Could The FPA’s Waning Power Given Its Declining Market Share Of CFP Certificants Lead To Its Untimely Demise?

What Is The Membership Association For CFP Certificants?

If you ask the average CFP certificant “as a CFP professional, what is the membership association that represents you and advocates on your behalf” you’d be surprisingly hard pressed to find a clear and consistent answer.

Many might respond the CFP Board, though in point of fact the CFP Board is not actually a 501(c)(6) membership association, but a 501(c)(3) charitable organization whose mission and purpose is to benefit the public by granting the CFP marks and maintaining their standards; the CFP Board grants the CFP certification and is the owner of the associated trademark, but functions closer to a “regulator” of CFP certificants (as an overseer of the use of the CFP trademark) than a membership association representing them. In fact, given some of the CFP Board’s recent enforcement actions, arguably the whole point of having a membership association for CFP certificants would be to specifically represent the interests of CFP professionals against the CFP Board when its policies go awry!

If it’s not the CFP Board, the next logical answer for the membership association for CFP certificants might be the Financial Planning Association (FPA), which came forth from the merger in 2000 of the former International Association of Financial Planning (IAFP), and the Institute for Certified Financial Planners (ICFP), where the latter really was effectively the membership association for CFP certificants, and the former was a broader organization open to anyone who wished to do or support financial planning (regardless of designation). The merger was intended to bring some of the size and capabilities (and dollars) of the IAFP, to the profession-building focus of the ICFP, consolidating their power, dollars, and numbers to advocate on behalf of the profession, and also simplifying the number of membership organizations to which financial planners belonged. At the time of the merger, the FPA was nearly 30,000 members strong.

Yet over the past 14 years, despite a clear Memorandum of Intent created to facilitate the merger and endow the subsequent direction and vision of the organization, the FPA has failed stunningly to live into its role as the membership association for CFP certificants and those who support them.

The FPA’s Declining Market Share Of CFP Professionals (And Total Membership, Too)

Since the merger, the FPA’s total membership headcount declined, from a peak at the merger of almost 30,000, to only about 23,000 currently. On the one hand, this might be “forgiveable” given that the overall number of financial advisors has declined a little over 10% (as estimated by Cerulli) over that time period as well.

Yet this decline in the FPA’s membership count has also come during a time period where the number of CFP certificants has nearly doubled (from about 36,000 to over 70,000), and the percentage of financial advisors who have CFP certification has more-than-doubled (from about 11% to 23%, as the count of CFP certificants is up even as the total number of financial advisors has declined).

As a result of these shifts, the FPA’s estimated market share of the CFP certificants it purportedly represents, which should be its core membership, has plummeted from 50% to under 25%. As of now, it’s estimated that only about 17,500 of its 23,000 members have their CFP certification today (the rest being students, international members, affiliated professionals, and a small number of non-CFP financial advisors), out of a total of more than 70,000 CFP professionals.

By contrast, if the FPA had merely maintained its market-share-percentage of CFP certificants since the merger, and did no more than hitch its wagon to the CFP Board’s growth engine for the past 14 years, the association would/should be more than double its current size, with upwards of 50,000 members in total! To be merely flat in membership since 2000 would actually indicate a significant loss of market share, and the actual decline in membership since 2000 represents a dramatic step backwards in the power of the organization since the merger!

Where Did The FPA Go Wrong Since The IAFP & ICFP Merger?

So given what appeared to be a relatively clear focus for the FPA at the time of the merger, what happened?

In the early years, the FPA (and especially its board) maintained a strong ICFP focus, notably spinning off the old IAFP broker-dealer division into the newly spawned Financial Services Institute in 2003 so the FPA could focus ever more on financial planning issues. The FPA’s early momentum culminated in 2004 when it sued the SEC over the broker-dealer exemption for fee-based accounts (colloquially known as the “Merrill Lynch” rule), and industry articles at the time were declaring that the ICFP’s profession-building CFP-centric focus were winning the contest for the FPA’s soul.

The FPA’s lawsuit turned out to be a resounding victory, as the organization not only sued the SEC... it won the lawsuit 3 years later! In turn, this forced broker-dealers that wanted their advisors to get paid investment management fees while providing ongoing advice to actually become registered as investment advisers, preventing broker-dealers from charging fiduciary-like fees without any fiduciary duty, and spawning the explosive rise in hybrid B-D/RIAs over the past decade or so.

Yet in the midst of its incredible forward momentum in being the membership association for CFP certificants as a burgeoning profession, the FPA started to come under criticism. Some suggested that the board of directors was becoming too RIA- (and former ICFP-member) centric, and needed to be less ICFP-homogeneous. Others raised the question of whether the FPA’s CFP-centric focus was preventing its growth (as total membership had remained stagnant for several years, though arguably that was inevitable early on as the merged organization found its footing), and whether the FPA needed to do a better job drawing in non-CFPs and other various allied/affiliated professionals.

As a result, the composition of the FPA board of directors began to shift, the organization began to adopt a more IAFP-style “big tent” philosophy (anyone who values financial planning is welcome under the big tent, with less focus specifically on CFP certificants), with the unfortunate outcome that even as the FPA won the lawsuit with the SEC, the victory may have marked the zenith of FPA’s power (and its membership count), both of which have been waning ever since as its focus has wandered.

The problem with this “swinging of the pendulum” back towards the IAFP in the mid-2000s is that it left the FPA in a deadly “no-man’s land” for membership; the organization was too CFP-centric to attract non-CFP financial advisors who didn't feel welcome (which today are estimated at only about 5% of total membership), but backed too far away from its CFP-centric messaging to be a beacon for CFP certificants either who were often turned off by the low bar necessary to become a member (driving down CFP market share from over 50% to under 25%). The end result: by trying to adjust its membership requirements to the lowest common denominator, the FPA has simultaneously become less appealing for CFP certificants and non-CFPs as well, and thus membership has been in decline, despite the fact that it was intended to be the membership association for a base of CFP certificants that has doubled over the same time period (and while some have suggested that FPA’s fiduciary positioning may have also “cost” it some members, it’s difficult to see how given that the CFP Board adopted its own fiduciary standard in 2008 and has continued to grow throughout!)!

FPA Bylaws And A Return To CFP Centricity... In Name Only?

In a seeming acknowledgement of its problem – and how far the pendulum had swung in the wrong direction – the FPA “recommitted” in 2012 to its ICFP roots, and ICFP-founder P. Kemp Fain’s vision of “one profession, one designation”, as incoming CEO Lauren Schadle took the reins.

One the one hand, the fact that the FPA had to “recommit” to this vision at all is somewhat stunning, as part of the legacy of the merger Memorandum of Intent was the ICFP’s codification of the FPA’s CFP-centricity into the bylaws of the organization itself. Accordingly, Article II of the FPA’s bylaws state (and have since the merger):

Article II – Purposes

Section 2.1. The purposes of the Association shall be to serve the needs of its members and to establish the value of financial planning and the success of the financial planning profession. This Association is organized exclusively for one or more of the purposes as specified in Section 501(c)(6) of the Internal Revenue Code of 1986.

Section 2.1.1. The thrust of FPA’s message to the public will be that everyone needs objective advice to make smart financial decisions and that when seeking the advice of a financial planner, the planner should be a CFP licensee.

Section 2.1.2. The thrust of FPA’s message to the financial services industry will be that all those who support the financial planning process are valued equally as members in FPA and that anyone holding themselves out as a financial planner should seek the attainment of the CFP mark. FPA will commit to assisting financial planners who are interested in pursuing the CFP designation.

Section 2.1.3. FPA will proactively advocate the legislative, regulatory and other interests of financial planning and of CFP licensees. FPA will encourage input from all of its members in developing its advocacy agenda. It is the intent of FPA not to take a legislative or regulatory advocacy position that is in conflict with the interests of CFP licensees who hold themselves out to the public as financial planners.

Notably, this FPA focus – “that anyone holding themselves out as a financial planner should seek the attainment of the CFP mark” while also allowing as members anyone else who supports the financial planning process – was not only written into the bylaws, but would be almost impossible to change, as Section 17.1 of the bylaws states: “…any amendment or repeal of the Organization’s purposes, as outlined in Article II, shall require ratification through an affirmative vote of at least a majority of the individual members of the FPA…” In other words, to the extent that the FPA in the mid-2000s wanted to become less CFP-centric in its focus, it was operating in violation of its own bylaws by shifting its focus without securing a majority vote of the membership!

Yet despite the FPA’s recommitment to what its bylaws already said it was, and a partial rebranding of the FPA towards a “One FPA” theme (One Profession, One Designation), since Schadle’s announcement of the FPA’s renewed focus upon becoming CEO in 2012 (and a rather negative “blasting” response from American College CEO Larry Barton), the FPA has taken virtually no public positions and statements declaring itself to be the primary membership association for CFP certificants, and taken no significant public positions advocating on their behalf to the CFP Board. Their “CFP centric” return appears to be reflected on only its own website, and is far more difficult to observe in its deeds and public advocacy beyond what may be discussed internally at its home office and board meetings.

In fact, in its recent “Advocacy Day In Washington DC”, the FPA focused all of its efforts lobbying legislators on Capitol Hill, and embarrassingly forgot to include the DC-based CFP Board itself on the list of organizations to visit regarding advocacy in Washington, despite the ongoing challenges for CFP certificants regarding compensation disclosures! In other words, the FPA has declared that it is an advocacy organization on behalf of CFP certificants, but apparently saw no need to advocate the very organization that oversees their CFP marks (despite plenty of recent CFP Board challenges and issues to advocate about!)!

The FPA And The CFP Board – Checks And Balances

The fact that the FPA has not viewed the CFP Board as an organization to which it should lobby and advocate raises a crucial fundamental question about its very reason for being – after all, what’s the point of having two organizations, the FPA and the CFP Board, if it’s not so they can serve as a system of checks and balances against each other? Couldn’t the profession have more efficiency, and generate more political clout on behalf of the profession to legislators and (other) regulators – not to mention, being less expensive for CFP certificants who don’t have to pay two fees to two organizations – if the roles were simply merged into one?

For instance, in Australia, the “FPA” actually fulfills both roles (there is no separation of membership and credentialing), allowing the organization to advocate directly to regulators as both the credentialing organization and the membership association – a key lobbying role it has been playing over the past several years as Australian regulators have rolled out their “Future of Financial Advice” (FoFA) reforms.

For members of the financial planning community here in the US, the answer to the question “why not just merge the FPA and CFP Board into one organization” quickly comes back to the fact that the CFP Board has a long and unfortunate history of engaging in “blunders” from time to time, for which the FPA (and its predecessor organizations) can sometimes play a key advocacy role in getting the CFP Board back on the right track. Yet when the FPA refuses to take a public position on key issues to represent CFP certificants to the CFP Board, it raises the question of whether the FPA is simply making itself irrelevant and is becoming redundant as a membership association.

The FPA’s Waning Power As An Advocate For CFP Professionals

To some extent, it’s not entirely surprising that the FPA has been less willing to push the CFP Board on advocacy issues pertaining to CFP certificants – because it doesn’t actually have a lot of power to advocate with as the FPA’s own clout has been waning dramatically while its share of CFP certificants declines. If the FPA had kept pace with the growth in CFP certificants itself, and had 40,000-50,000 of them as members (and likely well over 50,000 total members at that point), it would be hard for the CFP Board to ignore. As the FPA has failed to take up the mantle for CFP certificants and its market share has fallen to fewer than 25% of CFP certificants as members, its role as a check-and-balance to the CFP Board is coming undone, and the balance of power is shifting to the CFP Board.

The rapid decline in FPA’s power has been astonishing, especially given the recent compensation issues of the CFP Board. While the FPA could have taken the situation as a renewed opportunity to reassert itself as being relevant in representing CFP certificants to the CFP Board and embolden its CFP advocacy brand – especially on behalf of its members working at broker-dealers who may have been slighted by the compensation disclosure debacle but are not comfortable confronting the CFP Board directly – yet instead the FPA deferred entirely to the CFP Board about when to have "the talk” about its recent compensation disclosure issues (and given that the CFP Board has insisted there is no problem to talk about, is tantamount to the FPA just looking the other away and ignoring the issue altogether). In other words, in the span of under 10 years the FPA has gone from successfully suing the SEC to defend the interests of fiduciary financial advisors and commanding significant political clout, to not even being willing to publicly call out the CFP Board on the blatant flaws in its compensation disclosure rules at all.

In the meantime, the FPA’s waning power seems to be not only external; it is also struggling to keep itself focused and on message internally as well. For instance, despite trying to work collaboratively with the Financial Planning Coalition, an FPA board member recently raised the question of whether financial planning should be state regulated (while a reasonable consideration, the Coalition has not publicly agreed to pursue such a course), and there are rumors that the FPA of Florida statewide organization is exploring whether it could actually implement some kind of state licensing for financial planners without necessarily advocating for the CFP marks that are central to the FPA’s mission. Though FPA chapters are technically separate and standalone legal entities from the national organization, the conflict highlights the fact that the FPA still hasn’t fully obtained the buy-in of even its own chapters to the organization’s CFP-centric focus and bylaws, even 14 years after the merger.

And the FPA’s inability to stay on-message and coordinated with the Financial Planning Coalition raises the question of why the CFP Board would want to engage the FPA in the Coalition at all, as there’s little purpose to having the FPA in the Coalition if it will not (or cannot) support the whole purpose of a “coalition” which is to maintain a unified advocacy front! The FPA’s uncoordinated role in the Coalition is especially problematic since the primary asset the FPA brings to the Coalition – its state chapter system and potential to help drive a grassroots effort for state regulation (should the Coalition actually decide to pursue state regulation in a concentrated and coordinated manner) – isn’t much of an asset if the FPA can’t steer and coordinate its own chapters in the first place! Yet the possibility that the FPA may be making itself more of a liability than an asset to the Coalition is a dangerous position, given that the FPA needs the Coalition for advocacy clout far more than the Coalition needs the FPA (as the CFP Board already has more dollars, greater numbers, and stronger connections given its Washington DC base); if the FPA undermines its own role in the Coalition, its advocacy power and relevance to the profession just wanes even further.

The Rising Power Of The CFP Board Is Further Undermining The FPA

Of course, what is a decline in the power of the FPA also represents a rise in the power of the CFP Board, a transition in the balance of power that the CFP Board seems intent to accelerate and capitalize upon to advance its own goals. As noted earlier, the shift in the profession’s balance of power has allowed the CFP Board to control the issues, including not only quieting FPA amidst the CFP Board's refusal to acknowledge a problem with its compensation disclosure rules, but forcing NAPFA to abdicate its own leadership of the “fee-only” definition and capitulate to the CFP Board’s position despite the fact that NAPFA originated the fee-only definition and movement!

However, over the past two years the CFP Board has gone beyond just trying to drive and control the issues, and appears to be proactively trying to undermine the FPA - a potential “silent war” assaulting the FPA’s role in the profession and even its financial viability. First there was the CFP Board’s attempt to begin to offer CFP CE credit, effectively going into competition with the FPA (and other CE providers), which could have damaged attendance at FPA (and NAPFA) conferences that are still a key revenue generator to fund the organization’s annual operating budget; the FPA fought hard and repelled the CFP Board’s attempt (along with NAPFA which was similarly threatened), but only after engaging with a fervor that seemed to signal that the FPA recognized that its own life was on the line.

Then earlier this spring, the FPA announced its partnership with the Academy of Financial Services (AFS), including the decision to co-host an academic track at the FPA BE conference and for FPA to co-publish their Financial Services Review journal; not to be outdone, the CFP Board co-opted the FPA’s announcement with AFS by declaring its own new initiatives just weeks before the FPA/AFS partnership became public, including announcing the CFP Board’s new academic financial planning journal to compete against the FPA’s Journal of Financial Planning (and the AFS’ Financial Services Review), and a new Center for Financial Planning to support academic research. The CFP Board’s announcement of the initiatives – which seemed premature given that they still haven’t been implemented more than 6 months later – was rumored to have come specifically to pre-empt the FPA announcement once the CFP Board had failed in its own attempt to partner with AFS.

More recently, the CFP Board struck against the FPA again, announcing the launch of a new career center in 2015 that would be a “one stop shop” for guides on how to “bridge the gap” from student to financial planner, job and internship listings, and other career management content, a rather direct dig at the FPA’s own Job Board and its now-defunct “Bridge The Gap” program which have not lived up to the task and could now be trumped entirely by the CFP Board’s new initiative (as the CFP Board appears to have far more capabilities to reach students with messaging about its career center as they enroll themselves for the CFP exam in the first place). This presents not only financial implications to the FPA – as their Job Board is a(n admittedly not huge) source of non-dues revenue for the organization – but also potentially cuts off the FPA’s lifeline to students as future members. After all, the biggest issue a graduating financial planning student faces is trying to find a first job and enter the profession, and if the CFP Board is perceived as the go-to source for that solution, the FPA is potentially written out of the student’s awareness altogether.

And the FPA’s battle-weary response to the CFP Board’s latest initiative? The FPA not only declined to fight the issue (now so weak that it has to choose which battles to fight and which it will just concede), but it embarrassingly applauded the CFP Board’s victorious effort at implicitly highlighting the FPA’s failures and making the FPA less relevant to new students in the future.

Will The FPA Survive The Next Recession?

Ultimately, the risk to the FPA is that if the CFP Board manages to chip away at enough of the FPA’s supports – from its pipeline to students, to its non-dues revenue channels with the Journal (which generates advertising revenue) and the Job Board (for which firms pay to have job listings), to its conference attendance and offering of CE credits – the FPA itself could financially topple.

As is, the FPA’s revenue is down 36% from 2008, and it has been forced to trim staff and services accordingly, despite the fact that the markets, economy, and financial advisors are all seeing record highs for income and growth. If the FPA is off 36% in revenues despite the economic recovery of the past 5 years (and down 17% in members despite the fact that the number of CFP certificants is up 20%), then what happens when the next recession comes along and things get really tight, and more advisors choose not to renew while prospective sponsors also cut back their advertising budgets? Can the organization survive another recession after failing to recover from the last one, when it’s now down to only $2M in net assets (on a $10.6M operating budget)?

Acknowledged or not, it seems that the FPA is in a fight for its very survival right now, and it’s a fight the FPA may not win. A loss of the FPA would leave a gaping void in the profession, as it’s simply not feasible to have a group of 70,000+ CFP professionals who do not have their own dedicated professional membership association.

Which, in point of fact, may be exactly what the CFP Board is waiting for – to either facilitate a takeover/assimilation of the FPA, or simply replace it with a new membership organization. While the CFP Board can’t literally be the membership association for CFP certificants – it is legally structured as a 501(c)(3) charity, not a 501(c)(6) membership association, which limits its ability to directly deploy its assets and income as a membership organization – it’s not difficult to imagine ways the CFP Board could still facilitate the process. For instance, while it’s not clear whether the organization could legally use its some of its own $23M war chest of net assets on its balance sheet (according to its 2012 Form 990) to fund a new membership organization spin-off, it might use its relationships to leverage sponsors that could “seed” a new replacement membership organization, and then establish a tight integration between the CFP Board and the new association to rapidly accelerate its growth (for instance, by doing marketing directly to its list of CFP certificants to encourage them to join the new organization). In fact, I would go so far as to say the CFP Board and its Board of Directors would be remiss if they haven’t at least been exploring potential paths to supporting/sponsoring/spawning their own membership association if the FPA takes itself out of the picture.

Of course, the reality is that the FPA has become weak enough that the CFP Board could potentially launch a competing membership organization now, and just further accelerate the decline of the FPA. But realistically, the CFP Board likely would prefer to see the FPA fold (or become desperate in a manner where the CFP Board controls the terms of a merger or wind-down), so that the CFP Board can try to take over the one unique asset the FPA has that the CFP Board wants – its state chapter system and capabilities to do grassroots lobbying at the state level for state regulation, should it be decided that’s the ultimate regulatory path to pursue to advance the financial planning profession (with the CFP Board obviously advocating for the CFP marks as the minimum professional standard).

Where Should The FPA Go From Here?

So given all these challenges, where should the FPA go from here? At the most basic level, the FPA has to focus on one simple reality if it is going to survive: the only way to defend itself against the CFP Board is to have as many CFP certificants as possible, who support the FPA for its advocacy efforts on their behalf (including against the CFP Board) and keep the FPA relevant as a separate membership organization from the CFP Board. The FPA leadership should make “market share of CFP certificants” its one crucial Key Performance Indicator for the coming years when evaluating the success of its staff, programs, and efforts. Just growing membership isn’t enough (not that the FPA has even been succeeding in that regard); if the FPA isn’t gaining in total share of CFP professionals, too, it’s still losing ground in its power struggle with the CFP Board.

After all, the reality is that with 70,000 CFP certificants and the numbers still growing, there are too many CFP professionals to not have a clear membership association loudly and publicly advocating on their behalf and helping to make them more successful. If the FPA cannot take on that role – whether due to its fuzzy and meandering focus, lack of clear messaging, or simply poor execution – then some other organization will eventually fill the void (CFP-Board-driven or otherwise), and at the point a true competing membership association crops up to challenge the FPA, its demise may only be further hastened (as it cannot afford to lose what core CFP certificant membership base it has left). Which means, once again, the FPA either truly lives into its CFP-centric mission, or it must figure out an astonishing pivot that could keep itself relevant as a membership and advocacy organization competing against another CFP-centric membership group (and given the existence of FSI, NAIFA, and others, it’s not really clear what other role the FPA could realistically fulfill).

In other words, the FPA really has no choice at this point but to embrace its CFP-centricity – or better yet, clarify its position to be “one profession, one minimum designation” so it can support the CFP marks as a pathway to the financial planning profession without undermining its relationship with post-CFP educational providers – because any other path just makes the FPA “yet another financial advisor membership association” (a tactic that has clearly done it no favors for the past decade), and the less it attracts CFP certificants, the less beholden the CFP Board must be to the FPA, and the more opportunity the CFP Board has to try to undermine and replace the FPA. In other words, if the FPA doesn’t live into the vision of the ICFP, the CFP Board or some new competitor will take over the role themselves and make the FPA irrelevant to the future of the financial planning profession. There are too many CFP certificants to be so under-represented.

Notably, though, the FPA (finally) fully embracing its CFP centricity and (loudly and publicly) taking up its mantle as the membership association for CFP certificants and advocating on behalf of the CFP Marks does not mean acquiescing or subjugating itself to the CFP Board in the process. The FPA already takes lobbying issues to the SEC and FINRA, even though its members are RIAs and registered representatives; the fact that the FPA lobbies against certain policies of the regulators doesn’t change the fact that members are still expected to be registered with those regulators, and the same would be true of encouraging financial planners to be CFP certificants while advocating on their behalf against the CFP Board when apporpriate. In fact, the whole point of embracing CFP centricity is that by having more CFP certificants the FPA shifts the balance of power back into its favor, to be able to hold its own against the CFP Board and advocate even more effectively, because in advocacy the reality is that numbers = power. The Financial Services Institute recognized this, rapidly gained power in lobbying to FINRA because it has gathered nearly 37,000 registered representatives as members, and so too can the FPA (re-)gain power by trying to rapidly add more CFP certificants to its ranks in order to represent them.

Of course, it’s worth noting again that from the perspective of a CFP certificant, if the FPA cannot step up to the task and ultimately topples, the loss of the FPA isn’t necessarily a bad thing. A potential consolidation of the credentialing body and the membership association allows for a better pooling of resources, more coordinated advocacy and lobbying efforts, likely lower costs for CFP certificants who are FPA members and can just pay one fee instead of two, and the unification of the two could actually become a superior CFP-centric membership association than what the ICFP was and what the FPA was intended to be.

Again, though, the greatest caveat to the elimination of the FPA and a consolidation of the profession’s power within/behind the CFP Board is the fact that with the FPA out of the way, it becomes increasingly difficult for CFP certificants to push back against the CFP Board in an organized and coherent manner when the CFP board does something objectionable, as it has been wont to do from time to time over the years. Which means that ultimately, the FPA’s best path to survival at this point may be to explicitly capitalize on the collective nervousness of the CFP certificant community about what happens when the CFP Board goes “unchecked” for too long, and solicit members on the basis of being that organization which can advocate for their interests against the CFP Board when necessary (while also striving to help their members be successful in other ways as well, and advancing the CFP marks as the center of the financial planning profession in accordance with the FPA bylaws).

But the bottom line, though, is simply this: with the ongoing growth in CFP certificants, it is simply impossible for 70,000+ professionals to not have a membership and advocacy association dedicated solely and entirely to their needs. The FPA is at a crossroads about whether to step up and fully embrace the vision of the IAFP and ICFP merger – to loudly, proudly, and publicly be the membership association of CFP certificants and those who support the financial planning profession with the CFP certification at its center – and justify why CFP certificants should pay for both the CFP marks and a separate membership association to represent them, or risk being made irrelevant as its financial resources continue to dwindle and its power continues to wane, until eventually the CFP Board or some other competitor steps up to fill the CFP certificant membership void on its own terms.