CFP Board Pens Joint Comment Letter on NASAA Model Rule Proposed Amendments
CFP Board, together with the Financial Planning Association (FPA) and the National Association of Personal Financial Advisors (NAPFA), submitted a comment letter on December 19, 2024, to the North American Securities Administrators Association (NASAA) in response to their Request for Comment on proposed revisions to the NASAA model rule on “Dishonest or Unethical Business Practices of Broker-Dealers and Agents.”
The letter applauds NASAA for proposing to acknowledge and incorporate the principles of the U.S. Securities and Exchange Commission’s Regulation Best Interest into the rule, which will enable state regulators to enforce these important provisions for the protection of investors.
The letter also supports NASAA’s efforts to eliminate investor confusion by prohibiting misleading use of the titles “advisor” and “adviser” without licensure. However, it encourages NASAA to go further by preventing a dually registered financial professional from using the titles “advisor” and “adviser” when providing only brokerage services and restricting the use of similar terms in these circumstances.