Statement On Standards In Personal Financial Planning
Personal FinancialPlanning SectionStatement onStandards inPersonal FinancialPlanning ServicesTax. Estate. Retirement. Risk Management. Investments.
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Statement on Standards in PersonalFinancial Planning Services(To supersede the Statement on Responsibilities in Personal Financial Planning Practice [AICPA,Professional Standards, PFP Sec. 100])Revised, January 2015, to reflect conforming changes necessary due to the issuance of the revised AICPACode of Professional Conduct, effective December 15, 2014.
AcknowledgmentsResponsibilities in Personal Financial Planning Services Task ForceClark Blackman II, Past Chair–PFP Executive Committee and Past Chair–Task ForceDirk Edwards, Past Chair–PFP Executive Committee and Chair–Task ForceRichard Fohn, Past Chair–PFP Executive CommitteeCharles Kowal, Past Member–PFP Executive CommitteePersonal Financial Planning Services Standards Advisory Task ForceDirk Edwards, ChairNancy Hyde, Past Member–Tax Practice Responsibilities CommitteeAnthony King, Past Member–PCPS Executive CommitteeDavid McIntee, Past Member–PCPS Executive CommitteeWilliam Pirolli, Past Chair–PCPS Executive CommitteeThomas Purcell, Tax Practice Responsibilities CommitteeNorma Schrock, Chair–Tax Practice Responsibilities CommitteeAICPA staffAnthony Pugliese, Senior Vice President and Chief Operating OfficerMichael Buddendeck, General CounselEdward Karl, Vice President, TaxationJames Metzler, Vice President, Small Firm Interests; Public Practice and Global AlliancesJeannette Koger, Vice President, Member Specialization & CredentialingAndrea Millar, Senior Technical Manager, Personal Financial PlanningSarah Bradley, Technical Manager, Personal Financial Planning
Contents2Foreword3Statement on Standards in PersonalFinancial Planning Services3Scope3Applicability4Objective4Authority of statement4Definitions5Requirements5General professionalresponsibilities6Responsibilities of members inPFP engagements7Planning the PFP engagement8Obtaining and analyzinginformation8Developing and communicatingrecommendations9Implementation engagements9Monitoring and updatingengagements10 Working with other serviceproviders10 Using advice provided by otherservice providers11 Application material1
ForewordThe Personal Financial Planning Executive Committee (PFP EC) has issued Statement on Standardsin Personal Financial Planning Services No. 1 (the standard) to provide guidance to members and aframework for delivering PFP services with the highest levels of integrity, professionalism, objectivity,and competence so that a CPA financial planner can serve the best interests of his or her clients andthe public. The PFP EC is the senior committee of the AICPA designated to promulgate enforceablestandards of PFP practice. 1The standard applies to all members providing PFP services regardless of the jurisdictions in whichthey practice. Interpretations of the standard may be issued by the PFP EC as guidance to assist inunderstanding and applying the standard. The PFP EC interpretations are recommendations on theapplication of the standard. The standard and its interpretations are intended to complement other laws,regulations, and professional standards of PFP practice.The standard is written in as simple and objective a manner as possible. However, by their nature,practice standards provide for an appropriate range of behaviors and need to be interpreted to address abroad range of personal and professional situations. Accordingly, enforcement of these rules, as part ofthe AICPA’s Code of Professional Conduct “General Standards Rules” (AICPA, Professional Standards, ETsec. 1.300.001 and 2.300.001), and “Compliance with Standards Rules” (AICPA, Professional Standards,ET sec. 1.310.001 and 2.310.001) as well as paragraphs .02-.05 of the “Application of the AICPA Code”(AICPA, Professional Standards, and ET sec. 0.200.020), will be undertaken on a case-by-case basis.1.2Per AICPA Bylaw Section 360R, Implementing Resolutions Under Section 3.6 Committees, the Personal Financial Planning ExecutiveCommittee (PFP EC) is an AICPA senior committee. The PFP EC is designated as a body that may promulgate technical standards under“General Standards Rules” (AICPA, Professional Standards, ET sec. 1.300.001 and 2.300.001)and “Compliance with Standards Rules” (AICPA,Professional Standards, ET sec.1.310.001 and 2.310.001).
Statement on Standards inPersonal Financial PlanningServicesScopeApplicability1.4.The Statement on Standards in PersonalFinancial Planning Services No. 1 (the standard)addresses the responsibilities of AICPA members(members) who are described in paragraph 4that follows. The standard applies when personalfinancial planning (PFP) services are provided,even if part of another engagement.2. The standard establishes the applicablestandards for members with regard to PFPengagements. (Ref: par. A1)Nature of PFP services3.PFP is the process of identifying personalfinancial goals and resources, designingfinancial strategies, and making personalizedrecommendations (Ref: par. 12) (whether writtenor oral) that, when implemented, assist the clientin achieving these goals. This process mayinclude implementation of recommendations ormonitoring or updating the engagement. PFPservices encompass one or more of thefollowing activities:a.Cash flow planningb.Risk management and insurance planningc.Retirement planningd.Investment planninge.Estate, gift, and wealth transfer planningf.Elder planningg.Charitable planningh.Education planningi.Tax planningThe standard applies when a member providesPFP services as defined in paragraph 12, and (Ref:par. A2)a.represents to the public or clients that themember provides PFP services,b.engages in activities that would requireregistration as an investment adviser underfederal or state law1, orc.sells a product as a result of an engagement.5. The standard does not supersede other applicableAICPA professional standards, such as(Ref: par. A2-A3, A11)1.a.the Statement on Standards for Accountingand Review Services (SSARS) No. 6, Reportingon Personal Financial Statements Includedin Written Personal Financial Plans (AICPA,Professional Standards, AR sec. 600) withregard to the compilation of personal financialstatements;b.the Statements on Standards for Tax Services(SSTSs) with regard to tax services; andc.the Statement on Standards for ValuationServices (SSVS) No. 1, Valuation of aBusiness, Business Ownership Interest,Security, or Intangible Asset (AICPA,Professional Standards, VS sec. 100) withregard to valuation services.Reference The CPA’s Guide to Investment Advisory BusinessModels published by AICPA.3
ObjectiveDefinitions6.12. For purposes of the standard, the following termshave the meanings attributed:The standard provides authoritative guidance andestablishes enforceable standards for memberswho provide PFP services to assist them infulfilling their professional responsibilities.Authority of the statement7.8.9.The standard contains requirements designedto enable the member to meet the statedobjective. It also includes related guidance inthe form of application and other explanatorymaterial that provides context relevant to a properunderstanding of the standard and definitions.The requirements of the standard are expressedusing the word should. If a standard providesthat a member “should” perform an action, thenunless prevailing facts and circumstances dictateotherwise, this action is required. If a standardprovides that a procedure or action is one thatthe member “should consider,” the considerationof the procedure or action is required, whereascarrying out the specified procedure or actionis not. The professional requirements of thestandard are to be understood and applied in thecontext of the explanatory material that providesguidance for their application.The “Application” section and other explanatorymaterial provide further explanation of therequirements and guidance for carrying them out.10. The words may, might, and could, among others,are used to describe actions and procedures thatare recommended but not required. Although suchguidance does not, in itself, impose a requirement,it is relevant to the proper application of therequirements.11. The standard includes, under the heading“Definitions,” a description of the meaningsattributed to certain terms for purposes of thestandard. These are provided to assist with theconsistent application and interpretation ofthe standard and are not intended to overridedefinitions that may be established for otherpurposes, whether by law or regulation.4Personal financial planning services. Theprocess of identifying personal financial goalsand resources, designing financial strategies,and making personalized recommendations that,when implemented, assist the client in achievingthese goals. (Ref: par. 3)Personal financial planning engagement. Anengagement in which a member provides PFPservices and the standard applies. (Ref: par. 3-4)Implementation engagement. A PFPengagement that involves assisting the client intaking action on recommendations developedduring the PFP engagement.Monitoring engagement. A PFP engagementthat involves tracking and communicating theclient’s progress in achieving established PFPgoals.Updating engagement. A PFP engagement thatinvolves revising the client’s existing financialplan and financial planning recommendations asthe member and client agree upon.Personalized recommendation. Financial advicedirecting a client to take action based on theclient's personal financial information disclosedto the member. (Ref: par. 3)
RequirementsGeneral professional responsibilities13. The member should read the entire standard,including its application and other explanatorymaterial, to understand its objective and applyits requirements properly.14. The proper application of the requirementsestablished by the standard is expected toprovide a sufficient basis for the achievement ofthe objective. However, because circumstancesvary widely and all such circumstances cannotbe anticipated, the member should considerwhether, due to the existence of particularmatters or circumstances, procedures inaddition to those required by the standard areneeded to meet the stated objective.16. The member should consider applicableinterpretive publications when providingPFP services. (Ref: par. A5)Independence and PFP services17. If PFP services are performed for a client forwhich the member or member’s firm alsoperforms an “attest engagement” (AICPA,Professional Standards, ET sec. 0.400.04),the member should meet the requirementsof the “Nonattest Services” subtopic (AICPA,Professional Standards, ET sec. 1.295) underthe “Independence Rule” (AICPA, ProfessionalStandards, ET sec. 1.200.001), so as not to impairthe member’s independence with respect tothe client.15. The member must comply with eachrequirement of the standard unless,a.in the circumstances of the engagement,the requirement is not relevant becauseit is conditional, and the condition doesnot exist.b.the member judges it necessary to departfrom a requirement. In such circumstances,the member should perform alternativeprocedures to achieve the intent of thatrequirement and document the justificationfor that departure.5
Responsibilities of members in PFP engagements18. The member should comply with relevant ethical requirements. (Ref: par. A7)19. The member should possess a level of knowledge of PFP principles and theory, and a level of skill in theapplication of such principles, that will enable him or her to (Ref: par. A8)a.Identify client goals and objectives;b.Gather and analyze relevant information;c.Consider and apply appropriate planning approaches and methods; andd.Use professional judgment when developing financial recommendations.20. The member should evaluate whether any conflicts of interest exist with regard to the engagement as follows:(Ref: par. A9-A10)a.If the member determines conflicts of interest exist, the member should determine whether theengagement can be performed objectively.b.If the member determines the engagement can be performed objectively, the member should disclose allknown conflicts of interest and obtain consent as required under the “Conflicts of Interest” interpretations(AICPA, Professional Standards, ET sec. 1.110.010 and 2.110.010) under the “Integrity and Objectivity Rule”(AICPA, Professional Standards, ET sec. 1.100.001 and 2.100.001).c.If the member determines that the engagement cannot be performed objectively, the engagement shouldbe terminated.21. The member should comply with applicable federal, state, and other laws and regulations. The membershould comply with professional standards applicable to the PFP engagement unless superseded by laws orregulations. When there is a conflict between the standard and laws or regulations, the laws or regulations willprevail unless less stringent than the standard. (Ref: par. A11-A12)22. Prior to beginning the engagement, and throughout the engagement as circumstances dictate, the membershould disclose in writing all compensation the member and the member’s firm or affiliates will receive forservices rendered or products sold (Ref: par. A6, A13). The disclosure should includea.the method of compensation, including the impact of indirect compensation;b.the amount of compensation;c.the time period over which compensation will be received; andd.the compensation, including noncash benefits, received by the member for referrals to other providers.23. If compensation alternatives are offered, the member should disclose the differences in these alternativesin writing.6
Planning the PFP engagement (Ref: par. A14-A15)24. The member should document and communicate to the client the scope and nature of services to be providedand disclose the member’s agreed upon compensation for such services. This communication should bedocumented in the file and include descriptions of the following when applicable to the engagement:a.Engagement objectivesb.Scope of services to be providedc.Roles and responsibilities of the member, client, and other service providersd.Timing of the engagemente.Scope limitations and other constraintsf.Conflicts of interest (Ref: par. 20)g.Responsibility, or lack thereof, for helping the client implement planning decisionsh.Responsibility, or lack thereof, for monitoring the client’s progress in achieving goalsi.Responsibility, or lack thereof, for updating the plan and proposing new action25. The member should evaluate the appropriateness of the original engagement as the engagement proceedsand document and communicate needed changes to the client.26. If the member is aware of a service needed to complete the engagement and does not, or will not, provide thatservice, the member should limit the scope of the engagement accordingly and recommend that the clientengage another service provider for that service in writing.27. If the client declines to engage another service provider for services identified in paragraph 26, the membershould consider whether this limitation impairs the ability to provide PFP services:a.If the member determines that the ability to meet the standards established by the standard is impaired,the member should terminate the engagement in writing.b.If the member determines that the ability to meet the standards established by the standard is notimpaired, the member should communicate in writing that this limitation could affect the conclusionsand recommendations developed in the engagement.7
Obtaining and analyzing information28. The member should use professional judgment when obtaining and analyzing relevant information necessaryto develop recommendations based on the stated engagement objectives.29. If the member is unable to collect sufficient relevant information to establish a reasonable basis forrecommendations, the engagement scope may be restricted to those matters for which sufficient informationis available. This scope limitation should be communicated to the client in writing, including that this limitationshould be taken into account in the assessment of conclusions and recommendations developed.(Ref: par. A16)30. If sufficient information does not exist to proceed as agreed, the member should terminate or modify theengagement through mutual agreement with the client. This engagement modification or termination shouldbe communicated in writing.31. When analyzing information obtained while performing the engagement, the member shoulda.evaluate the reasonableness of estimates and assumptions that are significant to the plan;b.use assumptions that are appropriate and consistent with each other; andc.consider the interrelationship of various PFP activities (Ref: par. 3).Developing and communicating recommendations (Ref: par. A16-A20)32. The member should establish a reasonable basis for PFP recommendations.33. The member should develop recommendations derived from analyses of relevant information, client goals,and the client’s overall financial circumstances. Even when an engagement addresses a limited number ofpersonal financial goals, the member should consider the client’s overall known financial circumstances.34. The nature and extent of analyses and other procedures performed when establishing a basis forrecommendations are affected by the scope and objectives of the engagement and should be documented.35. The member should communicate to the client the assumptions and estimates that are significant to therecommendations. This should be documented and include the following:8a.A summary of the client’s goalsb.Significant assumptionsc.Estimatesd.Recommendationse.A description of limitations on the work performedf.The recommendations in the engagement should contain qualifications to the recommendations if theeffects of certain planning areas on the client’s overall financial picture were not considered
Implementation engagements(Ref: par. A21-A24)36. The member should document his or herunderstanding of the implementationengagement, including the roles andresponsibilities of the member, the client, andother service providers. This documentationshould include the following:a.A summary of the planning decisionsbeing implementedb.A summary of recommended actions tobe takenc.A description of limitations on thework performed in the implementationengagement37. The member should communicate in writing thelevel of responsibility, if any, for the following:a.Selecting and acquiring productsb.Selecting service providersc.Establishing selection criteriad.Coordinating or reviewing the deliveryof services or products by otherservice providers38. A member who is engaged to establishselection criteria shoulda.b.identify those criteria that are required toaccomplish the client’s objectives, subjectto any constraints that result from theclient’s circumstances or as identified bythe client.assist the client in evaluating the relativeimportance of criteria so that availablealternatives can be compared.c.40. A member who is engaged to assist the client intaking action on planning decisions developed ina PFP engagement in which the member did notparticipate should obtain an understanding ofthe planning decisions made.41. All other relevant guidance under the standardrelating to providing PFP services should befollowed in an implementation engagement.Monitoring and updating engagements(Ref: par. A25-A28)42. In a monitoring engagement, the member shoulddocument the nature and extent of the member’sservices, includinga.the frequency and time period of measuringthe client’s progress toward reaching thestated goals.b.utilization of monitoring criteria thatare appropriate to, and consistent with,the criteria used to establish the goalsbeing monitored.c.the criteria that are important to theachievement of the financial planning goalsbeing monitored.d.the member’s evaluation of progress towardachieving the client’s financial planninggoals, including whether the client’s existingfinancial plan and specific financial planningrecommendations should be updated.43. In an updating engagement, the member shoulddocument the nature and extent of the member’sservices, includinga.the determination of whether the goals,objectives, information, and assumptionsused as a basis for existing planningrecommendations are still valid.b.the evaluation of the impact of revisingrecommendations on the client’s ability toachieve other financial planning goals.39. A member who is engaged to participate inrecommending products shoulda.gather information that establishes areasonable basis for determining whether aproduct meets the selection criteria.b.communicate this evaluation in writing,along with product recommendations.disclose in writing any compensationreceived for recommending products.9
44. All other relevant guidance under the standardrelating to providing PFP services shouldbe followed in a monitoring or an updatingengagement.Working with other service providers45. When referring another service provider to aclient, the member shoulda.consider the professional qualifications ofanother service provider before referring theclient to that service provider;b.disclose, in writing, any compensationreceived for making such referrals; andc.communicate, in writing, the extent to whichthe member will or will not evaluate the workperformed by the service provider.Using advice provided by other serviceproviders46. When the member uses the advice of anotherservice provider when carrying out the PFPengagement, the member should understand theimpact of the service provider’s advice.47. If the member has evaluated the advice of theother service provider, and10a.if the member concurs with the other serviceprovider’s advice, the member need notcommunicate this concurrence to the clientbecause concurrence is implied by its use, orb.if the member does not concur with theother service provider’s advice, the membershould communicate this non-concurrenceto the client in writing.
Application materialScopeA1.The “Compliance with Standards Rules” (AICPA, Professional Standards, ET sec. 1.310.001 and 2.310.001)requires an AICPA member who performs a PFP engagement to comply with standards promulgated by thePersonal Financial Planning Executive Committee (PFP EC). The PFP EC develops and issues standards inthe form of statements through a process that includes deliberation in meetings open to the public, publicexposure of statements, and a formal vote. The standards are codified in AICPA Professional Standards.(Ref: par. 2)Applicability (Ref: par. 3-5)A2.If any of the activities listed in paragraph 3 are provided as part of a PFP engagement, the activity is coveredby the standard and should be considered in conjunction with the requirements set forth in the “Applicability”section (Ref: par. 4). In addition, depending on the nature of the service, other standards may apply (Ref: par.5). For example, any personal income tax services provided as part of a PFP engagement are covered by thestandard and are subject to the SSTSs.A3.Examples of activities not covered by the standard include the following: (Ref: par. 3-5)a.Tax advice: Advising a client regarding his or her income tax matters or gift and estate tax matterswhen PFP services as defined in paragraph 3 are not provided. These services are, however, subjectto the SSTSs.b.Valuation services: Any engagement that would be considered a valuation service under SSVS No. 1when PFP services as defined in paragraph 3 are not provided. These services are, however, subjectto SSVS No. 1.c.Business succession planningd.e.i.Planning to prepare for a vacancy in a key position resulting from a sudden departure, disability, ordeath and no advice is given to an individual.ii.Planning to prepare for the sale to another firm and no advice is given to an individual.Educational discussions or presentations covering PFPi.A workshop presented to a group of company employees on a PFP activity (Ref: par. 3) that does notinclude personalized recommendations.ii.A discussion with an individual that covers one or more PFP activities (Ref: par. 3) that does not resultin a personalized recommendation.Mechanical computationsi.Computation of the current income tax deduction for a client’s contribution of assets to a charitableremainder trust.ii.Computation of the current yield on a client’s investment portfolio.iii. Computation of the gift tax on a transfer of an asset.11
A4. A member may identify and create an analysis of historical spending and income activity for a client as a purelymechanical computation, which would not be considered PFP services. However, extension of this analysisto future periods based on the judgment of the member that entails the use of assumptions and personalizedrecommendations regarding investing would be considered PFP services.General professional responsibilitiesA5. Interpretive publications are not standards on PFP practice. Interpretive publications are recommendationson the application of the standard in specific circumstances. An interpretive publication is issued underthe authority of the PFP EC after all members have been provided an opportunity to consider and comment onwhether the interpretive publication is consistent with the standard. (Ref: par. 16)Responsibilities of members in PFP engagements (Ref: par. 18-23)A6. The member is required to comply with the “Commissions and Referral Fees Rule” (AICPA, ProfessionalStandards, ET sec. 1.520.001). (Ref: par. 22)A7. The member is subject to relevant ethical requirements relating to PFP engagements (Ref: par. 18). Ethicalrequirements consist of the AICPA Code of Professional Conduct, rules of state boards of accountancy fromwhich the member holds a license, and applicable regulatory agencies that are more stringent. The AICPACode of Professional Conduct establishes the fundamental principles of professional ethics, which includethe following:a. Responsibilitiesb. The public interestc. Integrityd. Objectivity and independencee. Due caref. Scope and nature of servicesA8. The “General Standards Rules” (AICPA, Professional Standards, ET sec. 1.300.001 and 2.300.001) explainsthat professional competence means that a member shall “undertake only those professional services that themember or the member’s firm can reasonably expect to be completed with professional competence.”(Ref: par. 19)A9. The “Objectivity and Independence Principle” (AICPA, Professional Standards, ET sec. 0.300.050) states thatobjectivity is a state of mind. The principle of objectivity imposes the obligation to be impartial, intellectuallyhonest, and free from conflicts of interest. (Ref: par. 20)A10. The member is required to comply with AICPA’s Code of Professional Conduct “Conflicts of Interest”interpretations (AICPA, Professional Standards, ET sec. 1.110.010 and 2.110.010). (Ref: par. 20)12
A11.Laws, regulations, and professional standards applicable to engagements to perform PFP services include,but are not necessarily limited to, the following: (Ref: par. 21, A5)a.Investment Advisers Act of 1940; see Securities and Exchange Commission Interpretive Release IA-1092b.Treasury Department Circular No. 230c.State boards of accountancyd.AICPA Code of Professional Conducte.Statements on Standards for Tax Services (SSTSs)f.Statement on Standards for Valuation Services (SSVS) No. 1g.Statement on Standards for Consulting Services No. 1h.Statements on Standards for Accounting and Review Services (SSARS) No. 6i.Maintaining adequate data protection safeguards regarding a client’s nonpublic personal informationj.Maintaining client confidentiality in accordance with the applicable rules of professional conduct andfederal and state laws and regulationsA12. Compliance with the AICPA Code of Professional Conduct depends primarily on the member’sunderstanding and voluntary actions, secondarily on reinforcement by peers and public opinion, andultimately on disciplinary proceedings, when necessary, against members who fail to comply with therules. (Ref: par. 21)A13. The member is not required to follow a standard format when communicating or documentingcommunication.Planning the engagement (Ref: par. 24-27)A14. An understanding of the client may include understanding matters such as the client’s family situation,commitment to the planning process, current cash flow and assets available, personal preferences, andrelationships with other professionals. This understanding may be obtained through comprehensiveinformation gathering or may result from knowledge gained during a long-term relationship with the client.A15.Additional services that require understanding and agreement by the client include the following:a.Implementing plan recommendationsb.Monitoring the client's progress in achieving goalsc.Updating recommendations13
Developing and communicating recommendations (Ref: par. 32-35)A16. Developing a reasonable basis for recommendations involves the following (Ref: par. 29):a.Collecting relevant quantitative and qualitative information. The nature and amount of information willdepend on the scope and complexity of the engagement. This information may include, but is notlimited toi.the client’s goals, existing financial situation, and available resources;ii.nonfinancial factors, such as client attitudes, r
The Personal Financial Planning Executive Committee (PFP EC) has issued Statement on Standards in Personal Financial Planning Services No. 1 (the standard) to provide guidance to members and a framework for delivering PFP services with the highest levels of integrity, professionalism, objectivity,
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