Thursday, August 8, 2013

CFP Board's Revised Compensation Disclosures: "Fee-Based" vs. "Commission-and-Fee"

Articles have already appeared regarding the CFP Board's revised compensation disclosures, and much of the discussion has centered around the elimination of the "salary" category and the CFP Board's unfortunate (in my view, and that of many) treatment of Alan Goldfarb.

Yet, somewhat overlooked is the fact that the CFP Board's three compensation categories - "fee-only", "commission", and "commission and fee" - do NOT included the term "fee-based."

It its Notice to CFP(r) certificants, which can be found at, the CFP Board of Standards advises, in connection with the CFP Board's "Find an Advisor" search engine:

If a CFP® professional and any related party receives or is entitled to receive both commissions and fees for providing professional activities, the CFP® professional must disclose his or her compensation as “Commission and Fee.”

The CFP Board does not expressly state that the term "fee-based" is fraudulent in nature (which I have opined in a past blog post - see Yet, by refusing to endorse the term "fee-based" on its own web site, and requiring "commission and fee" instead, the CFP Board may be on its way to a more robust regime of ensuring that compensation methods are adequately disclosed. Some Certificants (who attended a recent webinar by the CFP Board, to be posted on the CFP Board's web site soon)  indicated to me that the CFP Board requires compensation methods to be accurately disclosed in other disclosure documents, such as Form ADV Part 2A.

Let's give credit where credit is due. Thank you, CFP Board, for leading on this issue.

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