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A Financial Planning Insurance Mandate: A Modest Proposal


Someone who has followed the Lab for several years asked if we could post an op-ed piece that was published in Financial Planning Magazine in 2013. This is a bit controversial, but maybe it may help financial planners and investment advisers develop systems to bring more people into contact with financial planners/advisers …

To be a financial planner in the 21st Century is a wonderful thing. What other field of practice brings together diverse and competing practitioners—financial advisors, planners, counselors, therapists, and brokers—to help ensure the financial stability and security of American families? No other profession comes close to serving the interests of both Wall Street and Main Street in relation to money management services, wealth accumulation and protection planning, and legacy counseling. When viewed holistically, the financial planning profession is robust and profitable. Further, the profession’s net addition to the general welfare of the country is positive. Financial planning practitioners, on the whole, improve the social good.

Amidst this glowing recognition of the profession, it is important to recognize a distinct and important debate that is occurring almost daily within certification, association, and regulatory establishments, as well as colleges and universities that teach financial planning. The debate has potentially far reaching and negative implications for financial planning practitioners. On one side of the debate are consumer activists who are begging to ask why the profession has failed to transfer the benefits of financial planning to households at all levels of the socioeconomic spectrum. Stated another way, they ask if the financial planning process is so effective in changing behavior, why are financial planning services biased towards high wealth clientele?

Sitting on the other side of the debate are those contend, conceptually, that financial planning has the power to help all American households, but the way in which planning services are currently provided—either through a fee or commission structure—simply does not allow financial planners the freedom to work with clientele who may not at this time have the financial stability to “pay” for planning. In effect, their argument comes down to an implicit acknowledgement that as presently practiced, the financial planning process is an effective tool only for wealthier Americans.

This is not to say that the leadership within the financial planning profession agrees with those who believe financial planning is a service for the wealthy. In fact, leading practitioners and oversight bodies have, over the past several years, taken steps to encourage financial planners to at least appear to be serving underserved markets. The latest involves promoting pro-bono work; that is, some financial planners volunteer their time during organized “financial planning” events as a way to help those who have financial questions and concerns. While a noble concept, and one well worth pursuing, the actual number of truly needy individuals who receive help, and whether the advice received results in tangible changes in attitudes or behavior, remains totally undocumented; however, there is certainly a “feel good” effect for the financial planning profession.

There is likely another reason leaders within the profession have full heartedly backed pro-bono efforts. The impact of the mortgage crisis and backlash against Wall Street banks has not gone unnoticed. It is only a matter of time before consumer activists and policy makers shift their gaze towards the financial planning profession. The pro-bono movement is one way to divert attention from what is actually occurring within the profession. So, what might a policy maker observe if they started looking into the day-to-day workings of the financial planning profession?

Those scanning the profession from the outside will be stunned. They will find a business model that manages nearly $44 trillion in wealth. They will see a profession dominated by four large firms but encompassing about 136,000 firms overall. [i] They will be astonished at the profitability of financial planning. Revenues in 2012 exceeded $46 billion, with after-tax profits of nearly $8.5 billion. [ii] They will then wonder why it is that less than 25% of all American households are being served by financial planners. The numbers tell the story. Excluding the four largest firms that control approximately 46% of the market (i.e., Morgan Stanley Smith Barney, Wells Fargo, Bank of America, and Amerprise), the ratio of financial planning firms to individuals living in the United States is relatively low at about one firm for every 2,400 persons. The ratio of CFP® professionals to consumers is rough one for every 5,000 people. This compares to one attorney for every 584 Americans or one physician for every 434 people currently residing in the United States. Even if more financial planners suddenly flooded the marketplace, current compensation methods make it nearly infeasible, if not impossible, to work with middle- to low-income households.

Here is the question those in the profession hope is never asked: What is the overall reach and effectiveness of pro-bono and other efforts in helping middle- and low-income consumers? There are simply no data available to answer this question. A reasonable guess would be “not much” to both queries. Isn’t it time, then, that the financial planning profession stand up in a united stance and proclaim the universality of the financial planning process before being forced by consumer activists and policy makers to broaden the market for financial planning? What if there was a way to increase the market penetration of financial planning to all segments of American society without a noticeable decrease in revenues or profits within the profession? Well, such a solution exists.

Here is a modest—but serious—proposal. The foundation of the proposal is based on three assumptions. First, the compensation structure in the U.S. makes it difficult for financial planners to offer services to middle- and low-income households profitably. Second, those in the profession have a sincere desire to encourage financial literacy and wealth development among all Americans. Third, there are many advisors who are interested primarily in helping middle- and low-income households, but they cannot afford, any more than traditional financial planners, to build successful practices in this marketplace. A solution can be found in pay-as-you go social service insurance programs currently in place at the state and federal levels. Consider the following model:

  • A financial planning service insurance fund could be developed through binding contributions by firms operating in the financial planning marketplace.
  • An Office of Financial Planning Reimbursement (OFPR) would then be established
    • The OFPR would allocate the pool of assets on a state-by-state basis that matches geographical firm revenue generation.
    • The OFPR would oversee each state’s pool and distribute planner reimbursements based on an insurance claims model, similar to insurance reimbursements in the social service fields (i.e., a planner diagnoses a financial issue, approval to begin working with the client to address the issue is sought, client advice is provided, documentation of client outcomes is obtained, and reimbursement is made).
      • Approved financial planners could then receive reimbursement on either a flat or sliding reimbursement scale with a maximum cap of, say, $25 per hour.

Obviously, the infrastructure for such a system will need to be developed. Factors such as the size and scope of the OFPR need to be addressed, as do concepts relating to the registration and certification of approved financial planners who wish to receive reimbursement for services. Fortunately, much of the groundwork for infrastructure planning exists in other disciplines, such as health care, marriage and family therapy, psychology, and social work.

A more important question involves how such a plan would be funded. It is unfortunate that the financial planning profession has not been able to develop a planning model that is universally accessible. It is hoped that all firms would voluntarily participate in the funding of a financial planning insurance program, but to believe this will happen without some incentive is naive. As in nearly all cases where industry participants cannot agree on procedures, it may be necessary for regulatory bodies, such as FINRA, the SEC, and NAIC, to mandate binding contributions to an insurance pool. The good news is that on an individual advisor basis, the annual contribution would be modest.

Multiple funding mechanisms exist, but the simplest involves the placement of a levy on managed wealth, in the form of an assets-under-management (AUM) tax. In 2012, financial planners and associated advisors managed $43.8 trillion in household wealth. A flat-tax equivalent to one cent for every $10,000 in AUM would generate $43,800,000 annually as a financial planning insurance pool. This works out to a firm tax of less than $400 annually (by default, the largest firms in the marketplace will absorb close to 50% of all payments made to the insurance pool).  When evaluated on either a firm or employee basis, the binding contribution is likely less than the total labor value associated with pro-bono efforts currently underway throughout the United States; however, for the first time it will be possible to begin providing financial planning services to the broadest spectrum of American households.

Here is an example of how implementation of this proposal might work. Consider the state of Georgia. Financial planning firms located in Georgia generate approximately 1.5% of the total AUM revenue in the United States. As such, Georgia would be entitled, under this proposal, to $657,000. After paying, say, $20,000 to help offset the national OFPR operating budget, approved financial planners in Georgia could access $637,000 in total reimbursements for the year. This works out to over 25,000 hours of billable time at a reimbursement rate of $25 per hour. Obviously, a $25 per hour reimbursement does not provide enough income to support a large financial planning practice. It does, however, provide a base level of income for those interested in providing financial planning and counseling, financial therapy, financial social work, or some life planning solutions in the marketplace as an aspect of a more expansive practice. The reimbursement pool also offers a platform for new advisors to build a practice that includes middle- and low-income households. In the state of Georgia, even a modest financial planning insurance pool of less than three-quarters of million dollars would allow hundreds of advisors to reach out to currently underserved markets.

Those who view this modest proposal adversely will likely couch their arguments in terms of opposing an additional burdensome mandate and another regulatory infringement. In some ways, their argument is spot-on. Had the profession been working proactively to design a platform to increase access to financial planning then a proposal, such as this, would not be needed. There are times—and this is one of them—when regulatory intervention is needed to increase the social welfare for all Americans. Those who believe that financial literacy, wealth generation, and financial numeracy are values that should be held by all Americans, regardless of wealth or income, might find this modest proposal worthy of enactment.

Note: This was originally published as “Financial Planning for All: An Insurance Solution.”

[i] Investment Adviser Association. (2011). Evolution Revolution 2011—A Profile of the Investment Adviser Profession. Washington, DC: IAA.

[ii] Schmidt, D. (2012, March). Financial Planning & Advice in the US: IBIS World Industry Report 52393. Report available at