One of the hallmarks of recognized professions is that they have established Practice Standards that define the process that professionals of that discipline are expected to engage in to ensure that their clients/patients/etc. are well-served. The end result is not only a more consistent quality of service from that professional discipline – when everyone engages in a vetted process that has been refined by recognized best practices – but also an important means of protection for professionals themselves, who can point to the fact that the process was diligently followed, even and especially in scenarios where the outcome isn’t favorable (e.g., the doctor who can point to the fact that the processes were conducted appropriately, even if the patient themselves unfortunately didn’t survive).
Accordingly, CFP® professionals have long had a version of “Financial Planning Practice Standards” that apply to the delivery of Financial Planning itself, known by the EGADIM acronym (short for Establish relationship, Gather data, Analyze the client situation, Develop and present planning recommendations, Implement the recommendations, and Monitor). But effective on October 1st of 2019 (which were first enforced starting on June 30th of 2020), CFP Board updated the Financial Planning Practice Standards to a new 7-step process of CGADPIM (understand Circumstances, Gather data, Analyze, Develop recommendations, Present recommendations, Implement, and Monitor).
CFP® professionals providing Financial Planning are expected to engage in the full 7-step Financial Planning process with clients, unless the Scope of Engagement specifically excludes the Implement and Monitor phases (e.g., for an hourly or project-planning-only engagement). In addition, the full Financial Planning Practice Standards will apply if the Client engages the CFP® professional for Financial Advice that broadly integrates a wide range of advice areas or otherwise requires Financial Planning based upon a weighing of factors that CFP Board specifically identified in the Code and Standards (i.e., “Financial Advice that Requires Financial Planning”), or in situations where the Client has a reasonable basis to believe the CFP® professional will provide or has provided Financial Planning (i.e., if the CFP® professional suggests the Client is going to receive Financial Planning based on how they market and hold out, they have to actually do so!).
Notably, though, CFP® professionals do not have to engage in comprehensive (7-step) Financial Planning with every client. In situations where clients do not engage for Financial Planning, or seek out only narrow-scope (i.e., non-integrated) Financial Advice – or where the Client outright refuses to engage in the comprehensive Financial Planning process after being warned of the consequences – CFP® professionals may still proceed in providing non-Financial-Planning (i.e., not comprehensive and following the full 7-step process) Financial Advice. However, in all cases, CFP® professionals will still be held to CFP Board’s new ‘fiduciary-at-all-times’ standard with respect to the advice itself (even if not delivered pursuant to the full 7-step process).
The key point, though, is simply to understand that whenever CFP® professionals are engaged in Financial Planning itself – or provide advice that is so comprehensive and integrated it necessitates the full scope of Financial Planning – they are expected to follow the full 7-step Financial Planning process. Which isn’t intended to be unduly burdensome, but simply to help ensure that when financial planning advice is given, the CFP® professional has fully considered all the relevant facts and circumstances, as well as Client goals and objectives, before coming to a fiduciary recommendation in the Client’s best interests!