Unregulated Advisor Designations Leave Seniors Vulnerable, IMCA Says

Letter to CFPB outlines need for ‘authentic’ credentials

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  • Client Communication and Miscommunication RIA policies and procedures must specify what type of communications should be retained. The safest course of action is for RIAs to retain all communications—to clients, from clients, and about client accounts.  To comply with fiduciary obligations, communications must be thorough and not mislead.
  • Using Solicitors to Attract Clients Rule 206(4)-3 under the Investment Advisors Act establishes requirements governing cash payments to solicitors. The rule permits payment of cash referral fees to individuals and companies recommending clients to an RIA, but requires four conditions are first satisfied.

No alphabet soup, this; incompetent financial advice is a serious threat that leads to tangible losses for seniors, and accredited certification programs help protect against this risk, according to Investment Management Consultants Association (IMCA).

Responding to a request from the Consumer Financial Protection Bureau (CFPB) for comments related to senior financial exploitation, the Denver-based industry advocacy organization submitted a letter illustrating the importance of accredited financial certifications. In it, IMCA claims that the majority of financial credentialing programs meet no third-party standard, increasing concerns about consumer protections.

The letter is similar to one sent by the Certified Financial Planner Board of Standards on Aug. 21.

"Older Americans have already given many years of hard work and dedication—raising families, serving in the military, building businesses—all to become one of our most financially secure generations," CFP Board CEO Kevin Keller said at the time. A CFP Board survey had found "financial abuse victimizing America's seniors," he said.

IMCA’s letter to the CFPB provides supplemental comments to a letter American National Standards Institute submitted. ANSI accredited IMCA’s Certified Investment Management Analyst CIMA certification in 2011. Other key points from the letter include:

  • The best manner in which to determine legitimacy, value and authenticity of credentials is through a national or international standard designed for organizations that certify individuals, according to ANSI.
  • In the case of CIMA certification, “seniors and other consumers … can be assured that their advisor was certified by an objective, fair, transparent, valid and high-quality process.”
  • Fewer than 5% of certification bodies in financial services have completed any accreditation process for their respective personnel certification programs. 
  • Significant differences exist between certificate programs, university degrees and certification programs, and the three should not be considered equal when establishing financial advisory expertise.  

“The most effective way for seniors and all financial consumers to truly determine the value and competency of a financial advisor is to ascertain the credibility of the advisor’s qualifications,” Betsy Piper-Bach, chairman of IMCA’s board of directors, said in a statement. “A certification earned through a properly administered financial certification program provides comfort that the advisor has mastered advanced skills and knowledge.”

As IMCA notes, as an education and credentialing organization, it does not lobby Congress or regulators or advocate for any particular legislative or regulatory position.


Read CFP Board to CFPB: Seniors Drowning in Alphabet Soup of Advisor Credentials on AdvisorOne.

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