To InFRE CRC^® Certificants, Enrollees and Other Interested Parties:

Since early last summer, several state securities departments have passed or considered a regulation which limits the use of “senior-specific” certifications and designations used by advisors selling financial products and services.  I’d like to take this opportunity to provide an update for CRC^® certificants and request your assistance in supporting our comments pertaining to a model rule recently proposed by North American Securities Administrators Association (NASAA).

NASAA provides regulatory guidance, educational programs and an information-sharing forum for state securities agencies responsible for investor protection.  They recently proposed a model rule on the use of “senior-specific” certifications and professional designations that could be adopted by individual states.  The draft language for the proposed model rule was available for review in early November and public commentary could be submitted up until December 9, 2007.

InFRE strongly supports NASAA’s intent to develop a rule that not only would effectively regulate the use of designations, but also create a more uniform national regulatory environment.  We also agree with NASAA’s general premise that approved designations must meet professional accreditation standards.  However, InFRE, as well as other professional and consumer-oriented organizations, has concerns regarding the broad definition of “accreditation” in the drafted proposed rule.

Earlier in 2007 InFRE began the process of preparing the Certified Retirement Counselor^® (CRC^®) certification to meet the rigorous accreditation standards of the National Commission of Certifying Agencies (NCCA).  These standards include but are not limited to:

• Exam design that assesses the competency of the professional (versus knowledge only) using psychometrically-acceptable and defensible testing instruments and procedures 
• Adherence to a professional code of ethics 
• A disciplinary process overseen by an independent Board of Standards
• Recertification requirements that require professionals to keep their knowledge current

The proposed model rule by NASAA however, would exempt some designations from these important standards when offered by accredited institutions of higher education. We believe that this exemption may be counter-productive to the intent behind the regulation of “senior-specific” designations.

There can be a substantial difference between what might be a non-academically based certificate offered by an accredited institution of higher learning, and an academically-based certification that meets rigorous, independent, third-party, “program accreditation” standards.

Commentaries by InFRE and Dr. Bill Gustafson, professor at our academic partner, Texas Tech University, are available by clicking here; other commentaries may be viewed by clicking on the following link to the NASAA website: http://www.nasaa.org/issues___answers/regulatory_activity/7515.cfm.

Although the time to make public commentary has ended, it is important that NASAA continue to hear from other interested industry professionals while modifications to the drafted proposed model rule are considered.  If you would like to voice support for the comments submitted by InFRE and/or Texas Tech University and/or have other comments, please write or email Melanie Lubin and Rex Staples at the addresses below:

Ms. Melanie Lubin       
OAG, Securities Division 
200 Saint Paul Place      
Baltimore, Maryland  21202-2020
mlubin@oag.state.md.us

Mr. Rex Staples
NASAA
750 First Street, NE Suite 1140
Washington DC  20002
rs@nasaa.org

In the meantime, our efforts to increase the credibility and broad industry acceptance of the CRC^® continue.  On December 21, 2007, the State of Nebraska Department of Banking and Finance identified the CRC^® as one of the certifications and designations acceptable for use by investment adviser representatives and broker-dealer agents in advertising and on business cards and stationery.