiduciary relationship for the planning client continues until the agent ceases all contact with that client. The CFP Board would not consider the separation of time between the plan and the casualty sale to be a factor.

• For non-planning customers, the Board explained that "material elements" could create a financial planning situation including the fiduciary relationship. If two or more of the subject matter topics for financial planning (investment, insurance, estate, education, retirement planning and risk management) are provided to a customer, then the CFP certificant is engaged in financial planning services. This provides that an agent could deliver two or more IFR reports and, without realizing it, create a fiduciary relationship. This fiduciary obligation would apply to the solicitation of all products offered to this customer by State Farm.

• Although the Conclusion Acknowledgment is signed by the customer, the Board's position is that only the formal engagement is terminated. The fiduciary relationship continues into the future and applies to all product transactions.

Once again, this is not the outcome we had desired, and are disappointed the Board did not adequately address these concerns. We respect and appreciate the effort it took to achieve the CFP mark and value the comprehensive planning process. However, the evolving regulatory environment and risks introduced by the new Code of Ethics are not conducive to our business model. It's regrettable that the CFP Board has chosen this new direction.

Although we can no longer support the CFP mark, we do value of the importance of continuing your professional education. The time you have spent with customers in meeting their planning needs is greatly appreciated. Regardless of what lies ahead for the PFP program, State Farm remains committed to providing insurance and financial services.

To help you further understand the issues, the direction of the PFP program, and be able to ask questions, we are making arrangements for a video conference for all program participants on December 11th and 16th. Dial-in information for the conference, and instructions on terminating your certification, will follow shortly.

Relinquishment of Your CFP Certificate
A CFP certificant can relinquish rights to use the CFP certification marks in two ways: by written notice to the CFP Board, or by non-payment of renewal fees. We are providing a form you can use to voluntarily relinquish your right to use the CFP certification marks by December 31, 2008. What this means is that you will not be an active CFP certificant, but you have reserved the right to request reinstatement of the right to use the CFP certification marks during the next 5-year period by paying a $100 reinstatement fee, paying past dues, and catching up on all required CE during that time period. Best of all, if you act within the next 5 years, you will not have to take the exam again. For more details, you can go to www.cfp.net , look in the left margin for "CFP Certificants" and then select the "Renew your CFP Certification".

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*Note,  I did not receive this information direct from State Farm. I received it from what I believe to be a credible source; however, I was unable to confirm it directly with State Farm.

[Zek, The Grand Nagus]

Yeah, like State Farm is the almighty God of all that is financial services.  They should stick to P&C insurance, and ditch everything else, especially their puny little proprietary funds.

Ron

 

[FPAdvice]

I wish the CFP and FPA would get off of their high horse about this issue, stop wasting my dues money lobbying against firms that give billions to senators, and let me be a Fiduciary RIA as things stand now before they ruin financial advice for consumers completely. I am so glad I have the ChFC to fall back on should I decide the CFP Board goes too far with this issue and want to revoke my certificate voluntarily (no, I am not a broker, but I am growing tired of their wasted 'work' on this issue, and in turn their lack of support of CFPs in the field).

 

The CFP Board and FPA apparently have no education in the law of unintended consequences when dealing with government. Let me explain it. When you ask for something of government, you get the opposite.

 

Does the CFP Board and FPA sincerely believe their investment of my dues money in this issue will result in thousands of untrained brokers overnight becoming qualified to be fiduciaries, or that they will change their advice or behavior in ANY way? It will never happen. I don't care if they become fiduciaries, they'll find a way to still be a broker. But it's not even worth considering because it will never happen despite all of the time they spend lobbying against insurers, brokers, banks, etc...

 

These firms will find a way around it, and in the end nothing will be accomplished. Look at the great success with fee-based brokerage accounts that were going to 'end'. What consumer pulled their account because some new disclaimer they don't read got attached to their fee-based account.

 

Now here's the unintended consequences if there was any aspect of 'success'with government by the CFP Board and FPA:

 

1) RIAs and true fiduciaries are now going to be regulated by a partisan, biased, incompetient body.You are going to give RIAs massive new costs, massive new regulations, and you are probably going to have many very good planners quit or otherwise have issues with becoming employed.

 

2) You are going to drive the costs of true fiduciary advice on those that can least afford it through the roof. There will be far more compliance costs, and those that currently get 'OK' advice from their non-fiduciary broker, who wouldn't be able to afford anything else, won't get any advice at all.

 

I have had fiduciary run-ins with broker-dealers in the past, involving an entire practice I worked at. When I turned to the CFP Board for support, what response did I get for my $350 dues payment? None. There's 200+ clients they could have helped while supporting a CFP in the field. If the CFP Board and FPA were TRULY trying to change what they currently see as a problem why are they NOT assisting those that attempt to work in the b/d setting fulfill their fiduciary responsibility? Why do they ignore more cost-effective and more likely routes of succeding? Our laws aren't only written in Congress. They are determined in courts. If the CFP Board is truly committed to this idea of fiduciary actions they should SUE smaller broker-dealers that allow the use of it's marks for marketing reasons, yet ignore their rules. Yet, they have no desire to offer assistance to reps in these firms, and in fact are losing their certificants and foothold in that world, and will continue to as long as they choose to ignore their certificants there and focus instead of fighting 'for consumers' against senators and massive corporations. A win against a small broker-dealer could create precident that must be applied to larger broker-dealers as well.

 

And so what if an individual gets second class advice. They are free to shop around and ask plenty of questions to learn about the advice they are getting. If they don't see that time as being worthwhile, that is a choice THEY make. That is how the market works. I choose to not pay extra for an Apple Computer, even knowing that because I spend less on a PC I'll probably have more issues with it's operation. That's my choice. I accept the lower standard because I know my budget and I am making a choice. People that chose to not shop around and learn the issues, or thost that do and chose to not pay what most qualified fiduciary advisors charge are making the same choice. The CFP Board would deny advice to those starting out, those that do not have much in assets, etc, by imposing this standard.

 

Let those people that stumble into a State Farm office and end up needing a little help get that advice. There are certainly many that walk into an office to renew their auto insurance, they never would seek out financial advice on their own, their finances are a mess, they will never research the fiduciary issues and don't care. If they get some good advice on saving, get sold a State Farm S&P Index fund that charges a little more than the next guy, then let them get SOME advice.

 

Meanwhile, let me practice as a fiduciary and not a FINRA regulated fiduciary, and let me advertise and educate my clients and the public on that difference, because despite the amount of money that will be wasted on this issue, there will always be a difference. 

[FPAdvice]

As I am sitting here doing my taxes, another realization came to me...

 

For all of the complexities of doing ones own taxes, and having the experience of someone that prepares them professionally, and also reviews taxes individuals prepare on their own, that due to the cost of having a tax-return prepared professional, many individuals feel it is very worthwhile to trust 'software' to prepare their taxes for them. Of those that do, my estimate is 75% I review are incorrect, most often not in the preparers favor.

 

If the CFP Board and FPA want to drive consumers of financial planning services to 'do-it-yourself' approaches and away from competitent, professional advice, just as has occurred in the tax preparation field, they should continue down the same road of allowing their field to become as regulated as the brokerage and tax prep fields.

 

On top of all of that, what is it the professionals in that field have to put up with... so much regulation and oversight that they can NOT afford to assist all those that need help. They have to worry about whether or not they attach a 230 disclosure to a statement, whether or not they are making certain types of statement in an email, etc, etc, etc. Why does the CFP Board and FPA think those types of insane regulations won't come down on them when they seek govt involvement in the fiducuiary issue, which is far greater than just dealing with the tax return, as they work as fiduciaries with a client's entire financial picture?

 

The regulation will be a killer to those that want to work with middle-America. I understand most on the CFP Board don't work with this group. I understand many are trying to volunteer more on the Board than in the past when they worked more with clients. I do hope they understand the consequences of their actions towards clients and current practicioners. I don't believe they do.

[Tad Borek]

There is a great deal of talk today about revisiting the regulatory environment for financial advice. The position of most large financial services organizations (i.e., broker dealers and insurance companies) is that the regulatory structure reflected by FINRA is superior to the less formalized regulatory environment for Registered Investment Advisors.

 

Bernard Madoff Securities LLC should be the nail in the coffin for this idea, most recently raised by Alabama's Richard Shelby (R), that advisers need to be FINRA regulated. I can't believe he was able to say that with a straight face.

 

FINRA already regulated Madoff, and has for many years. You can go into BrokerCheck right now (www.sec.gov) and find all the information there. They didn't catch it. FINRA was, and I use the term carefully here: worthless as a regulator, in this set of circumstances. Worthless. Unable to detect fundamental fraud on a massive scale. One of last week's stories said it's possible that not one bona fide trade was placed for these clients. Not one trade! And FINRA couldn't catch that, despite years of oversight? Incredible.

 

So that's the point to state over and over again - and we RIAs will need to state it over and over again - Madoff was already FINRA regulated, and that regulation had no value whatsoever; in fact it points directly to "the FINRA problem." It's the fox/henhouse issue, writ large.

 

The solution "should be" a) all these fiduciary lawsuits that are going to happen over the next decade, that shut down a fair number of firms who placed money there, and whose due diligence was sloppy b) a top-down shakeup of FINRA and the SEC because neither enforced the toothy laws already on the books (including the '40 Advisers Act) and c) enough accredited investors take a bath in the Madoff scandal that they inspire the remaining accredited investors not to be so lazy with their money in the future.

 

-Tad

[Dick Luedke]

State Farm supports a fiduciary standard with respect to financial planning.  In fact, we have always operated our personal financial planning (PFP) program with the understanding that the agents were acting as fiduciaries during the financial planning engagement.  Our concern lies with the Certified Financial Planning (CFP) Board defining the financial planning engagement in a way that potentially subjects the sale of all financial services and insurance products to the same fiduciary standard.  In that event, our CFP agents would be subjected to a standard that does not exist for other agents.

Also, I can confirm that the letter (memo) you asked about is authentic.  

-Dick Luedke, State Farm

 

[Zek, The Grand Nagus]

Gee, what a crime.

Ron

[FPAdvice]

I completely don't understand the CFP Board's issue with this business decision. We have a firm that has priced their service at a level that allows them to give fiduciary advice to probably everyone, when they consider the potential revenue from the use of their products.

 

I'm glad there is a place that lower income and those starting out can go for qualified advice that they can take where-ever they want and implement. This post from Mr. Luedke gives me a good opinion of the level of dilligence State Farm has done on the financial planning engagement.

 

I'm also glad I have a designation that seperates me from those that must implement with their company's products, and I don't mean that in anyway to be disrespectful of State Farm, I infact do not know State Farm's products. But - I am glad the CFP(r) designation requires complete fiduciary advice, and I would be even gladder if more firms and brokers recognized that they don't meet the requirements either. Again, I chose to practice myself as an Apple Computer, those that choose to practice as a Dell or other model, fine, so long as it works and the consumer makes the choice. The CFP Board seems to want to create one basic model for every consumer based on their beliefs.

 

So, what's the problem? Lower dues for the CFP Board? My answer would be stop spending them so recklessly, market your brand better, and companies may want to change their practices for your designation. Or they may not.

[BruceM]

Although not part of the internal discussions of FPA + NAPFA + CFP Board, it seems clear that they are preparing for the tough questions Congress will be asking. But if this discussion with State Farm is any indication, it would seem that accepting commissions for products recommended is going to undergo some tough scrutiny vsi-a-vis' the fiduciary standard. Now, I know my insurance and investment product friends bristle to their marrow when they hear this, but if my guess is anywhere near close, the financial planning community is moving away from this arrangement.

This doesn't mean the product driven advisors will become illegal...it just means they, like Real Estate Agents and Mortgage brokers,  will most likely not be able to hold themselves out as fiduciaries, unless certain circumstances are met....but this is my best guess.

And were I an  insurance agent, I'd think very carefully about surrendering your CFP designation in protest (as opposed to simply not using it). What will you do if Federal/State legislation is passed licensing CFP certificants (and perhaps other designations) as the only credential authorized to use the term 'Financial Advisor' or some equivalent. Is State Farm willing to completely separate themselves from this future possible eventuality?

Bruce Miller, CFP

[The Wedge]

Then you find a different "title" to define yourself with.

"Titles" don't define YOU.  And "titles" haven't defined anything in financial services EVER.  (Ever walk into a bank?  Next time COUNT how many "vice presidents" there are.  I bet there might even be one on the teller line.)

If all you do is sell your clients on the title you have... then you're not a very good sales-person or business owner.  Clients care about what YOU can do for THEM, not the title you have on your business cards.

As far as the CFP being the "only" designation to use a specific title... fine.  But I won't become assimilated into them because they're the "biggest and baddest" and trying to regulate people out of the industry.  (If you can't beat em..., well I won't be doing that either.)

FYI - MassMutual has sent out a similar letter and has required all CFP certicate holders to complete an additional form for compliance purposes.  They will also NO LONGER reimburse expenses towards CFP coursework or exams.

As far as Fiduciary Standards... I keep to one standard at ALL times - regardless of fee-based or not.  It is simply this:  "What would I do in YOUR situation to improve that situation using the knowledge I have and the knowledge my firm can provide to generate a meaningful, positive difference in your financial life?  Can I implement such advice on a regular & consistent basis and know that I'm improving my financial standing with each contribution into my plan (whatever it may be - savings, insurance, investments, establish trusts & wills, whatever)?"  If I keep to THIS standard, I sleep very well at night.

[Vig Oren]

Off Topic somewhat: Gonna get a CLUe,  IMO, it's a good idea to get a CLU designation. But, I would never advertise it unless you want to become a commission based advisor. Most investors especially retirees shun advisors who sell products. Of course, CLUs, LTCi sellers etc., are important, but they should  avoid personal contact with clients. Let the financial planners do the job of "needs analysis" and let them contact the products salesmen, after disclosing the commission fees arrangement. As my friend, the actuary, says: everybody hates insurance except the insurance Cos. owners and their agents.

[Michael Shaw, CFP Board]

Thank you, Harold, for initiating this discussion.  All of us at CFP Board were surprised and disappointed when we learned that State Farm had asked about 60% of their associates who hold the CFP® certification to relinquish the marks.  While this was an unfortunate development, CFP Board makes no apologies for the high standards it has established for financial planning through the CFP® certification requirements. 

 

CFP Board sought public input from within and outside the financial planning profession when creating the revised Standards to ensure their appropriateness and relevance to the professional practice of financial planning.  The proposal of a specific fiduciary duty of care received much attention during the two comment periods.  We believe the final definition of "fiduciary" in CFP Board's updated Standards ("one who acts in utmost good faith, in a manner he or she reasonably believes to be in the best interest of the client") is appropriate for the financial planning profession and for the clients who seek financial planning services from CFP® certificants. 

 

It's important to remember that CFP Board's fiduciary standard does not apply to product sales by a CFP® certificant unless those sales are made within the context of a financial planning relationship.  For example, a CFP® certificant whose client requests services limited to a specific type of product – whether property/casualty insurance, securities transactions or other products – is required under the Standards to put the client's interest ahead of his or her own, but is not held to CFP Board's fiduciary standard.  On the other hand, if a CFP® certificant provides those same services within the context of a financial planning relationship, CFP Board requires that they be provided with a fiduciary standard of care. 

 

A discussion of two typical scenarios may be helpful in explaining a CFP® certificant's obligations under the Standards.  In the first scenario, a client engages a certificant to prepare a financial plan, then refers the client to another financial professional or professionals to assist the client in implementing the plan.  Here, the fiduciary duty applies to the recommendations contained in the financial plan but not to the implementation of those recommendations.  In the second scenario, a client engages a certificant to prepare and implement a financial plan.  Here, the fiduciary duty extends to any product sales or advice given by the certificant during implementation of the financial plan.      

 

We recognize that the current economic situation and news about misconduct within the financial industry will result in Congress considering stronger regulation of the industry.  Changes are already being discussed, and we're working with FPA, NAPFA and others to ensure that the financial planning community is positioned to shape that discussion.  The Statement of Understanding our coalition released earlier this month highlights our focus on benefitting the public that seeks financial planning services, affirming the goal of having financial planning services delivered to the public with fiduciary accountability and transparency, serving the client's best interest first and always. 

 

CFP Board's involvement in public policy debates will keep the interests of clients at the forefront.  At the same time, we will be working to ensure that any regulatory changes are fair to the CFP® certificants who provide the benefits of financial planning to clients.  And we will work to keep the certificant community informed of any developments on the regulatory front.

 

Michael Shaw

Managing Director, Public Policy & Legal

CFP Board

[Harold1]

Michael, thanks for the comment. I'm only sorry that some commentators confuse my comments regarding fiduciary responsibility with my beleif in the importance of the CFP mark. While it's true that I am an avid supporter of the mark, the issue of "fiduciary" trancends the mark. For example, if State Farm were to dissavow all association with anytrhing related to CFP (R) but required their reps to meet a fiduciary standard vis-a-vis their clients, I'd happily drop my criticism.

Harold

[Tad Borek]

It's important to remember that CFP Board's fiduciary standard does not apply to product sales by a CFP® certificant unless those sales are made within the context of a financial planning relationship.  For example, a CFP® certificant whose client requests services limited to a specific type of product – whether property/casualty insurance, securities transactions or other products – is required under the Standards to put the client's interest ahead of his or her own, but is not held to CFP Board's fiduciary standard.

 

Improving the standards was to me a positive step, and it's interesting that State Farm was shaken out by it. But there's still that product-sale vs planning loophole. Until that changes, I won't regard these as professional standards on par with the duties imposed on me already via licensing. It's just too nuanced a distinction, one that consumers can't understand - are these services within the scope of a planning relationship, or not?

 

Consumers need something simple...you go to your guy/gal, and if they're of a certain type (whether that means CFP or some new/other credential or license) you get the best financial advice they're able to give. That's it. Not some of the time, but all the time. The standard doesn't change if you call up and say "hey I need to open a 529 plan" which under the CFP rules throws it into product sales instead of planning (correct?). So if you're a CFP who happens to work for a certain now-defunct brokerage firm, you could throw them in what was arguably the worst 529 plan on the planet, because that's the one you sell. If the CFP standards had teeth, that would be a clear ethical violation. But it sounds like it isn't?

 

This is the problem...it's a mile-wide loophole that to me detracts from the credential and its putative standards. Especially because so much client work involves these discrete, point in time questions rather than comprehensive plans. Plus, a plan can easily be handed off to an affiliate - it seems - for implementation to get around the rule entirely.

 

Pardon my directness but when I hear that the CFP board is getting into DC during this period that regulation is ripe for rejiggering...I worry about what will ensue. The Board's involvement in public policy debates will "keep the interests of clients at the forefront." But the Board acts more like an industry trade group than a consumer group. Its reason for maintaining the "product sale exemption" is, I assume, to avoid losing a bunch of the membership, whose business realities mean they don't always put clients interests first in a fiduciary capacity. So what? That just flushes out the non-fiduciaries and strengthens the mark. Getting rid of that two-standard fiction would be a significant step towards the stated goal of coming up with a scheme that puts clients' interests first. In the meantime, I'm already operating that way, under the existing regulatory scheme...so please don't mess with it in a way that results in more work for me, and reduced standards for clients.

 

-Tad

[the observer]

Hate to say I told you so... but I told you so! Been telling you so for 10 years or more.

When the discussion was only about 402, I spent hours and hours writing and rewriting the entire 400 series, demanded they all be revised, and much of what I recommended ended up in the final draft. It gave insurance agents who cannot serve two masters the ability to disclose under 401 on a level playing field with all other insurance agents, and financial planners full disclosure under 402 on a level playing filed with investment advisers.

You had to go and mess with something that worked perfectly well for a long time though, thanks to NAPFA's influence and just rolled over on 401 / 402 disclosure. That's not leadership in the field, it's follow the leadership and maybe you should hand the marks over to NAPFA right now and start all over again.

There's an old saying "If it ain't broke don't fix it". Now thanks to NAPFA the "fix" is in. State Farm will not be the last insurance company taking this action and if insurance agents skip CFP® Certification in future, the best interests of consumers can hardly be said to have been served.

This and the Board's hopelessly flawed definition of "fee-only" when they should actually be defining fee-only financial planning is just another nail in the coffin.

Is it time once again to ramp up the opposition and seek real and meaningful "Change"? It's getting close...

[The Wedge]

Off Topic somewhat: Gonna get a CLUe,  IMO, it's a good idea to get a CLU designation. But, I would never advertise it unless you want to become a commission based advisor. Most investors especially retirees shun advisors who sell products. Of course, CLUs, LTCi sellers etc., are important, but they should  avoid personal contact with clients. Let the financial planners do the job of "needs analysis" and let them contact the products salesmen, after disclosing the commission fees arrangement. As my friend, the actuary, says: everybody hates insurance except the insurance Cos. owners and their agents.

It's probably because of your mindset that the FPA is starting to do layoffs.

http://www.investmentnews.com/apps/pbcs ... kingNews01

I think financial planners are TOO AFRAID of doing the implementation with the client's best interests at heart. And yes, LIFE INSURANCE and other insurances are part of it. But if you don't understand life insurance and you don't have the client's best interest at heart... is probably why you would let someone else implement your recommendation.