September 21, 2021

Via CFP Board website submission @ https://www.cfp.net/ethics/enforcement/Comment-onProposed-Revisions-to-the-Sanction-Guidelines-and-ProceduralRules?_zs=rASTg1&_zl=gg2n7

Certified Financial Planner Board of Standards, Inc.
1425 K Street, NW
Suite 800
Washington DC 20005

Re: SIFMA comment re: CFP Board’s Proposed Revisions To Sanctions Guidelines and Procedural Rules

Dear Sir / Madam:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to comment on CFP Board’s Proposed Revisions to Sanctions Guidelines and Procedural Rules (the “Proposal”).2 The Proposal would increase the sanction for failing to timely report potential misconduct to CFP Board, and for filing an inaccurate Ethics Declaration to CFP Board, from the current sanction of a private censure to a public censure.

SIFMA’s member firms currently employ tens of thousands of CFP® certificants (each a “certificant” and collectively, “certificants”), representing a significant percentage of the total number of certificants, which current stands at nearly 90,000.3 These certificants provide a wide variety of products and services on behalf of their firms, and are subject to extensive regulatory oversight by the SEC, FINRA, and state securities and insurance regulators, among others. They are also subject to robust supervision by the firms with which they are associated.

1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate on legislation, regulation, and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.

2 CFP Board’s Proposed Revisions to Sanctions Guidelines and Procedural Rules (July 28, 2021), available at CFP Board Requests Comments on Proposed Revisions to Sanction Guidelines and Procedural Rules | CFP Board.

3 See CFP® Professional Demographics | CFP Board.