APRIL 18, 2013

REDUCING CONSUMER CONFUSION AND RISKS

Senior Designations for 

Financial Advisers
2 CONSUMER FINANCIAL PROTECTION BUREAU

Message from 

Richard Cordray

Director of the CFPB

The mission of the Consumer Financial Protection Bureau is to help financial markets work for 

consumers by making rules more effective, by consistently and fairly enforcing those rules, and 

by empowering consumers to take more control over their economic lives. Our Office of 

Financial Protection for Older Americans focuses on the consumer financial issues that affect 

seniors. It is the only federal office devoted exclusively to protecting the financial health of 

Americans age 62 and over. The Office engages in education and policy initiatives to support 

sound financial decision-making by older Americans and to protect them against unfair, 

deceptive, or abusive practices.

The Consumer Bureau is delivering a report to Congress and the U.S. Securities and Exchange 

Commission, entitled Senior Designations for Financial Advisers: Reducing Consumer 

Confusion and Risks, as required by law. Congress directed our Office for Older Americans to 

make recommendations to help facilitate and improve the ability of older consumers to sort out

and assess the numerous and varying “senior designation” titles that financial advisers use to 

market their services.

These designations imply special training and experience in providing financial advice to 

seniors. If well grounded, they can provide a sound basis for recommending financial products 

to help consumers prepare for and maintain a secure retirement. In preparing the enclosed 

report, however, the Office for Older Americans heard frequently from industry representatives, 

state and federal regulators, and consumer organizations that older consumers may be confused 

or misled by financial advisers touting senior designations. This problem is particularly 
3 CONSUMER FINANCIAL PROTECTION BUREAU

dangerous to the financial health of older Americans, who often have little capacity to absorb 

and recover from financial losses.

The enclosed report contains the Consumer Bureau’s findings and recommendations. It also 

discusses a series of approaches that policymakers and regulators at the federal and state level 

could consider to address these critical consumer protection issues and help seniors navigate the 

complex financial marketplace. The report also reflects the Office for Older American’s efforts to 

work with state and federal agencies to help ensure that seniors have the information they need 

to make sound financial decisions.

We recognize the critical importance of protecting the financial security of our nation’s seniors.

And so we will continue working to help seniors improve their economic security, as well as to 

make consumer financial markets work better for all consumers.

Sincerely, 

Richard Cordray
4 CONSUMER FINANCIAL PROTECTION BUREAU

Table of contents

Message from Richard Cordray..................................................................................2

Executive summary .....................................................................................................6

1. Introduction ...........................................................................................................9

2. Background .........................................................................................................11

2.1 Reported problems with senior designations ........................................ 12

3. Challenges and concerns facing older consumers .........................................18

3.1 Older consumers are disproportionately vulnerable to investment 

deception and fraud................................................................................ 21

4. Confusing characteristics of senior designations...........................................23

4.1 Training requirements for and conferring organization oversight over 

senior designees vary widely ..................................................................23

4.2 Professionals who use senior designations are subject to varying 

regulatory regimes ..................................................................................29

4.3 The duty of care owed to consumers varies by regulated activity..........30

5. Consumer protection concerns remain even after recent 

regulatory efforts.................................................................................................33

5.1 NASAA and NAIC model rules and regulations.....................................33

5.2 Reported problems after model rules.....................................................36

5.3 CFPB findings: more protections needed...............................................38
5 CONSUMER FINANCIAL PROTECTION BUREAU

6. Recommendations ..............................................................................................48

6.1 Recommendations Regarding Education and Disclosure .....................50

6.2 Additional Recommendations ................................................................52

7. Conclusion...........................................................................................................55

Appendix A: Methodology ....................................................................................56

Appendix B: Senior Designations Table .............................................................58
6 CONSUMER FINANCIAL PROTECTION BUREAU

Executive summary

The Dodd-Frank Wall Street Reform and Consumer Protection Act directs the Office of 

Financial Protection for Older Americans in the Consumer Financial Protection Bureau (CFPB 

or Bureau) to make recommendations to Congress and the Securities and Exchange Commission 

(SEC) on the best practices for (i) disseminating information regarding the legitimacy of 

certifications of financial advisers who advise seniors; (ii) methods in which a senior can identify 

the financial adviser most appropriate for the senior’s needs; and (iii) methods in which a senior 

can verify a financial adviser’s credentials. 

In recent years, federal and state regulators, 

financial industry representatives and consumer 

groups have been reporting that some financial 

advisers with “senior designations” are targeting 

older consumers and selling them inappropriate and sometimes fraudulent financial products 

and services. Financial advisers often use “senior designations” to imply to consumers that they 

have advanced training or expertise in the financial needs of older consumers. A particular 

problem associated with senior designations is the participation of some designees in “free lunch 

seminars.” These events are often marketed as educational seminars, when in fact they are 

staged sales events to sell investment and other financial products. 

In preparing this report, the Bureau found that the use of senior designations is extremely 

confusing for consumers. There are more than 50 different senior designations currently used in 

today’s marketplace with senior designees recommending or selling a variety of products, such 

as securities, investment opportunities, financial products, and insurance products like 

annuities and long-term care insurance.

The titles and acronyms for the different designations are often similar or nearly identical to 

other designations, making it difficult for consumers to distinguish between different 

The use of senior designations 

is extremely confusing for 

consumers.
7 CONSUMER FINANCIAL PROTECTION BUREAU

designations’ qualifications or legitimacy. Every senior designation is different, and there is a 

very wide range in their characteristics. For example, there are differences regarding training 

requirements, qualifying examinations, continuing education requirements, oversight by the 

conferring organization, complaint procedures for aggrieved clients, and accreditation.

Moreover, the presence, depth and rigor of these components vary widely among designations.

Individuals holding senior designations are subject to different federal and state regulatory 

regimes, adding an additional layer of complexity in comparing these designations. Depending 

on the product or service provided, a senior designee could be regulated by the SEC, Financial 

Industry Regulatory Authority (FINRA), a state securities or insurance regulator, state boards of 

accountancy, a federal or state prudential banking regulator, the Federal Trade Commission 

(FTC), and now the Bureau.

In this report, the Bureau’s Office for Older Americans outlines observations and policy 

recommendations for consideration by Congress’ and the SEC. The recommendations also refer 

to other policymakers, particularly at the state level, because they have primary authority over 

many senior designees and, therefore, are well positioned to improve the marketplace for 

consumers in this area.

The recommendations in this report seek to reduce consumer confusion and protect consumers 

by improving the: (1) dissemination of information and consumer education around senior 

designations; (2) standards for the acquisition of senior designations; (3) standards for senior 

designee conduct; and (4) enforcement related to the misuse of senior designations. The Bureau 

believes that adoption of these recommendations will help older consumers avoid financial 

advisers who would misuse their designations to sell inappropriate investment and financial 

products.

Key observations include the following:

§ Consumers are likely to be confused by the more than 50 senior 

designations used by financial advisers. Senior designations vary widely in 

terms of training required, from rigorous college-level coursework to weekend 

seminars. Consumers have no simple, clear means to distinguish among these 

designations.

§ The financial services industry is complex and its professionals use 

multiple overlapping titles. Many consumers do not understand the basic 

differences between financial professions and the services they provide. The large 
8 CONSUMER FINANCIAL PROTECTION BUREAU

number of similar-sounding senior designations creates additional, undue 

complexity for consumers shopping for senior expertise in financial planning and 

investing. 

§ Rigorous training standards for the approved use of senior designations 

would reduce risks to consumers. If state and federal regulators imposed 

rigorous criteria for acquiring senior designations, including specific standards for 

qualifying prerequisites, education, training, and accreditation, consumers would 

likely encounter fewer designations, and those offered would require a consistent and 

a high- level of training and oversight.

§ Rigorous standards of conduct for those using senior designations would 

reduce risks to consumers. If state and federal regulators set minimum 

standards for the conduct of senior designation holders, consumers would experience 

a more predictable, consumer-oriented market when shopping for senior financial 

expertise.

§ Increased enforcement of existing laws and supervision of senior 

designees will help to deter misleading and fraudulent practices and 

protect older consumers. Consistent enforcement and supervision is needed to 

ensure that standards for senior designees’ conduct and qualifications are upheld.
9 CONSUMER FINANCIAL PROTECTION BUREAU

1. Introduction

The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 directs the Office of 

Financial Protection for Older Americans (Office for Older Americans) in the Consumer 

Financial Protection Bureau (CFPB or Bureau) to make recommendations to Congress and the 

Securities and Exchange Commission (SEC or the Commission) on the best practices for (i) 

disseminating information regarding the legitimacy of certifications of financial advisers who 

advise seniors; (ii) methods in which a senior can identify the financial adviser most appropriate 

for the senior’s needs; and (iii) methods in which a senior can verify a financial adviser’s 

credentials.

1

As consumers move toward retirement, they often face complex financial decisions. Making 

sound decisions depends heavily on the individual’s and family’s particular situation. Due to a 

multitude of factors, including insufficient retirement savings and little time to recover from 

financial losses, appropriate financial decisions are critically important for older consumers. The 

vast majority of older consumers cannot afford to suffer the financial losses that can result from 

inappropriate products or services, or worse, fraud or exploitation. 

There is a bewildering array of senior designations used by financial advisers claiming an 

expertise in the financial issues and choices affecting older Americans. A financial adviser 

acquires a “senior designation” to signify a specialized expertise in advising older consumers.

 

1 See 12 U.S.C. § 5493 (g)(3)(C). The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (DoddFrank Act or Act) established the Office for Older Americans within the CFPB. 12 U.S.C. § 5493(g)(1). The functions of 

the Office include, among other things, developing goals for programs that “help seniors recognize warning signs of 

unfair, deceptive, or abusive practices, [and] protect themselves from such practices.” 12 U.S.C. § 5493(g)(3)(A)(i).
10 CONSUMER FINANCIAL PROTECTION BUREAU

Although many financial advisers with senior designations are reputable professionals, the 

Bureau found that many designations often confuse and sometimes mislead older consumers.

Unfortunately, older consumers are too often targeted by financial services professionals with 

senior designations who are selling products or services that may not be appropriate.

It is within this context that Congress directed the Office for Older Americans to make 

recommendations related to the legitimacy of senior designations, the selection of the most 

appropriate financial adviser, and the verification of a financial adviser’s credentials.
11 CONSUMER FINANCIAL PROTECTION BUREAU

2. Background

There are more than 50 different senior designations currently used by financial advisers in 

today’s marketplace.2 Senior designation credentials, which are voluntarily acquired from 

private conferring entities, generally imply that the financial adviser holding the designation has 

advanced training or expertise in the financial needs of older consumers who are planning for 

retirement or who are already retired.3 However, the Bureau found that the scope and content of 

the required training, qualifying examinations, continuing education, ethical standards, and 

oversight associated with a particular designation varies widely.

The professionals who typically acquire these designations include investment advisers, brokerdealers, accountants, insurance agents, and financial planners and other general financial 

professionals.4 Different senior designees may recommend or sell a variety of products, such as 

securities, investment opportunities, financial products, and insurance products like annuities 

and long-term care insurance. As discussed below, these professionals are not all subject to the 

same regulatory regimes.

 

2 The Bureau reviewed senior specific designations as well as general designations that professionals frequently use to 

market their services to seniors. See, e.g., Financial Industry Regulatory Authority (FINRA), Understanding 

Professional Designations, http://apps.finra.org/DataDirectory/1/prodesignations.aspx (last visited Mar. 18, 2013). 

The term “senior designation” as used in this report encompasses both types of designations.

3 See FINRA, Senior Designations, http://www.finra.org/Industry/Issues/Seniors/P124734 (last visited Mar. 18, 

2013).

4 For a general description of each type of professional, see FINRA, Selecting Investment Professionals: Learn About 

Different Types of Investment Professionals, 

http://www.finra.org/Investors/SmartInvesting/GettingStarted/SelectingInvestmentProfessional/P117278 (last 

visited Mar. 18, 2013).
12 CONSUMER FINANCIAL PROTECTION BUREAU

Senior designees typically use their designation’s acronym or title on their business cards or 

marketing materials. The Bureau found in its review of the field that the titles and acronyms for 

the different designations are often similar or, in some cases, nearly identical to other 

designations, making it extremely difficult for consumers to distinguish between different 

designations’ qualifications or legitimacy.

For example, Certified Estate Planners (CEP), Chartered Estate Planning Practitioners (CEPP), 

and Certified Estate and Trust Specialists (CES) are different designations conferred by different 

organizations, with different training requirements, yet the similarity of these titles may lead 

consumers to believe each possess similar qualifications and expertise.5

2.1 Reported problems with senior 

designations

This section describes some of the reports of senior designees engaging in improper and even 

fraudulent conduct. Because studies indicate that older consumers may be more likely to rely on 

the recommendations of or advice from a professional using a senior designation,

6 reports of 

misconduct are a serious concern.

 

5 See Nat’l Inst. of Certified Estate Planners, http://www.nicep.org/ (last visited Mar. 18, 2013); Chart’d Estate 

Planning Practitioner Prof’l Desig’n Prog., http://www.cepp-epi.com/ (last visited Mar. 18, 2013); Inst. of Bus. & Fin., 

http://icfs.com/ (last visited Mar. 18, 2013).

6 See e.g., FINRA, Senior Fraud Risk Survey (2007), available at 

http://www.finra.org/web/groups/sai/@sai/documents/sai_original_content/p036702.pdf (finding that 46% of 

respondents indicated that a financial adviser's senior-specific accreditation made them more likely to listen to the 

professional's advice).
13 CONSUMER FINANCIAL PROTECTION BUREAU

2.1.1 Results of the SEC’s “Seniors Summits”

The SEC led three “Seniors Summits” between 2006 and 2008 to raise awareness and to 

coordinate multi-regulator efforts to address these issues.7 Summit participants included the 

National Association of Securities Dealers (NASD) and NYSE Regulation, Inc. (now consolidated 

as FINRA), the North American Securities Administrators Association (NASAA), academics, and 

AARP. 

Following the first “Seniors Summit,” the SEC, 

NASAA and FINRA launched a yearlong 

coordinated securities compliance examination 

sweep of 110 firms that were offering free lunch 

sales seminars.8 The examinations found that the 

seminars frequently targeted seniors, and had titles such as “Senior Financial Survival Seminar.”

The sweeps found that the advertising for the seminars often focused on the expertise of the 

financial adviser, some of which included the adviser’s senior designation(s), in ways that could 

be misleading.9 Specifically, the examination found that 

individuals presenting seminars called themselves a “Certified Senior Adviser,” 

or “Elder Care Asset Protection Specialist” or “Chartered Retirement Planning 

Counselor”—terms that suggested that the financial professional has a 

credential indicating specialized training or is certified from a regulatory 

authority, when in fact there is no regulatory qualification or registration that 

recognizes such expertise.10

 

7 See SEC, Third Annual Seniors Summit (Sept. 22, 2008), http://www.sec.gov/investor/seniors/ss3.htm; see also

SEC, Spotlight On: Seniors Summit, http://www.sec.gov/spotlight/seniors/seniors_summit.htm (last updated Sept. 

18, 2007).

8 See SEC, NASAA, FINRA, Protecting Senior Investors: Report of Examinations of Securities Firms Providing “Free 

Lunch” Sales Seminars (Sept. 2007), http://www.sec.gov/spotlight/seniors/freelunchreport.pdf.

9 Id. at 15.

10 Id.

It is critical that the marketplace 

for financial advisers is 

transparent, understandable, 

and fair.
14 CONSUMER FINANCIAL PROTECTION BUREAU

During the sweeps, the regulators found that more than half of the examined firms were using 

sales or advertising that may have been misleading. In addition, regulators found indications of 

unsuitable investment recommendations in nearly one-fourth of seminars examined.11 Thirteen 

percent of firms may have been engaging in potentially fraudulent practices, such as serious 

misrepresentations of risk and return, liquidation of accounts without the customer’s knowledge 

or consent, and sales of fictitious investments. 

The report also found that many of the firms advertised seminars as “educational” or 

“workshops,” when the primary goal was sales. As SEC Chairman Cox noted:

What we are increasingly finding through our examination sweeps of 

investment advisers and brokers who market their wares to seniors is that the 

fraud artists and swindlers among them who prey on older investors often have 

the same MO. They call themselves “Senior Experts” in order to gain the 

victim's trust. They use fancy designations, such as “Certified Senior Investment 

Planner,” or “Registered Senior Investment Adviser” to give the impression that 

they have older investors' best interests at heart. But all too often these are just 

clever marketing ploys to bait the hook so that they can reel in another sucker. 

They sound like genuine designations that require months or years of study and 

rigorous examinations. But in reality, they may be issued by some fly by-night 

operator on the Internet, or they might be the pure invention of the broker or 

the investment adviser.12

The misleading tenor of the advertisements, combined with use of the senior designations, the 

report noted, gave the false impression that the seminar would be unbiased and based on special 

 

11 Unsuitable recommendations included recommending a risky investment to an investor with a “conservative” 

investment objective, or recommending an illiquid investment to an investor with a short-term need for cash. Id. at 4-

5. 

12 Advising Seniors About Their Money: Who Is Qualified – And Who Is Not?: Hearing Before the S. Special Comm. 

on Aging, 110th Cong. 11-12 (2007) (statement of Christopher Cox, Chairman, SEC).
15 CONSUMER FINANCIAL PROTECTION BUREAU

expertise to serve the financial well-being and needs of the senior attendee, leaving seniors 

especially vulnerable to aggressive marketing tactics.13

2.1.2 State regulator experience: Massachusetts Securities 

Division

State regulators have been identifying consumer protection concerns in connection with the use 

of senior designations and related senior sales practices since at least 2003.14 Massachusetts was 

the first state to enact regulations to address the problem of fraudulent and misleading use of 

senior designations.15 The Massachusetts Securities Division (MSD or Division) in 2007 adopted 

regulations after finding a marked increase in the use of various designations and purported 

credentials potentially targeting senior citizens by, among others, broker-dealer agents and 

investment adviser representatives.16

The MSD found:

many instances of a purported senior specialist using credentials or professional 

designations, as well as other marketing tools, to give seniors the impression 

that he or she is acting as their unbiased, knowledgeable and independent 

adviser when the real objective is to convince them to sell financial assets in 

order to purchase a product the specialist offers.17

The MSD pursued enforcement actions against insurance salespersons, who masqueraded as 

unbiased advisers to seniors, and

 

13 See SEC, NASAA, FINRA, supra note 8.

14 See, e.g., Mass. Sec. Div., Discussion of Reasons for, and Objectives of, New Regulations Regarding Use of Senior 

Designations 1 (2007), http://www.sec.state.ma.us/sct/sctpropreg/adminrec.pdf.

15 950 Mass. Code Regs. 12.204(2)(i) (2007); 950 Mass. Code Regs. 12.205(9)(c)(15) (2007), available at

http://www.sec.state.ma.us/sct/sctpropreg/propreg.htm.

16 Mass. Sec. Div., supra note 14.

17 See id. at 1.
16 CONSUMER FINANCIAL PROTECTION BUREAU

convinced seniors to sell existing securities and other assets in order to fund the 

purchase of high-commission equity-indexed annuities and other annuities and 

insurance products, often without regard to suitability to the particular client’s 

age, tax situation or cash flow needs .... 

[Further, the adviser’s] explanation often deemphasizes or entirely skips the 

unattractive features of the instrument, such as lock-up periods and surrender 

fees.18

In one case, MSD found that an insurance agent prepared a letter for one of his elderly clients to 

sign and send to her financial adviser that stated, “I am presently making some life changes and 

I am going to be working with a retirement specialist. He is well known and fully accredited to 

work with seniors.” The agent convinced the senior to sell her securities and other assets to fund 

the purchase of expensive and unsuitable insurance products. The client stated that the agent’s 

designation was “instrumental” in her decision to purchase the annuities.19

In a separate regulatory enforcement action the MSD charged that senior designees:

used such specious titles as “Certified Elder Planning Specialists” (CEPs) to 

mislead the elderly and disguise the fact that associates were simply insurance 

salesman. . . . Respondents conducted ‘Senior Financial Survival Workshops’ as 

part of an unethical and dishonest scheme to deceive, coerce, and frighten the 

elderly into purchasing annuities.20

 

18 See id. at 2, 8. A lock-up period is a period of time during which the investor is prohibited from accessing the funds 

invested. See, e.g., SEC, Structured Notes with Principal Protection: Note the Terms of Your Investment (2011), 

http://investor.gov/news-alerts/investor-bulletins/structured-notes-principal-protection-note-terms-yourinvestment (last visited Mar. 20, 2013). A surrender charge is a charge for withdrawing money from a variable 

annuity within a certain period of time, like the first six or seven years of the investment. The charge declines over 

time until there is no longer a charge (e.g., 7% in year 1, 6% in year 2). See SEC, Glossary: Surrender Charge, 

http://investor.gov/glossary/glossary_terms/surrender-charge (last visited Mar. 20, 2013).

19 Mass. Sec. Div., supra note 14.

20 Id. at 1-2.
17 CONSUMER FINANCIAL PROTECTION BUREAU

The MSD noted that “the requirements to obtain professional designations, and the monitoring 

of people who have obtained those designations, can vary greatly.”21 The MSD found that seniors 

were influenced by senior designations, without understanding the designations’ underlying 

training requirements.22 In response, Massachusetts adopted rules making it a “dishonest and 

unethical” business practice to use a senior designation unless the designation has been 

accredited by an accreditation organization recognized by the Commonwealth.23

 

21 Id. at 5.

22 Id. at 1-2.

23 950 Mass. Code Regs. 12.204(2)(i) (2007); 950 Mass. Code Regs. 12.205(9)(c)(15) (2007), available at

http://www.sec.state.ma.us/sct/sctpropreg/propreg.htm.
18 CONSUMER FINANCIAL PROTECTION BUREAU

3. Challenges and concerns 

facing older consumers

The number of older people in the U.S. is increasing dramatically now that the baby boomers 

(those born between 1946 and 1964) started turning 65 in 2011. The older population in 2030 is 

projected to be twice as large as in 2000, growing from 35 million to 72 million.24 As the number 

of Americans reaching retirement age increases sharply in coming decades, they are expected to 

confront an increasing variety of complex and difficult financial decisions. Consumers who are 

approaching retirement with accumulated assets or the expectation of retirement income may 

be seeking to make strategic investment and lifestyle choices, such as liquidating certain assets 

or downsizing their family homes. For those who are approaching retirement, how they choose 

to invest their assets is critically important to their future. These decisions often determine the 

quality of a senior’s life at a time when, for most older Americans, there is a reduction in income.

Notably, an increasing number of consumers must plan their own retirement investments and 

may turn to professionals for retirement guidance and advice.25 This is due in part to the decline 

in the percentage of workers covered by traditional defined benefit pension plans that pay a 

lifetime annuity and the increase in the percentage of employees with defined contribution 

 

24 See Federal Interagency Forum on Aging, Older Americans 2012: Key Indicators of Well-Being (2012), 

http://www.agingstats.gov/Main_Site/Data/2012_Documents/Population.aspx.

25 See, e.g., Barbara A. Butrica, et al., The Disappearing Defined Benefit Pension and Its Potential Impact on the 

Retirement Incomes of Baby Boomers, 69 Soc. Sec. Bulletin 1 (2009), available at

http://www.ssa.gov/policy/docs/ssb/v69n3/v69n3p1.html; U.S. Dep’t of Labor, Changing Landscape of 

Employment-based Retirement Benefits (2011), available at http://www.bls.gov/opub/cwc/cm20110927ar01p1.htm

(finding that as of 2011, 50% of private industry workers have a defined contribution retirement account, compared to 

22% of private industry workers who have a defined benefit account).
19 CONSUMER FINANCIAL PROTECTION BUREAU

accounts, which the employees own and control.26 Specifically, employees in defined 

contribution plans who are required to direct their own investments must consider the 

investment objectives, the risk and return characteristics, and the long-term performance of the 

plans’ options.27 Therefore, given the data that show an increasing percentage of workers will 

likely have to face complex investment decisions, it is critical that the marketplace for financial 

advisers is transparent, understandable, and fair.

28

 

26 See, e.g., Butrica, et al., supra note 25, at 1 (describing defined contribution plans as “an investment account 

established and often subsidized by employers, but owned and controlled by employees.”).

27 See Dep’t of Labor, A Look at 401(k) Plan Fees (revised Oct. 2010), available at 

http://www.dol.gov/ebsa/publications/401k_employee.html.

28 See Dep’t of Labor, Changing Landscape, supra note 25 (stating that “[r]ecent data suggest that the [percentage of 

workers in defined benefit plans] may continue to decline, as 1 in 4 participants in private industry defined benefit 

plans are in plans that have imposed some type of freeze.”).
20 CONSUMER FINANCIAL PROTECTION BUREAU

This is especially true in light of recent findings that older consumers do not have a good grasp 

on managing investments. One study found that despite having made many financial decisions 

over their lifetimes, older people were unfamiliar with asset pricing, risk diversification, 

portfolio choice, and investment fees.

29 Employees and retirees are increasingly being asked to 

take on tasks requiring financial sophistication, including making saving and investment 

choices, yet they often lack the requisite financial capabilities.30 Thus, older consumers are likely 

to increasingly turn to professional financial advisers for recommendations and advice.

Many Americans also appear to be facing a serious shortage in retirement savings. According to 

the Employee Benefit Research Institute 2012 Retirement Confidence Survey, while two-thirds 

of all workers surveyed reported having saved money for retirement, only 35 percent of workers 

who earn less than $35,000 per year reported having done so.31 Moreover, 60 percent of 

workers surveyed “report[ed] having less than $25,000 in total savings and investments 

(excluding their home and pension), including 30 percent who have less than $1,000 in 

savings.”32

An analysis of 2010 U.S. Census data shows that 75% of Americans age 50-64 without defined 

benefit retirement plans have annual incomes below $52,201; this group has an average 

retirement account balance of $26,395.33

In addition to insufficient or limited retirement savings, older adults, including near retirees, 

generally have little time and fewer resources to enable them to recoup lost savings.34 Some may 

 

29 Annamaria Lusardi, Olivia S. Mitchell & Vilsa Curto, Financial Sophistication in the Older Population, Wharton 

School Research Paper No. 25, 2012, available at http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2064440.

30 Id.

31 Employee Benefit Research Institute, 2012 Retirement Confidence Survey—2012 RCS Fact Sheet #3 (2012), 

http://www.ebri.org/pdf/surveys/rcs/2012/fs-03-rcs-12-fs3-saving.pdf.

32 Id. at 2.

33 Joelle Saad-Lessler & Teresa Ghilarducci, Retirement Account Balances by Income: Even the Highest Earners 

Don't Have Enough, The New School (2012), available at http://www.economicpolicyresearch.org/guaranteeingretirement-income/528-retirement-account-balances-by-income-even-the-highest-earners-dont-have-enough.html.
21 CONSUMER FINANCIAL PROTECTION BUREAU

have an option to rejoin the workforce, but many, if not most, do not. Catastrophic financial 

losses can undermine the health of older Americans and their ability to support or care for 

themselves.

35

For these reasons, the accuracy and credibility of the information guiding older consumers’ 

financial and investment decisions is more critical now than ever. 

3.1 Older consumers are disproportionately 

vulnerable to investment deception and 

fraud 

People 60 years and older make up 15% of the population but are estimated to account for 30% 

of investment fraud victims.36 The disproportionate percentage of older victims of investment 

fraud is attributable to at least two causes.

First, many older consumers are attractive targets 

for the marketing of various financial products 

due to their higher household wealth, such as 

savings for retirement, inheritance, accumulated 

home equity, or other assets. The net worth of 

U.S. households age 65+ was approximately $18 

trillion in 2009.37 Unfortunately, these 

 

34 Robert E. Roush, et al., Why Clinicians Need to Know about the Elder Investment Fraud and Financial 

Exploitation Program, 36 Generations (Issue No. 2, Summer 2012), at 94-97, available at

http://generations.metapress.com/content/k87244298281/?sortorder=asc&p_o=10.

35 U.S. Government Accountability Office, GAO 13-110, Elder Justice: National Strategy Needed to Effectively 

Combat Elder Financial Exploitation (2012), http://www.gao.gov/assets/660/650074.pdf.

36 See Karla Pak & Doug Shadel, AARP Foundation, National Fraud Victim Study 23-26 (2011),

http://assets.aarp.org/rgcenter/econ/fraud-victims-11.pdf.

37 SEC, NASAA, FINRA, supra note 8 (observing that in 2006, 75% of the nation’s consumer assets were held by 

households headed by someone who is 50 years or older).

People 60 years and older 

make up 15% of the population 

but are estimated to account for 

30% of investment fraud 

victims.
22 CONSUMER FINANCIAL PROTECTION BUREAU

characteristics can also make older Americans more attractive targets for fraud and deception. 

In its victim profiling research, AARP found that the mean age for investment fraud victims was 

69 years old.38

Second, as individuals grow older, they are more likely to experience cognitive decline, which 

can impair their capacity to manage their finances. Financial capacity is often understood as 

“the capacity to manage money and financial assets in ways that meet a person’s needs and 

which are consistent with his/her values and self-interest.”39 Financial capacity encompasses 

such core skills as identifying and counting money, understanding debt and loans, paying bills, 

and maintaining judgment to act prudently and avoid financial exploitation.

Financial capacity is one of the first abilities to decline as cognitive impairment and early 

dementia encroach, yet older people, their families and others with whom they interact are 

frequently unaware that these deficits are developing.40

The increased possibility of cognitive impairment in the senior population compounds existing 

challenges in educating seniors about how to select and verify the legitimacy of financial 

advisers and the financial products and services they offer.

 

38 These victims also tended to be male, better educated and relatively wealthy. See Pak & Shadel, supra note 36, at 

23-26 (2011), http://assets.aarp.org/rgcenter/econ/fraud-victims-11.pdf.

39 Daniel C. Marson, Katina Hebert and Andrea C. Solomon, Assessing Civil Competencies in Older Adults with 

Dementia: Consent Capacity, Financial Capacity, and Testamentary Capacity, in Forensic Neuropsychology: A 

Scientific Approach 401-37 (Glenn G. Larrabee ed., 2d ed. 2011).

40 K.L Triebel et al., Declining Financial Capacity in Mild Cognitive Impairment, 73 Neurology 932 (2009).
23 CONSUMER FINANCIAL PROTECTION BUREAU

4. Confusing characteristics of 

senior designations

4.1 Training requirements for and conferring 

organization oversight over senior 

designees vary widely

The distinguishing components among most senior designations include training requirements, 

qualifying examinations, continuing education requirements, oversight by the conferring 

organization, complaint procedures for aggrieved clients, and accreditation. The presence, depth 

and rigor of these components vary widely among different designations.

Entities that confer senior designations include higher education institutions, trade or 

professional associations, non-profit organizations, and for-profit companies.41 Some 

designations require specialized training through an accredited professional program of study 

 

41 See e.g., CPF Board (non-profit), http://www.cfp.net/, The American College (higher education institution),

http://www.theamericancollege.edu/, and The Society of Certified Senior Advisers (for-profit entity),

http://www.csa.us/. These entities generally offer training based on a curriculum and exams to obtain a designation, 

continuing education classes to maintain the designation, and advertising tools to help designees market their 

designation to clients. The entities generally claim that a designation will increase the designee’s expertise in specified 

or general subject areas, and earning potential. 
24 CONSUMER FINANCIAL PROTECTION BUREAU

while others use an unaccredited curriculum.42 Some designations require candidates to satisfy 

prerequisites or hold other professional licenses and fulfill continuing education requirements, 

while others have no such requirements.43

Despite these numerous differences, many designations have names and acronyms that are 

nearly identical or imply similar qualifications. While conferring organizations often provide 

general descriptions of the designations they confer, these descriptions often do not include 

standardized terms or metrics making it nearly impossible for senior investors to compare 

designations.

The lack of clarity can exist even where some criteria might immediately appear standardized.

For example, accreditation is an important step in the development of credentialing and 

educational programs. The accreditation process uses an impartial third party to evaluate a 

program against defined standards. Accreditation evaluators test examination procedures for 

bias and fairness. Evaluators look at whether the training procedures support the competencies 

defined by the program. Third party oversight allows organizations to demonstrate to 

professional peers and to the public that their program(s) have met the accepted standards set 

by the accreditor. 

Nonetheless, accreditation in the senior designation field does not indicate a minimum level of 

competencies or qualifications. Rather, accreditation ensures that a designation’s training and 

testing protocols are suitable for the competencies identified by the designation.44 Even though 

accreditation is an important accountability mechanism, the legitimacy and value of a 

designation is highly contingent on the designation, its objectives and the specific training and 

 

42 See Joyce A. Rogers (AARP), Comment, Request for Information Regarding Senior Financial Exploitation, 77 Fed. 

Reg. 36491, 36491-36492 (June 19, 2012), http://www.regulations.gov/#!documentDetail;D=CFPB-2012-0018-0917;

Laurence Barton (The American College), Comment, Request for Information Regarding Senior Financial 

Exploitation, 77 Fed. Reg. 36491, 36491-36492 (June 19, 2012), 

http://www.regulations.gov/#!documentDetail;D=CFPB-2012-0018-1000. (noting “some designations require a 

qualifying examination while others may require that an applicant merely pay a fee to the conferring organization”).

43 See AARP, Preventing the Misuse of Senior Designations (2010), http://assets.aarp.org/rgcenter/ppi/consprot/i40-senior.pdf.

44 Institute for Credentialing Excellence, http://www.credentialingexcellence.org/p/cm/ld/fid=81 (last visited Apr. 2, 

2013).
25 CONSUMER FINANCIAL PROTECTION BUREAU

exam requirements it imposes. The fact that a senior designation is conferred by an accredited 

organization does not guarantee that financial advisers who acquire the designation possess the 

necessary skills and competencies to provide financial advice to older consumers.

The following descriptions and charts illustrate key differences that exist across designations 

and some of the complexity inherent in attempting to compare designations. 

For example, an Accredited Retirement Adviser (ARA) is an exam-only designation that does 

not require applicants to complete a defined course of study, or demonstrate previous 

professional experience. Instead, students may purchase a study aid before taking an exam. 

Though the ARA’s conferring organization offers accreditation for a different designation for 

accounting, the ARA designation is not accredited.

45 Therefore, the 100-question, multiplechoice examination has not been evaluated against third party accreditation standards to ensure 

that competencies are being effectively tested. The ARA does require designees to receive 72

hours of continuing education every three years. The organization’s website is unclear whether it 

is possible to file a complaint against a designee.46

An Accredited Estate Planner (AEP) candidate (1) must be an attorney, accountant, insurance 

professional, financial planner, or trust officer; (2) must be in good professional standing and 

not subject to disciplinary action; and (3) must have a minimum of five years’ experience in 

estate planning in their profession.47 The training requirements include two graduate level 

courses offered by an accredited higher education graduate program as part of a master’s or 

 

45 Accreditation Council for Accountancy and Taxation, http://connect.nsacct.org/ACAT/About1/AboutACAT (last 

visited Apr. 2, 2013). 

46 Accreditation Council for Accountancy and Taxation, http://www.acatcredentials.org/About1/ContactUs (last 

visited Apr. 2, 2013).

47 National Association of Estate Planners & Councils (NAEPC), http://www.naepc.org/designations/estate-planners 

(last visited Apr. 2, 2013). To be eligible for the AEP designation, the applicant must be currently licensed to practice 

law as an attorney (J.D.) or as a Certified Public Accountant (CPA), or currently designated as a Chartered Life 

Underwriter (CLU), Chartered Financial Consultant (ChFC), Certified Financial Planner (CFP), or Certified Trust & 

Financial Advisor (CTFA), in any jurisdiction of the U.S.
26 CONSUMER FINANCIAL PROTECTION BUREAU

doctoral degree. The conferring organization provides a link to consumer complaint procedures 

on the front page of its website.48

To illustrate the variety of training requirements and quality controls among senior 

designations, the tables below compare four important criteria among eight senior designation 

programs.

49

TABLE 1: COURSEWORK REQUIRED BY EIGHT SENIOR DESIGNATION PROGRAMS

SENIOR DESIGNATION REQUIRED COURSEWORK

Accredited Retirement Advisor (ARA) None

Accredited Retirement Plan Consultant 

(ARPC) None

Certified Senior Advisor (CSA) Three-day training course

Certified Retirement Financial Advisors 

(CRFA)

None

(optional three day course)

Certified Specialist in Retirement Planning 

(CSRP) Self-study seven courses

Chartered Advisor for Senior Living (CASL) 15 Semester Hours

(18 months average completion time)

 

48 See Accredited Estate Planner Complaint Procedure, NAEPC, http://www.naepc.org/designations/estateplanners/complaints (last visited Apr. 1, 2013).

49 The information in the tables was derived from the information appearing on the designation conferring 

organizations’ websites in March 2013. The four criteria featured in the tables were selected for two reasons: (1) the 

NASAA and NAIC model rules devote guidelines to related criteria, and (2) financial education experts and consumer 

advocates prioritized these criteria in interviews with the Bureau. See NASAA, Model Rule On the Use of SeniorSpecific Certifications and Professional Designations (2008), http://www.nasaa.org/wpcontent/uploads/2011/07/3-Senior_Model_Rule_Adopted.pdf; see also NAIC Model Regulation, 

http://www.naic.org/documents/committees_a_suitability_reg_guidance.pdf. The tables are provided for 

illustrative purposes only, and the Bureau is not responsible for and cannot verify information from sources other 

than from the Bureau. The Bureau does not warrant or guarantee the accuracy or completeness of the information.

Nor does the Bureau endorse any particular credential or adviser. And, of course, consumers should not rely on a 

credential alone when selecting an adviser. See App. B for tables comparing additional designations.
27 CONSUMER FINANCIAL PROTECTION BUREAU

Personal Retirement Planning Specialist 

(PRPS)

6 weeks of self-study with 24 hours of webcast 

recorded lectures

Retired Income Specialist (RIS) 60-hour online self-study program

TABLE 2: ACCREDITATION STATUS OF EIGHT SENIOR DESIGNATION PROGRAMS

SENIOR DESIGNATION ACCREDITATION

Accredited Retirement Advisor (ARA) Not Accredited

Accredited Retirement Plan Consultant 

(ARPC) Not Accredited

Certified Senior Advisor (CSA) Nationally accredited (NCCA)

Certified Retirement Financial Advisors 

(CRFA) Nationally Accredited

(NCCA)

Certified Specialist in Retirement Planning 

(CSRP) Not Accredited

Chartered Advisor for Senior Living (CASL) Regionally accredited

Personal Retirement Planning Specialist 

(PRPS) Not Accredited

Retired Income Specialist (RIS) Not Accredited
28 CONSUMER FINANCIAL PROTECTION BUREAU

TABLE 3: DESIGNEE “GOOD STANDING” CHECK AND CONSUMER COMPLAINT PROCESS FOR EIGHT 

SENIOR DESIGNATION PROGRAMS

TABLE 4: PROCEDURES TO DISCIPLINE DESIGNEES OR REVOKE DESIGNATIONS FOR EIGHT SENIOR 

DESIGNATION PROGRAMS

SENIOR DESIGNATION

WEBSITE DISCLOSES DISCIPLINARY 

PROCEDURES FOR DESIGNEE 

MISCONDUCT

Accredited Retirement Advisor (ARA) No

Accredited Retirement Plan Consultant 

(ARPC) No

Certified Senior Advisor (CSA) Yes

Certified Retirement Financial Advisors 

(CRFA) Yes

Certified Specialist in Retirement Planning 

(CSRP) Yes

SENIOR DESIGNATION ONLINE METHODS TO CHECK ANY DESIGNEE'S 

STATUS AND SUBMIT COMPLAINTS

Accredited Retirement Advisor 

(ARA) No

Accredited Retirement Plan 

Consultant (ARPC) No

Certified Senior Advisor (CSA) Online and telephone

Certified Retirement Financial 

Advisors (CRFA) Online

Certified Specialist in Retirement 

Planning (CSRP) No

Chartered Advisor for Senior Living 

(CASL) Online and telephone

Personal Retirement Planning 

Specialist (PRPS) Online

Retired Income Specialist (RIS) No
29 CONSUMER FINANCIAL PROTECTION BUREAU

Chartered Advisor for Senior Living (CASL) Yes

Personal Retirement Planning Specialist 

(PRPS) Yes

Retired Income Specialist (RIS) No

4.2 Professionals who use senior 

designations are subject to varying 

regulatory regimes

The fact that different regulatory regimes govern the conduct of the individuals holding senior 

designations adds an additional layer of complexity in comparing designations. As a general 

matter, large investment advisers are regulated by the SEC, while small and mid-sized 

investment advisers are regulated by state securities regulators. Broker-dealers are regulated by 

the SEC, FINRA, and state securities regulators. Insurance professionals are generally regulated 

by state insurance commissions and accountants are generally regulated by state boards of 

accountancy. Depository institutions are regulated by federal or state prudential banking 

regulators and the Bureau. Attorneys are overseen by state bars. Other persons with senior 

designations, or those not acting in an otherwise regulated capacity, may be regulated by states, 

the FTC, and or the Bureau.50

These regulators do not impose uniform rules for providing financial advice, services, and 

products to seniors.

 50 See FINRA, Selecting Investment Professionals, supra note 4; see also NAIC, State Insurance Regulation: History, 

Purpose and Structure, http://www.naic.org/documents/consumer_state_reg_brief.pdf; U.S. Gov’t Accountability 

Office, GAO-11-235, Consumer Finance: Regulatory Coverage Generally Exists for Financial Planners, But 

Consumer Protection Issues Remain (2011), http://www.gao.gov/new.items/d11235.pdf. The Bureau has authority 

with respect to the provision of certain financial advisory services as described in 12 U.S.C. § 5481(15)(A)(viii) (2011).

The Bureau’s authority is subject to certain limitations with respect to securities and insurance professionals acting in 

their regulated capacities, whose activities are the main subject of this report. See 12 U.S.C. § 5517(f), (h), (i) (2011).
30 CONSUMER FINANCIAL PROTECTION BUREAU

4.3 The duty of care owed to consumers 

varies by regulated activity

A particularly confusing issue for many consumers is the standard of care owed to them by their 

financial adviser.51 Many consumers assume, incorrectly, that financial advisers have a uniform 

legal duty to make recommendations or sell products that are in the client’s best interest.52 The 

use of senior designations can compound consumer confusion.53

Although senior designation conferring organizations may require adherence to a code of ethics 

or similar standards, these standards are not uniform across designations. In addition, the 

conferring organizations do not have uniform disciplinary processes for professionals that fail to 

abide by a particular designation’s standards. 

As a general matter, designees’ regulatory status – not their designation – determines whether 

they have a legal duty of care to their clients, and if so, the type of duty of care. As indicated 

above, since a wide range of professionals hold senior designations, numerous regulatory 

regimes and standards of care apply.54

For example, two types of financial professionals who may hold senior designations and provide 

personalized financial and investment advice and recommendations – broker-dealers and 

 

51 See, e.g., SEC Staff Report, Study on Investment Advisers and Broker Dealers (2011),

http://www.sec.gov/news/studies/2011/913studyfinal.pdf (noting that retail investors are often unaware of the 

different standards of care that apply to advice about and transactions related to securities versus other products, and 

that they are confused by the different standards that apply to investment advisers and broker-dealers).

52 See, e.g., id. (noting that “[m]any [investors] expect that both investment advisers and broker-dealers are obligated 

to act in the investors’ best interests.”)

53 See Advising Seniors About Their Money: Who Is Qualified – And Who Is Not?, supra note 12 (noting that in 

addition to the potential confusion created by different standards for investment advisers and broker-dealers, “[o]ne 

particular source of potential investor confusion is the use of "senior" professional designations by brokers, 

investment advisers, and others.”)

54 See GAO, Report, supra note 50; see also SEC, Study, supra note 51.
31 CONSUMER FINANCIAL PROTECTION BUREAU

investment advisers – are currently held to different standards of care.55 Investment advisers are 

held to a “fiduciary” standard of care, which requires them to act in their clients’ best interest.56

A fiduciary standard prohibits an investment adviser from subordinating a client’s interest to 

the adviser’s interest, and requires advisers to disclose conflicts of interest.57 Broker-dealers, by 

contrast, are not required to act as fiduciaries to their clients. A broker-dealer’s securities 

recommendations are measured against a “suitability” standard, which means that the 

recommendations must be consistent with the client’s interests.58

For some professionals, there may be varying 

standards of care depending on their location or 

size, or the specific products they sell. For 

example, insurance agents are generally regulated 

by the states.59 Some, but not all, states have 

adopted rules requiring insurance agents to have 

reasonable grounds to believe a recommended 

annuity transaction is suitable for the consumer.60

Other types of financial professionals use general titles such as “financial planner,” “financial 

analyst,” or “wealth adviser” that do not necessarily require or indicate that the individual holds 

 

55 See, e.g., SEC, Study, supra note 51. This SEC staff study and recommendations were released in 2011, pursuant to 

Section 913 of the Dodd-Frank Act, and examined, among other things, “the differences in legal and regulatory 

standards in the protection of retail customers relating to the standards of care for broker-dealers, investment 

advisers and their associated persons for providing personalized investment advice about securities to retail 

customers.”

56 See SEC, Regulation of Investment Advisers by the U.S. Securities and Exchange Commission 23 (2013),

http://www.sec.gov/about/offices/oia/oia_investman/rplaze-042012.pdf .

57 See id. at 23-24.

58 See SEC, Study, supra note 51.

59 See 15 U.S.C. § 1012 (2011). 

60 See GAO, Report, supra note 50, at 7-8; see also NAIC Model Regulation, 

http://www.naic.org/documents/committees_a_suitability_reg_guidance.pdf.

Many consumers assume, 

incorrectly, that financial 

advisers have a uniform legal 

duty to make recommendations 

or sell products that are in the 

client’s best interest.
32 CONSUMER FINANCIAL PROTECTION BUREAU

a license or is subject to any particular regulatory requirements.61 These professionals may offer 

detailed or generalized advice about a personal financial plan for a client without handling the 

client’s accounts or executing transactions on behalf of the client. Those who hold themselves 

out as financial planners, financial analysts, or wealth advisers need not always be licensed or 

registered. However, many of these professionals provide services that subject them to licensing 

or registration requirements, along with standards of behavior that apply when these 

professionals act in a regulated capacity.62 For example, financial planners who provide advice 

related to securities may be subject to a fiduciary standard of care because they are acting as 

investment advisers.63 However, other financial planners may provide recommendations in 

contexts in which they are not required to act in their clients’ best interest.64

As noted above, the SEC has reported that financial advisers’ roles and applicable standards of 

care frequently confuse consumers.65 In a trade-consulting firm’s recent survey of 380 advisers 

(brokers, investment advisers and dual registrants) relating to their understanding and use of 

the fiduciary standard of care, over 71% of advisers said they believed “there should be clear 

differentiation between product providers and advice providers, and that industry titles like 

‘adviser,’ ‘consultant,’ and ‘planner’ imply that a fiduciary relationship exists.”66

 

61 See, e.g., FINRA, Selecting Investment Professionals, supra note 4.

62 Id.

63 See, e.g., SEC, Investment Advisers: What You Need to Know Before Choosing One (2012), 

http://www.sec.gov/investor/pubs/invadvisers.htm (noting that many financial planners may be investment advisers,

but that others who call themselves financial planners may only be able to recommend investing in a narrow range of 

products, and sometimes products that are not securities.)

64 Id.

65 See, e.g., SEC, Study, supra note 51.

66 fi360, Is the Fiduciary Standard the New Normal For Financial Advisors? Findings of the 2012 fi360-AdvisorOne 

Fiduciary Survey 13 (2012), http://www.fi360.com/main/pdf/fiduciarysurvey_resultsreport_2012.pdf.
33 CONSUMER FINANCIAL PROTECTION BUREAU

5. Consumer protection 

concerns remain even after 

recent regulatory efforts

5.1 NASAA and NAIC model rules and 

regulations 

In response to concerns expressed by many state regulators about the misleading and fraudulent 

use of senior designations, in 2008, the North American Securities Administrators Association 

(NASAA) and the National Association of Insurance Commissioners (NAIC), adopted model 

rules that would prohibit the misleading use of senior-specific designations in connection with 

the sale of securities or insurance products, respectively, or related investment advice.67 Based 

on the Massachusetts rule discussed above, the model rules cover the misleading use of senior 

designations as well as inadequate standards in the designating or certifying organization.68

 

67 See, e.g., Neb. Dep’t of Banking & Finance, Special Notice (2007), http://www.ndbf.ne.gov/forms/bd-ia-specialnotice.pdf; Mass. Sec. Div., supra note 7; Press Release, NASAA, State Securities Regulators Announce New Model 

Rule on the Use of Senior Certifications and Professional Designations (Apr. 1, 2008), 

http://www.nasaa.org/5685/state-securities-regulators-announce-new-model-rule-on-the-use-of-seniorcertifications-and-professional-designations/; see also Press Release, NAIC, State Regulators Protect Consumers 

From Insurance Fraud (Sept. 24, 2008), http://naic.org/Releases/2008_docs/fraud_protect.htm. NASAA and NAIC 

are associations comprised of state securities and insurance regulators, respectively.

68 Lisa A. Catalano & Christine Lazaro, Financial Abuse of the Elderly: Protecting the Vulnerable, 1 J. Sec. L., Reg. & 

Compliance 13 (2008).
34 CONSUMER FINANCIAL PROTECTION BUREAU

The NASAA Model Rule provides that the misleading use of a senior-specific designation in 

connection with the sale or advice related to securities is a “dishonest and unethical practice” 

under the relevant state securities law.69 Prohibited uses of a senior designation include the use 

of a designation to indicate or imply a level of training or experience the designee does not have; 

the use of a non-existent or self-conferred designation; and the use of a designation not actually 

earned.70

The Model Rule also prohibits senior-specific designations obtained from a designating 

organization that: (i) is primarily engaged in the business of instruction in sales and/or 

marketing; (ii) does not have reasonable standards or procedures related to assuring 

competency of its designees; monitoring and disciplining designees; and continuing education 

requirements. 71

The NASAA Model Rule also establishes a rebuttable presumption that a designation is qualified 

if the designating organization has been accredited by certain enumerated organizations 

including those on the U.S. Department of Education’s list of accrediting agencies recognized for 

purposes of Title IV of the Higher Education Act.72

The NAIC adopted a nearly identical model regulation on senior certifications and designations 

for the insurance industry in 2008.73 The NAIC Model Rule also specifies the same specific 

misleading uses as the NASAA Model Rule, and the same rebuttable presumption regarding the 

certifying or designating organization.

 

69 NASAA, Model Rule On the Use of Senior-Specific Certifications and Professional Designations § 1 (2008), 

http://www.nasaa.org/wp-content/uploads/2011/07/3-Senior_Model_Rule_Adopted.pdf.

70 Id. at § 1(a)-(c).

71 Id. at § 1(d)(i)-(iv).

72 Id. at § 2(i)-(iii).

73 NAIC, Model Laws Regulations, and Guidelines § II-278-1 (2012), 

http://naic.org/documents/committees_models_table_of_contents.pdf.
35 CONSUMER FINANCIAL PROTECTION BUREAU

As of June 2012, 28 states and the District of Columbia had adopted the NASAA model rule (or 

close variant) and 30 states and the District of Columbia had adopted an identical or similar 

version of the NAIC rule through statute or administrative regulation.

74

In early 2008 the SEC, FINRA and NASAA issued a report containing examples of best practices

that financial firms could adopt to increase senior investor protection.75 These best practices 

included procedural controls to ensure age-related considerations on products and policies, 

senior-issues training opportunities for securities professionals, methods for effective 

communication, distribution of investor education materials, and best practices regarding 

advertising and marketing to seniors, including content containing references to senior 

designations. Specifically, the report recommended that firms:

§ Review the training materials used by entities or organizations that confer a designation 

to ensure that predatory sales techniques are not included as part of the training;

§ Verify the appropriate use of designations during field office inspections by reviewing 

securities professionals’ business cards;

§ Maintain a list of approved designations;

§ Ban the use of any designation that includes the word “Senior” to help ensure that 

investors are not confused; and

§ Permit use of designations only if accredited by a national accreditation organization. 76

 

74 In June 2012, the Bureau conducted a scan to see how many states passed laws based upon the NASAA or the NAIC 

model rules. At that time, 10 states had not adopted either the NASAA or NAIC model rules, 18 states and the District 

of Columbia adopted both the NASAA and NAIC model rules, 10 states adopted only the NASAA model rules, and 12 

states adopted only the NAIC model rules. NASAA reported in its submission in response to the Bureau’s June 2012 

Request for Information that as of August 2012, 30 states had adopted their rule, and two states had adopted similar 

rules prior to the issuance of the model rules. See Jack E. Herstein (NASAA), Comment, Request for Information 

Regarding Senior Financial Exploitation, 77 Fed. Reg. 36491, 36491-36492 (June 19, 2012),

http://www.regulations.gov/#!documentDetail;D=CFPB-2012-0018-0980.

75 SEC, NASAA, FINRA, Protecting Senior Investors: Compliance, Supervisory and Other Practices Used by 

Financial Services Firms in Serving Senior Investors (2008), 

http://www.sec.gov/spotlight/seniors/seniorspracticesreport092208.pdf.

76 Id.
36 CONSUMER FINANCIAL PROTECTION BUREAU

5.2 Reported problems after model rules

Despite the regulatory efforts described above, the Bureau’s research and outreach revealed 

substantial concerns related to the wide range of training requirements associated with different 

senior designations as well as the lack of uniform standards of conduct for designees. As 

discussed further below, the responses to the CFPB’s June 2012 Request for Information and the 

information gathered by the Bureau at its roundtable listening sessions indicate that consumers, 

and even financial services professionals, remain confused about the quality and expertise 

associated with different senior designations.

The accreditation provisions in the model rules established an important baseline to ensure the 

quality of training required for senior designations, and to ensure that the expertise and 

qualification claims made by particular senior designations do not mislead consumers. 

However, the rules and the accreditation process do not contain uniform requirements for 

training or competencies for senior designations. Therefore, some designations appear on their 

face to imply specialized financial expertise, yet they can be earned without the requisite 

training to ensure designees have competencies to advise seniors on financial products and 

services.77

In addition to concerns about training and qualifications required for senior designations, 

concerns persist regarding the lack of uniform standards of conduct for senior designees and the 

lack of comprehensive supervision and enforcement to ensure that persons using senior 

designations do not mislead or harm consumers. Moreover, the organizations that confer senior 

designations lack consistent standards of conduct, complaint processes, and disciplinary 

mechanisms. In addition, many of the efforts to improve the senior designation field consist of 

voluntary best practices. Without the application of uniform minimum conduct standards across 

the financial services industry for all who claim a specialized expertise in advising seniors 

through a senior designation, consumer protections will remain inconsistent. 

 

77 For example, when used by financial professionals, the designation Certified Senior Adviser (CSA) may be 

understood by seniors to imply senior-specific financial expertise. However, the designation does not focus on 

training designees regarding financial or investment products for older investors. Rather, the CSA is a general 

designation intended for use among a wide variety of professions to demonstrate an interest in serving seniors. See

Society of Certified Senior Advisors, http://www.csa.us/ (last visited Mar. 19, 2013).
37 CONSUMER FINANCIAL PROTECTION BUREAU

For example, a January 2011 FINRA survey of retail broker-dealer firms found widespread use 

of senior designations in the broker-dealer community (68% of the 157 firms that completed the 

survey), and varying levels of vetting and oversight of the quality of permissible designations. In 

particular, FINRA found that, 

[i]n certain instances, senior designations approved by firms or widely used by

registered persons did not require rigorous qualification standards. As a result, 

the existence of qualification standards to obtain a designation did not ensure 

that those registered persons holding the designation possessed financial 

services skills that were unique or valuable to senior investors. This finding was 

consistent across survey participants and is of concern to FINRA.78

FINRA found that “[i]nvestors are unlikely to differentiate between designations that represent 

an enhanced level of proficiency in dealing with financial matters relevant to senior investors 

versus a designation that is simply a marketing tool.”79

FINRA highlighted sound practices used by some firms to address these problems and 

encouraged broker-dealer firms to adopt these practices and procedures. For example, FINRA 

recommended that: 

§ firms may reduce the risk of confusion or overreliance by their customers by 

implementing procedures aimed at only permitting their registered persons to use senior 

designations that instill substantive knowledge to better serve and protect senior 

investors;

§ firms could prohibit the use of designations that do not have a rigorous curriculum, an 

emphasis on ethics, continuing education requirements, a method for determining the 

registered person’s status regarding the designation, and/or a public disciplinary 

process;

§ firms review advertising and sales literature to ensure that registered persons do not use 

self-conferred or misleading designations without the knowledge of the firm; 

 

78 See FINRA Regulatory Notice 11-52 (Nov. 2011), available at 

http://www.finra.org/Industry/Regulation/Notices/2011/P125093.

79 Id. at 3.
38 CONSUMER FINANCIAL PROTECTION BUREAU

§ registered persons use only earned and approved designations; and 

§ registered persons comply with training and annual attestation requirements.80

These recommendations constitute promising approaches to reducing consumer confusion as 

well as the misleading use of senior designations. However, it is unclear how widely these 

recommendations will be adopted given that they remain voluntary and are addressed only to 

the firms FINRA regulates. 

5.3 CFPB findings: more protections needed

To better understand current perspectives about senior designations, the Bureau issued a 

Request for Information and held two roundtables to hear from policymakers, regulators, 

consumer advocates, financial educators, and other experts regarding consumers’ experiences 

with senior designations. Many of the comments and perspectives the Bureau received described 

the difficulties consumers face in verifying the legitimacy of designations, and the lack of 

consistent and robust standards for designee training and oversight of designee conduct.

5.3.1 Results of the CFPB roundtable listening sessions

The Bureau held roundtable listening sessions with stakeholders in Washington, DC and San 

Francisco, CA in late 2012 to discuss seniors’ understanding of and experience with senior 

designations. Attendees included financial planners, insurance and securities professionals, 

consumer advocates, social workers, and other industry stakeholders. 

The discussion topics focused on effective methods to protect older consumers in a confusing 

and somewhat opaque senior designation marketplace. Specifically, attendees shared their 

thoughts on best practices to provide seniors with the tools to assess the legitimacy of senior 

designations and verify the credentials of financial advisers, how seniors might identify an 

appropriate adviser, and how the Bureau might best ensure that seniors have access to these 

tools. The most common themes arising in the discussions were:

 

80 Id. at 3-6.
39 CONSUMER FINANCIAL PROTECTION BUREAU

§ the need for information and tools to enable consumers and the industry to assess the 

legitimacy and value of senior designations;

§ support for the development of a senior designation ratings system; and 

§ the vulnerability of senior consumers. 

The most common concern expressed during the roundtables was that seniors have insufficient 

information to determine the legitimacy and value of different senior designations. One 

Certified Financial Planner (CFP) professional echoed the sentiments of many in both 

roundtables when she stated, “Good information is urgently needed to help consumers 

understand the differences between these credentials.”

Some participants provided anecdotal examples about the obstacles to assessing the legitimacy 

of senior designations despite having expertise in financial services matters. A financial adviser 

in San Francisco said, “If it’s confusing for me, how must it be for seniors, especially those 

without investing experience?” 

A Registered Investment Adviser in San Francisco expressed the importance of ensuring that 

clients understand the distinction between different designations when saying that, “I’m a CFP 

and I have several other designations. The CFP took me two years to earn. The others took two 

months. All of my credentials have been useful to me, but my clients deserve to know the 

difference between them.”

Financial professionals, academic representatives, and conferring organizations all expressed 

interest in seeing improved educational resources on how to judge a financial adviser's 

credentials and determine their fit with a consumer’s financial needs and goals. There were 

numerous calls at both roundtables to establish a ratings system for senior designations. One 

financial planner suggested a “simple approval system, comparable to the Good Housekeeping 

seal of approval.” Other attendees called for ratings systems that resemble food safety scores or 

academic report cards.

Many attendees also stated that confusion exists on "both sides of the table," noting that 

industry professionals are often unsure of which senior designations are a good investment of 

their time and energy to obtain. 

Attendees universally agreed on the vulnerability of older investors in the financial services 

marketplace. Attendees also expressed concern that seniors frequently assume financial advisers 

hold their interests above all else. Many noted that older clients do not understand that a 

fiduciary duty is not universal in the financial services field. One financial adviser attending the 
40 CONSUMER FINANCIAL PROTECTION BUREAU

San Francisco roundtable noted that “seniors need to understand how their adviser is 

incentivized, and what this means for the services they receive.” An investment adviser added,

“Consumers, especially older ones, should know the basic (differences) between a fiduciary and 

someone following suitability. They almost never do.” 

5.3.2 Results of the CFPB request for information 

In June of 2012, the Bureau issued a Request for Information (RFI) in the Federal Register 

inquiring about several topics related to senior financial exploitation.81 The questions 

concerning senior designations focused on 1) the evaluation of senior designations and 

designees, 2) availability of quality information about senior designations, and 3) fraudulent or 

misleading use of senior designations. 

The comments addressing senior designations provided a rich picture of the current consumer 

protection concerns.82 The commenters generally expressed concerns that the misleading use of 

senior designations is a long-standing consumer protection concern. Commenters also noted 

that even within the current regulatory regime, senior designations lack consistent training, 

qualification, and oversight standards. Lastly, many commenters stated that consumers do not 

have the tools or information to determine the value or legitimacy of different designations, or 

to understand how designations differ from one another. Below is a sample of responses to the 

RFI that illustrate this point.

The Financial Industry Regulatory Authority (FINRA) is the largest independent 

regulator for all securities firms doing business in the United States. FINRA oversees 

approximately 4,275 brokerage firms, about 161,550 branch offices and approximately 629,980 

registered securities representatives.83 FINRA in its response noted that the use of professional 

designations in general has been a long-standing regulatory concern. In addition to outlining its 

extensive work in investor education, FINRA focused attention on the potentially unfair, 

 

81 77 Fed. Reg. 36491, 36491-36492 (June 19, 2012), available at www.federalregister.gov/articles/2012/06/19/2012-

14854/request-for-information-regarding-senior-financial-exploitation.

82 A total of 1,045 responses were received and posted to the Federal Register. Not all responses addressed senior 

designations.

83 See FINRA, http://www.finra.org/AboutFINRA/index.htm (last visited Apr. 2, 2013).
41 CONSUMER FINANCIAL PROTECTION BUREAU

abusive, or deceptive practices of targeting seniors at free-lunch sales seminars. FINRA noted 

that even though there may be nothing "inherently wrong" with a sales seminar, consumer 

protection problems around sales tactics have arisen in the past.84 FINRA offers an investor 

alert on its website titled Free Lunch" Investment Seminars – Avoiding the Heartburn of a 

Hard Sell.85 FINRA also offers a Professional Designations Tool, which is a database of 

professional designations currently in use. FINRA states that “while extensive, the tool is not an 

all-inclusive database....”86

The North American Securities Administrators Association (NASAA), organized in 

1919, is a voluntary association whose membership consists of 67 state, provincial, and 

territorial securities administrators in the 50 states, the District of Columbia, Puerto Rico, the 

U.S. Virgin Islands, Canada, and Mexico.87 NASAA’s submission described its record in leading 

consumer protection efforts regarding senior designations. Specifically, “[the] widespread 

deception [relating to the use of senior designations], often combined with free-meal seminars, 

was identified by state securities regulators following investor complaints in various regions of 

the United States," and therefore, since 2005, NASAA has been alerting seniors to carefully 

check the credentials of individuals claiming to be senior specialists. Further, in 2008, NASAA 

issued its Model Rule on Senior-Specific Certifications and Professional Designations. To date, 

30 states have adopted the NASAA Model Rule and two states had adopted similar rules prior to 

the issuance of the model rules. However, in its RFI response, NASAA expressed continued 

concerns over senior designation misuse and fraud. NASAA noted the particular vulnerability 

seniors face regarding fraud and other financial abuses in light of “misleading” senior 

designations. NASAA stated, “[t]he requirements to obtain these designations and certifications 

 

84 See Marcia E. Asquith (FINRA), Comment, Request for Information Regarding Senior Financial Exploitation, 77 

Fed. Reg. 36491 (June 19, 2012), available at http://www.regulations.gov/#!documentDetail;D=CFPB-2012-0018-

0913. 

85 See FINRA, “Free Lunch” Investment Seminars: Avoiding the Heartburn of a Hard Sell, Investor Education Series 

(2011), http://www.finra.org/web/groups/investors/@inv/@protect/@ia/documents/investors/p125861.pdf.

86 See FINRA, Comment, supra note 84.

87 See NASAA, http://www.nasaa.org/about-us/ (last visited Apr. 1, 2013).
42 CONSUMER FINANCIAL PROTECTION BUREAU

vary greatly, as can the processes for monitoring compliance with a code of conduct or ethics, if 

any, adopted by the organization that awards the designation or certification.”88

The Investor Protection Trust (IPT) & Investor Protection Institute (IPI) are nonprofit, investor education organizations founded in 1993 as part of a multi-state settlement to 

resolve charges of misconduct.89 The IPT also oversees the Investor Education Fund, which 

receives deposits resulting from some settlement cases in the securities industry.90 In their 

response to the RFI, IPT & IPI submitted the results of an online survey conducted of 756 

professionals, including state securities regulators, financial planners, health care professionals, 

social workers, adult protective services, law enforcement officials, elder law attorneys, and 

academics.91

According to IPT & IPI, two-thirds of those surveyed have experience working with elderly 

victims of investment fraud/financial exploitation. Three-quarters said that such cases are a 

“very serious” problem in America today and 78 percent reported that older Americans are “very 

vulnerable” to investment fraud/financial exploitation.92 IPT & IPI reported specific findings 

related to senior designations:

§ 58 percent of surveyed professionals said seniors are “not very able” or “not able at all” to 

determine the legitimacy, value, and authenticity of credentials held by their financial 

advisers and planners.

 

88 See Jack E. Herstein (NASAA), Comment, Request for Information Regarding Senior Financial Exploitation, 77 

Fed. Reg. 36491, 36491-36492 (June 19, 2012), http://www.regulations.gov/#!documentDetail;D=CFPB-2012-0018-

0980.

89 Investor Protection Trust, http://www.investorprotection.org/ipt-activities/?fa=about (last visited Mar. 19, 2013).

90 According to IPT’s website, “[i]n April 2003, [NASAA, the SEC], FINRA, and the New York Stock Exchange 

announced the settlement of enforcement actions involving conflicts of interest between the research and investment 

banking operations of 10 of the nation’s largest investment firms. Seven of the firms agreed to pay a total of $80 

million for investor education purposes. Of that amount, $30 million was paid to State Securities Regulators and 

those funds comprise the Investor Education Fund overseen by IPT.” Id.

91 See Don Blandin (IPT & IPI), Comment, Request for Information Regarding Senior Financial Exploitation, 77 Fed. 

Reg. 36491, 36491-36492 (June 19, 2012), http://www.regulations.gov/#!documentDetail;D=CFPB-2012-0018-1010.

92 See id. for complete survey. 
43 CONSUMER FINANCIAL PROTECTION BUREAU

§ Respondents reported that “current efforts for maintaining the legitimacy, value, and 

authenticity of credentials held by financial advisers and planners” are “not very 

effective” (36%) or “not effective at all” (26%).

§ 59 percent reported that existing accountability controls are not effective “when it comes 

to deterring the misuse of senior adviser credentials.”

§ 53 percent reported that “the available resources for seniors when selecting a financial 

adviser with appropriate knowledge to address their specific financial needs” are either 

not very effective or not effective at all. 

The Women's Institute for a Secure Retirement (WISER) is a non-profit organization 

that develops and runs retirement education programs. WISER noted in its submission in 

response to the RFI that over the last three decades, Americans have faced increasingly complex 

financial decisions in spite of low overall financial literacy.93 WISER reported seeing “confusion 

and uncertainty in all corners of the country when we conduct workshops.” Citing the conflicting 

and often poor advice from family and colleagues and the uneven performance of online 

retirement calculators,94 WISER observed that the many senior designations pose additional 

barriers to clarity:

The avalanche of information and the complexities involved are significant 

barriers to seniors trying to protect themselves from financial insecurity. Then 

introduce the confusing certifications and designations used by certain financial 

predators and you have the steady increase of seniors who are misled and who 

are purchasing unsuitable products.

WISER also described the confusing jargon and numerous titles in the financial services 

industry, which creates an increased risk of confusion for older consumers:

Just think about some of the terms that are part of the everyday financial lingo:

there are CFP’s, CFA’s, RMD’s[,] MMA’s, CD’s, DB’s, DC’s, IRA’s, annuities, and 

 

93 WISER, Comment, Request for Information Regarding Senior Financial Exploitation, 77 Fed. Reg. 36491, 36491-

36492 (June 19, 2012), http://www.regulations.gov/#!documentDetail;D=CFPB-2012-0018-1026. 

94 Review of calculators conducted by CBS MoneyWatch: http://www.cbsnews.com/8301-505146_162-

57490505/can-you-trust-retirement-calculators/?tag=cbsnewsSectionsArea;cbsnewsSectionsArea.6.
44 CONSUMER FINANCIAL PROTECTION BUREAU

more. To reach people—to have them hear the message—we need to take a step 

back from all the jargon and give people basic, usable information from reliable 

trusted messengers, in combination with the tools to find out who is reliable.

Thus, WISER expressed concern that consumers may throw their hands in the air or walk into 

the arms of predators who portray themselves as 

protectors of the rights of seniors.

AARP is a nonprofit, nonpartisan organization 

that advocates on issues like healthcare, 

employment security and retirement planning.95

AARP noted in its response to the RFI that 

problems with respect to senior designations, 

such as the lack of information available to assist 

seniors in evaluating various designations and 

poor accountability controls for issuing 

organizations and designation users, increase the 

risk of senior financial exploitation.96 AARP noted the varied quality among senior designations, 

commenting that training and accountability requirements range from “minimal” leading to 

“self-awarded designations,” to “substantial specialized training and adherence to heightened 

standards of conduct and oversight.” AARP noted that this lack of consistency creates 

substantial consumer confusion:

[T]he absence of consistent training requirement benchmarks] complicates

exponentially the choice a consumer must make. In order to evaluate the 

differences in the designations, a consumer is forced to conduct complicated 

research. But the lack of information to assist them in comparing the 

credentials of one adviser to another further complicates that process and 

increases the potential for misuse. The information that is available about 

 

95 AARP, http://www.aarp.org/about-aarp/ (last visited Apr. 1, 2013).

96 See Joyce A. Rogers (AARP), Comment, Request for Information Regarding Senior Financial Exploitation, 77 Fed. 

Reg. 36491, 36491-36492 (June 19, 2012), http://www.regulations.gov/#!documentDetail;D=CFPB-2012-0018-0917.

The information available about 

certifications and designations 

is not remotely comprehensive

and does not provide sufficient 

comparisons to permit a 

consumer to quickly and easily 

assess the differences between 

designations.
45 CONSUMER FINANCIAL PROTECTION BUREAU

certifications and designations is spotty, in that it is not remotely 

comprehensive, and does not provide sufficient comparisons to permit a 

consumer to quickly and easily assess the differences between designations.

AARP provided specific suggestions to address the inadequacy of resources available to 

determine the legitimacy, value, and authenticity of credentials held by their financial advisers 

and planners. In addition to requiring that designees provide clear, comparable information, 

AARP suggested requiring “clear disclosure regarding the educational and other requirements 

necessary to obtain and maintain a designation by any professional that uses one.” Finally, 

AARP called for greater accountability controls for policing the use of senior designations by 

increasing the enforcement of existing laws and regulations, particularly related to fraud and 

unfair trade practices that harm older investors. 

The American College is a non-profit higher education institution that provides financial 

education programs, including several senior designations. The American College provided 

recommendations to improve consumers’ ability to discern the legitimacy of different 

designations:

An ideal outcome of your work would be to create a single-source consumer

website to help seniors understand which designations represent depth and 

quality of education and which ones do not. Information on the site would need 

to explain that other marks may have some educational value, but that only 

credentials that meet certain minimum national standards should be viewed as 

professional designations that may be used with the public.97

The American College noted several consumer protection concerns, including that “consumers 

can't really be expected to [know the difference]” between a senior designation requiring 

hundreds of hours of preparation and one that is merely purchased along with a weekend 

seminar. The American College supports the creation of minimum national standards for senior 

designations.

 

97 See Laurence Barton (The American College), Comment, Request for Information Regarding Senior Financial 

Exploitation, 77 Fed. Reg. 36491, 36491-36492 (June 19, 2012),

http://www.regulations.gov/#!documentDetail;D=CFPB-2012-0018-1000.
46 CONSUMER FINANCIAL PROTECTION BUREAU

The National Association of Insurance and Financial Advisers (NAIFA) is one of the 

oldest and largest financial services organizations representing the interest of insurance 

professionals. NAIFA's submission to the Bureau noted that seniors rely on designations to 

acquire a sense of an adviser's expertise and recognized that, 

people often do no additional investigation or due diligence to ensure that their

financial adviser or other service provider has the necessary experience and 

knowledge to provide the services the individual needs.98

For this reason, NAIFA noted that the substance behind a certification or designation is very 

important.

The CFP Board is a non-profit organization that grants the Certified Financial Planner (CFP) 

designation. The CFP Board contracted with APCO Insight to survey current CFP professionals 

on issues related to senior financial exploitation. The online survey received 2,649 responses, 

and researchers conducted in-depth telephone interviews with a subset of respondents. The 

findings from the survey provide an important lens into the views of financial planners’ 

regarding the prevalence of senior financial exploitation and of the challenges seniors face in 

selecting an appropriate and trustworthy financial adviser.

CFP professionals reported seeing senior financial exploitation in the form of invitations for free 

financial or investment seminars, unsolicited calls for financial products/services and offers for 

high-yield investment products that are described as no-risk or low-risk. Through these 

channels and others, CFP professionals reported being aware of the sale of what they consider to 

be “unsuitable” products, omission of important facts, misrepresentation and negligence or lack 

of follow-up by financial advisers. 

The CFP Board’s key findings were:

§ More than half (56%) of CFP professionals personally have worked with an older client 

who has been subject to what the professionals consider to be unfair, deceptive or 

abusive practices in the delivery of financial advice or the sale of financial products.

 

98 See Gary Sanders (NAIFA), Comment, Request for Information Regarding Senior Financial Exploitation, 77 Fed. 

Reg. 36491, 36491-36492 (June 19, 2012), http://www.regulations.gov/#!documentDetail;D=CFPB-2012-0018-0924. 
47 CONSUMER FINANCIAL PROTECTION BUREAU

§ 32 percent personally know an older non-client who has been subject to what the 

professionals consider to be unfair, deceptive or abusive practices.

§ Seniors are being targeted for free lunches, risky investments and abusive practices. 

§ 73 percent of CFP professionals are aware of older investors who have been invited to 

“free meal” seminars. 

§ 58 percent are aware of older investors who have received unsolicited pitches for 

financial products or services.

§ Half are aware of older investors who have been offered high-yielding investments 

described as no-risk or low-risk. 

§ Approximately a third are aware of older investors who have been pitched for prizewinning scams.

§ 74 percent of CFP professionals are aware of older investors who have been offered 

unsuitable financial products by a financial advisor.

§ 58 percent are aware of older investors who have been subject to omission of material 

facts about financial products.

§ 48 percent are aware of older investors who have been subject to misrepresentations 

about financial products.

§ 46 percent are aware of older investors who have been subject to negligence or lack of 

follow-up in connection with financial products. 

§ Approximately one in five CFP professionals are aware of practices by financial advisors 

such as fraud with intent or lying (19%) and unauthorized transactions (17%).99

The survey revealed that CFP professionals responded that, "by far, the most common products 

involved in the subjection of an older American to unfair, deceptive or abusive practices by a 

financial advisor are equity indexed or variable annuities." 

CFP professionals reported that they have most often witnessed financial exploitation that 

involved equity indexed or variable annuities (76%), variable life insurance (32%), mutual funds 

(29%), and universal or whole life insurance (28%).100

 

99 Marilyn Mohrman-Gillis (CFP), Comment, Request for Information Regarding Senior Financial Exploitation, 77 

Fed. Reg. 36491, 36491-36492 (June 19, 2012), http://www.regulations.gov/#!documentDetail;D=CFPB-2012-0018-

1036. 
48 CONSUMER FINANCIAL PROTECTION BUREAU

6. Recommendations

In light of its findings from a review of the senior designation marketplace, the Bureau has 

developed the recommendations outlined below. 

The first section of the recommendations (Section 6.1) addresses dissemination of information 

to consumers. In order for consumers to understand the legitimacy of certifications, effectively 

identify the most appropriate adviser and verify an adviser’s credentials, consumers will need 

information about, among other things, the training, qualifications, education, and standards 

required for a given designation. 

The second section of the recommendations 

(Section 6.2) similarly seeks to address the 

consumer confusion around senior designations, 

as well as related consumer protection concerns 

the Bureau observed in its review of the field. These recommendations seek to enhance the 

consistency and quality of standards for the acquisition of senior designations, senior designee 

conduct, and accountability and oversight of senior designees. 

The effectiveness of methods to inform older consumers about the legitimacy of senior 

designations, to assist them in selecting the most appropriate financial advisor, and to enable 

them to verify a financial advisor’s credentials (described in Section 6.1) hinge on addressing the 

lack of consistent standards for training and conduct for financial professionals who use senior 

designations, and the use of misleading senior designee titles (described in Section 6.2).

Enforcement plays an important role in ensuring that older investors are protected. Providing 

individuals with a private right to seek redress is one enforcement tool that many states employ 

 

100 Id. 

Enforcement plays an important 

role in ensuring that older 

investors are protected.
49 CONSUMER FINANCIAL PROTECTION BUREAU

to protect consumers. Most states provide private rights of action to enforce state laws 

prohibiting unfair or deceptive acts or practices, or similar consumer protection statutes.

101

However, misleading conduct around senior designations is not within the coverage of all such 

statutes.102 And while investors with claims against broker-dealers who are registered with 

FINRA may be required to bring claims using FINRA’s arbitration process rather than file a 

lawsuit under state law,103 use of senior designations is not limited to broker-dealers. Increasing 

enforcement with respect to prohibited conduct – whether by providing a private right of action, 

increasing enforcement and supervision efforts by regulators, or otherwise – could help to 

address consumer harm and deter prohibited conduct in connection with misuse of senior 

designations.

Though regulators will need to consider the recommendations in light of their legal authorities 

and available resources, the Bureau believes that these recommendations, if adopted, will help 

reduce consumer confusion and protect older consumers in their retirement years.

104

 

101 See, e.g., Rob Sand, Note, Fraud’s Final Frontier: Iowa’s Battle Over Becoming the Final State to Allow Private 

Consumer Fraud Actions, 35 J. Corp. L. 615 (Spring 2010). 

102 See, e.g., Morris v. Gilbert, 649 F. Supp. 1491 (E.D.N.Y. 1986) (claim under N.Y. Gen. Bus. Law § 349(h) by a 

disappointed investor concerning alleged deceptive practices in regard to the sale of securities was outside the ambit 

of the statute); see generally Consumer Protection and the Law, AmJur2d § 4.21 (updated Nov. 2012) (securities and 

insurance claims often excluded from ambit of state consumer protection statutes).

103 See FINRA Code of Arbitration Procedure for Customer Disputes, available at

http://www.finra.org/web/groups/arbitrationmediation/@arbmed/@arbion/documents/arbmed/p117546.pdf.

104 With respect to recommendations that would be implemented for broker-dealers, the SEC may determine that 

implementation is best undertaken by FINRA rather than directly by the SEC.
50 CONSUMER FINANCIAL PROTECTION BUREAU

6.1 Recommendations Regarding Education

and Disclosure

6.1.1 Education

The SEC may wish to consider establishing a centralized tool through which senior 

investors can verify a financial adviser’s 

designations.

The SEC may wish to coordinate this effort with 

other regulators and build upon existing 

resources, for example, SEC’s Investment Adviser 

Public Disclosure (IAPD) which provides 

investors with online access to registration 

documents and other background information on 

more than 25,000 SEC- or state-registered 

investment advisers; FINRA’s BrokerCheck, which provides investors with professional 

background information on current and former FINRA-registered brokers and dealers; and 

NASAA’s website, ” which includes contact information for state securities’ regulators.

105 While 

the SEC’s and FINRA’s tools include extensive information about an individual or firm’s 

professional history, qualifications and disciplinary history, the tools generally do not include 

information about the nature of advisers’ senior designations. In addition, FINRA has created 

the Understanding Professional Designations Database. This database provides helpful 

information regarding existing designations. It does not, however, provide tools that let 

consumers quickly assess how one designation compares with others.

Including information about senior designations in existing professional background databases 

or in a newly created tool, and ensuring coordination of resources, would help to increase 

consumers’ ability to assess the legitimacy of a financial adviser’s qualifications, including any 

senior designations, and would help to reduce consumer confusion. These databases could 

 

105 See NASAA, How to Check Out Your Broker or Investment Adviser, http://www.nasaa.org/2709/how-to-checkout-your-broker-or-investment-adviser/.

Older Americans deserve 

a consumer financial 

marketplace that is transparent 

and fair, where they can easily 

compare among products and 

services to determine those 

that best meet their needs. 
51 CONSUMER FINANCIAL PROTECTION BUREAU

provide seniors with simple ways to check (a) whether the financial advisor that they are dealing 

with actually has the senior designation he/she claims to have and (b) the requirements for 

obtaining that senior designation, so the senior can decide whether the designation has validity 

and substance. In addition, seniors should have access to a toll-free number that would provide 

them an alternative way to obtain this information. An authoritative, unbiased, and 

comprehensive resource would help consumers make meaningful comparisons among advisers. 

6.1.2 Tracking and Data Collection

The SEC may wish to consider establishing a mechanism to capture complaints 

and enforcement actions against senior designation holders and consider 

reporting the data to designation providers consistent with and to the extent 

allowed by the Commission’s legal obligations. 

The Bureau believes that adoption of this recommendation may help:

§ Minimize consumer harm and financial loss by enhancing the ability of consumers to 

protect themselves from unscrupulous designees;

§ Provide regulators with a comprehensive, global resource to monitor designee conduct; 

§ Enable honest and qualified designees to distinguish themselves in the marketplace.

6.1.3 Disclosure

Congress and the SEC may wish to consider requiring financial professionals who 

utilize a senior designation to provide a disclosure to clients and prospective 

clients.

For example, the senior designation disclosure could require information that explains (1) the 

adviser’s qualifications; (2) the meaning of senior-specific certifications; and (3) how consumers

may obtain further information concerning the advisor’s qualifications and disciplinary 

background.

Additionally, Congress and the SEC may wish to consider requiring that other related 

information should be disclosed by the adviser to the extent not already required by existing 

law. For instance advisers might be required to disclose the fees and compensation, including 

any commissions or performance-based compensation that the adviser receives and to discuss 

the duty of care they owe the consumer, including whether the adviser will act as a fiduciary to 

the client.
52 CONSUMER FINANCIAL PROTECTION BUREAU

To the extent there are existing disclosures already being distributed that contain at least some 

of the information called for in this recommendation, regulators may consider whether a 

combined disclosure or a separate brochure regarding senior designations is preferable.

The Bureau believes that adoption of this recommendation may help:

§ Ensure that consumers have access to comprehensive, relevant, and understandable 

information to understand the meaning of different senior designations;

§ Ensure consumers have access to comprehensive and standardized information to make 

comparisons among different senior designations;

§ Ensure consumers have access to relevant and understandable information to enable 

consumers to determine how the different designees’ qualifications and standards of care

relate to the consumers’ financial needs and goals and to identify the adviser most 

appropriate for the consumers’ needs; and

§ Reduce the barriers to older consumers’ locating relevant and understandable 

information about senior designations.

6.2 Additional Recommendations

6.2.1 Acquisition of Senior Designations

Policymakers may wish to consider providing minimum standards for acquiring 

senior designations and the amount of training necessary to earn the designation, 

including requiring standardized testing and specific number of units of 

education. This would improve the consistency and quality of designations. 

Policymakers may also wish to consider prohibiting the use of senior designations 

issued by any non-accredited conferring organization.106

 106 The Bureau anticipates that the relevant federal and state regulators and policymakers would determine standards 

for accreditation appropriate for the entities that they regulate. For instance, the NASAA and NAIC model rules and 

regulations provide guidance by recognizing the American National Standards Institute, the National Commission for 

Certifying Agencies, and organizations that are on the U.S. Department of Education’s list entitled ‘“Accrediting 
53 CONSUMER FINANCIAL PROTECTION BUREAU

The Bureau believes that adoption of this recommendation may help:

§ Minimize the potential for consumer harm and financial loss by ensuring minimum, 

consistent standards for acquiring senior designations;

§ Reduce consumer confusion by reducing the wide variation in quality for senior 

designations in use;

§ Provide regulators with consistent standards to monitor the senior designation 

marketplace; and

§ Establish a level playing field for senior designations across industries.

6.2.2 Conduct of Senior Designees

Policymakers may wish to consider providing minimum standards of conduct for 

any person holding a senior designation. 

For example policymakers may wish to consider:

a. Prohibiting the misleading use of senior certifications to the extent that such 

practices are not already prohibited by federal or state law.

b. Prohibiting harmful acts known to be targeted toward or particularly detrimental to 

seniors, such as prohibiting designees from recommending or selling unregistered 

investment products (such as private offerings) to investors at group sales events. 

c. Specifying standards for advertising and customer communications for holders of 

senior specific designations, to the extent such standards do not exist, to avoid 

misleading consumers with respect to the nature of the designation, expertise, or 

purpose of an event, including prohibiting senior designees from characterizing sales 

events as educational seminars, and selling financial products and services at events 

that are advertised, promoted or described as educational or informational events.

 Agencies Recognized for Title IV Purposes.”’ See e.g., NASAA Model Rule On The Use Of Senior-Specific 

Certifications And Professional Designations, Adopted March 20, 2008 at http://www.nasaa.org/wpcontent/uploads/2011/07/3-Senior_Model_Rule_Adopted.pdf; and Model Regulation On The Use Of Senior Specific 

Certifications And Professional Designations In The Sale Of Life Insurance And Annuities (October 2008)

http://www.naic.org/store/free/MDL-278.pdf.
54 CONSUMER FINANCIAL PROTECTION BUREAU

The Bureau believes that adoption of this recommendation may help:

§ Minimize consumer harm and financial loss by reducing consumer confusion and 

potential for fraud;

§ Provide regulators with consistent standards to monitor the senior designation 

marketplace and hold designees accountable;

§ Establish a level playing field for senior designations across industries; and

§ Provide older consumers with an enhanced level of protection in light of this 

population’s unique vulnerabilities and this marketplace’s history of exploitation. 

6.2.3 Enforcement

a. Recommendation to SEC and States: policymakers may wish to consider increasing 

use of existing supervision and enforcement authority to enjoin and penalize 

misleading or other improper conduct by a holder of a senior designation.

b. Recommendation to States: where private remedies do not currently exist, 

policymakers may wish to consider providing consumers with a private right to seek 

appropriate relief for improper conduct in connection with the use of senior 

designations.

The Bureau believes that adoption of these recommendations may help:

§ Establish a level playing field for senior designations across industries;

§ Provide older consumers with an enhanced level of protection in light of their unique 

vulnerability to exploitation; and

§ Provide consumers with tools to deter misconduct and seek redress for harm suffered. 

6.2.4 State Disclosures

State policymakers may wish to consider requiring financial professionals who utilize a senior 

designation to provide a disclosure to clients and prospective clients as described in section 6.1.3

above. 
55 CONSUMER FINANCIAL PROTECTION BUREAU

7. Conclusion

Older Americans deserve a consumer financial marketplace that is transparent and fair, where 

they can easily compare among products and services to determine those that best meet their 

needs. The Bureau found that the current marketplace for financial advisers who hold senior 

designations generally does not provide seniors with that option. Instead, consumers face 

numerous obstacles to assessing the legitimacy of a designation and verifying the expertise of 

persons who hold these designations. The lack of consistent and minimum standards to acquire 

and use a senior designation and the increased likelihood that seniors will accept advice from 

someone holding a designation increases the potential for seniors to be misled or even 

defrauded by someone holding a designation.

For these reasons, the CFPB, in response to Congress’ directive in the Dodd-Frank Act, offers 

the recommendations in this report for federal and state policymakers’ consideration. 
56 CONSUMER FINANCIAL PROTECTION BUREAU

APPENDIX A: METHODOLOGY

The purpose of this report is to support the Bureau’s best practices recommendations on senior 

designations. To achieve this aim, the Bureau had the following three objectives: (1) examine 

how senior designations are obtained and used by advisers in the financial services industry, (2) 

explore the range of program requirements for senior designations in use, and (3) identify 

essential consumer protection concerns associated with the use of these credentials.

The Bureau conducted multiple in-depth interviews and meetings with over 60 individual 

stakeholders and experts to gain insight into consumer protection concerns about senior 

designations. 

Interviews and meetings were held with staff from the SEC, FINRA, NASAA, NAIC, the Federal 

Insurance Office, National Association of Insurance and Financial Advisors, and numerous state 

securities administrators to discuss the regulatory oversight of senior designation holders. 

Interviews were also conducted with numerous financial education academics, policy experts 

from conferring organizations, and compliance professionals from brokerage and insurance 

firms. These interviews helped the Bureau to better understand the training, testing, and 

conduct requirements of those holding senior designations. They also provided insight for how 

financial firms analyze senior designations to approve or deny their use. 

The Bureau interviewed subject matter experts at AARP, American Financial Advisors, the 

Association for Financial Counseling, Planning, Education, the Financial Planning Association, 

the Insured Retirement Institute, Women’s Institute for a Secure Retirement, and state law 

enforcement officials. These interviews allowed Bureau staff to acquire a broad appreciation for 

the consumer protection issues triggered by senior designation use, as well as a deeper 

understanding of the challenges financial professionals face when working with seniors. 

The Bureau sought direct engagement with the public in two forums. First, the Bureau posted a 

Request for Information in the Federal Register, requesting public input on several key 

questions relating to senior financial exploitation. Several of these questions concerned senior 

designations directly. Over one thousand comments were received. Second, Bureau staff 

conducted public listening sessions in Washington, DC, and San Francisco, CA. The listening 

“roundtables” gave consumers, advocates, and industry professionals the opportunity to share 

their thoughts and concerns on senior designations directly in dialogue with the Bureau. 
57 CONSUMER FINANCIAL PROTECTION BUREAU

Finally, Bureau staff completed an extensive literature review. Sources included state and 

federal reports, testimony, academic analysis, white papers, regulatory alerts and notifications, 

publications from consumer advocacy groups, and press.
58 CONSUMER FINANCIAL PROTECTION BUREAU

APPENDIX B: SENIOR DESIGNATIONS TABLE

The table is provided for illustrative purposes only, and the Bureau is not responsible for and 

cannot verify information from sources other than from the Bureau. The Bureau does not 

warrant or guarantee the accuracy or completeness of the information. Nor does the Bureau 

endorse any particular credential or advisor. And, of course, consumers should not rely on a 

credential alone when selecting an advisor.

107

Designation Required 

coursework Accreditation

Online 

methods to 

check any 

designee's 

status and 

submit 

complaints

Website 

discloses 

disciplinary 

procedures 

for designee 

misconduct

Accredited 

Estate Planner 

(AEP)

Two graduate level 

courses as 

components of 

masters or 

doctorate program

Regionally 

accredited 

curriculum

Online Yes

Accredited 

Pension 

Administrator 

(APA)

Four self-study 

courses

Not accredited No No

Accredited 

Pension 

Representative 

(APR)

Four self-study 

courses

Not accredited No No

Accredited 

Retirement 

Advisor (ARA)

None (Optional 

online study guide 

is available)

Not accredited No No

Accredited 

Retirement Plan 

Consultant 

(ARPC)

None (Optional 

online study guide 

is available)

Nationally 

accredited 

(NCCA)

No No

 107The information in the tables was derived from the information appearing on the designation conferring 

organizations’ websites in March 2013. The four criteria featured in the tables were selected for two reasons: (1) the 

NASAA and NAIC model rules devote guidelines to related criteria, and (2) financial education experts and consumer 

advocates prioritized these criteria in interviews with the Bureau. See NASAA, Model Rule On the Use of SeniorSpecific Certifications and Professional Designations (2008) available at http://www.nasaa.org/wpcontent/uploads/2011/07/3-Senior_Model_Rule_Adopted.pdf; NAIC, Model Regulation at 

http://www.naic.org/documents/committees_a_suitability_reg_guidance.pdf. 
59 CONSUMER FINANCIAL PROTECTION BUREAU

Accredited 

Retirement Plan 

Specialist 

(ARPS)

None (Optional 

online study guide 

is available)

Not accredited No No

Board Certified in 

Estate Planning 

(BCE)

Now the “CES” 

designation, but 

still honored by 

conferring 

organization

Certified 401(k) 

Professional 

(C(k)P)

Three levels of 

coursework with

online and 

classroom options

Curriculum 

offered at 

regionally 

accredited 

institution

No No

Certified Asset 

Protection 

Planner (CAPP)

24 hours of 

classroom or 

online study

Not accredited No No

Certified Estate 

and Trust 

Specialist 

(formerly Board 

Certified in 

Estate Planning) 

(CES)

Six self-study 

modules Not accredited No No

Certified Estate 

Planner (CEP)

Five to six month 

average combined 

study of eight

modules (Online 

and classroom)

Not accredited Online Yes

Certified 

Financial 

Gerontologist 

(CFG)

Self-study program 

of six courses Not accredited No No

Certified 

Financial Planner 

(CFP)

21 semester hours 

in financial 

planning topics

Nationally 

accredited 

(NCCA)

Online Yes

Certified 

Healthcare 

Financial 

Professional 

(CHFP)

None (Optional 

online study guide 

is available)

Not accredited No No

Certified Income 

Specialist (CIS)

Six module selfstudy program to 

be completed 

within 15 weeks

Not accredited No No

Certified Pension 

Consultant 

(CPC)

None (Candidates 

must pass eight 

exams)

Not accredited Online Yes

Certified 

Retirement 

Counselor (CRC)

None (Self-study 

with optional study 

guides available 

for purchase)

Nationally 

accredited 

(NCCA)

Online Yes
60 CONSUMER FINANCIAL PROTECTION BUREAU

Certified 

Retirement 

Financial 

Advisors (CRFA)

Optional four-day 

classroom course 

or self-study 

course

Nationally 

accredited 

(NCCA)

Online Yes

Certified 

Retirement 

Planner (CRP)

Seven units of 

CRP preliminary 

and advanced 

coursework and 

five retirement 

planning 

techniques 

seminars

Not accredited No* No

Certified 

Retirement 

Services 

Professional 

(CRSP)

Institute of 

Certified Bankersapproved 

employee 

benefit/retirement 

services training 

program (This 

condition is waived 

if the candidate 

has five or more 

years of 

experience in 

ERISA and IRS 

Code/Regulations)

Not accredited No No

Certified Senior 

Advisor (CSA)

CSA training 

course, plus one 

class from 

approved list of 

pre-requisites

Nationally 

accredited 

(NCCA)

Online Yes

Certified 

Specialist in 

Estate Planning 

(CSEP)

Six core and two 

elective self-study 

courses

Not accredited No Yes

Certified 

Specialist in 

Retirement 

Planning (CSRP)

Five core and two 

elective courses Not accredited No Yes

Certified Wealth 

Preservation 

Planner (CWPP)

24 hours of 

classroom or 

online study

Not accredited No No

Chartered 

Advisor for 

Senior Living 

(CASL)

15 semester hours 

of specified 

coursework related 

to senior clients 

and financial 

planning

Regionally 

accredited Online Yes

Chartered Estate 

Planning 

Practitioner 

(CEPP)

Three segments of 

self-study Not accredited No No
61 CONSUMER FINANCIAL PROTECTION BUREAU

Chartered 

Healthcare 

Consultant 

(CHC)

Six courses, 18 

semester hours

Regionally 

accredited Online Yes

Chartered Life 

Underwriter 

(CLU)

Five courses, 15 

semester credit 

hours

Regionally 

accredited Online Yes

Chartered 

Retirement 

Planning 

Counselor 

(CRPC)

Online instructor 

led or self-study 

course. Course is 

equivalent of up to 

three 

undergraduate 

credit hours

Regionally 

accredited Online Yes

Chartered 

Retirement Plans 

Specialist 

(CRPS)

Online instructor 

led or self-study 

course. Course is 

equivalent of up to 

three 

undergraduate 

credit hours

Regionally 

accredited Online Yes

Chartered Senior 

Financial Planner 

(CSFP)

Three-day inperson course

Not accredited Online and 

mail-in Yes

Chartered Trust 

and Estate 

Planner (CTEP)

None (Designation

awarded for 

previously 

completed 

education)

Accredited by 

the 

Accreditation 

Council for 

Business 

Schools and 

Programs

Online Yes

Graduate 

Certificate in 

Retirement 

Planning

Four self-study 

courses equivalent 

to 12 semester 

credit hours

Regionally 

accredited Online Yes

Master Certified 

Estate Planner 

(MCEP)

Classroom or selfstudy course 

(Eight modules)

Not accredited Online Yes

Personal 

Retirement 

Planning 

Specialist 

(PRPS)

Six weeks of selfstudy with 24 

hours of web cast 

recorded lectures

Not accredited Online Yes

PLANSPONSOR 

Retirement 

Professional 

(PRP)

Online 

coursework, twoday onsite seminar 

and attendance at 

a multi-day, 

instructor-led 

training session

Not accredited No* Yes
62 CONSUMER FINANCIAL PROTECTION BUREAU

Professional Plan 

Consultant (PPC)

16 hour 401 (k)

training program

Instruction 

offered through 

regionally 

accredited 

Robert Morris 

University

No* No

Qualified 401(k) 

Administrator 

(QKA)

None (Candidates 

must pass four 

exams)

Not accredited Online Yes

Qualified 

Financial Planner 

(QFP)

None (Meta 

designation

intended to reduce 

confusion by 

qualifying financial 

planning 

designations 

according to 

standards)

Not accredited Online and 

mail-in Yes

Qualified 

Pension 

Administrator 

(QPA)

None (Candidates 

must pass six 

exams)

Not accredited Online Yes

Qualified Plan 

Financial 

Consultant 

(QPFC)

None (Candidates 

must pass two 

exams)

Not accredited Online Yes

Registered 

Employee 

Benefits 

Consultant 

(REBC)

Three required 

courses related to 

retirement 

planning and 

group benefits

Regionally 

accredited Online Yes

Registered 

Financial 

Consultant (RFC)

Two self-study 

courses

Not accredited No* Yes

Registered 

Financial Planner 

(RFP)

None Not accredited No* Yes

Registered 

Paraplanner (RP)

Completion of an 

internship and 10-

module course 

(Self-study or 

instructor-led)

Regionally 

accredited Online Yes

Retirement 

Income Certified 

Professional 

(RICP)

Three courses, 

nine semester 

credit hours

Regionally 

accredited Online Yes

Retirement 

Management 

Analyst (RMA)

Pass a Retirement 

Income Industry 

Association 

Approved 

Education 

Program

Not accredited Online Yes
63 CONSUMER FINANCIAL PROTECTION BUREAU

Retirement Plans 

Associate (RPA)

Two retirement 

planning courses 

and one elective

Not accredited No No

* Online search function does not specify if it verifies total universe of members or merely searches for listed 

members. Does not indicate whether members are identified as in good standing