Financial Planning Education and Regulatory Requirements: A Cross Country Comparison between Australia, Canada, United Kingdom and United States of America

Abstract

Conflicted remuneration, corporate collapse, lack of disclosure and a range of unethical practices have served to undermine the reputation of financial advisers over the past thirty to forty years and impeded the recognition of financial planning as a profession. However, a range of education and regulatory reforms over the same period have assisted in the development of financial planning and attempted to lift the professional profile of financial advisers, particularly in the western world. This study includes a comparison of the education and regulatory requirements of four main countries: Australia, Canada, United Kingdom and United States of America to consider how education and regulation in these countries have attempted to mitigate wrongdoings of the past and contribute to the development of financial planning as a profession. A brief history of the education and regulation requirements for financial planning in each country is reviewed, along with reforms that were introduced to improve the quality of financial advice for consumers. The focus of education and regulatory requirements was found to differ across countries, with some countries focusing on disclosure and transparency, or licensing or remuneration structures and others requiring stringent education and qualification requirements or codifying the terms ‘financial adviser’ and ‘financial planner’ in legislation. Regulations outlining a fiduciary duty requirement for financial advisers were common across countries. While there is still no universal approach to the education and regulatory requirements for financial planning, there have been some recent developments which point towards the internationalisation of financial planning and the recognition of financial planning as a discipline it its own right. However, the complexity of education and regulation in the financial planning industry means that this process is likely to take some time and will require academics, educational and professional bodies, financial advisers, industry representatives and regulators to work together on a global scale for this to be realised

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