In this day and age, professionals are laden with the alphabet after their names.
My industry is no exception.
When I started my career with my previous firm, we immediately acquired the AAMS (Accredited Asset Managment Specialist) Designation. While serving in Iraq, in my downtime I studied for the CRPC (Chartered Retirement Planning Consultant).
These are just two of several designations I could attain if I had the time and patience to study for them. But despite the two I had, and several I could get: the coveted mark I knew I had to have was the mark of the CFP®.
What Makes a CFP® Different?
From my perspective, the CFP® was the mark of a serious financial planner.
With countless financial consultants at other investment firms, insurance agents offering investments and banks now having in-house brokerages, I knew I needed to differentiate myself.
Many people I know are not familiar with the CFP® mark, so I wanted to share what I had to go through to get it.
Financial professionals who have earned the right to use the CFP® mark have met the following requirements:
Education: There are three ways to meet the CFP® certification education requirement:
- Completing an education program at a college or university whose curriculum is registered with the CFP® Board; or
- Submitting a transcript of previous financial planning-related coursework to the CFP® Board for review and credit; or
Showing the attainment of certain professional designations or academic degrees.
- Examination: Individuals must pass a rigorous two-day, 10-hour CFP® Certification Examination administered by the CFP® Board who covers the financial planning process and includes such topics as tax planning, employee benefits and retirement planning, estate planning, investment management and insurance.
Experience: Candidates for CFP® certification must prove they have experience in the financial planning process before being authorized to use the CFP® marks.
Ethics: As a final step to certification, CFP® practitioners agree to abide by a strict code of professional conduct, known as CFP® Board’s Code of Ethics and Professional Responsibility, which sets forth their ethical responsibilities to the public, clients and employers.
CFP® Board also performs a background check during this process, and each individual must disclose any investigations or legal proceedings related to their professional or business conduct.
Candidates must also adhere to the CFP Board’s Code of Ethics and Professional Responsibility and Financial Planning Practice Standards.
How to Choose The Best Financial Advisor/Planner for You
You knew one day it would come.
Retirement planning has been something you have postponed for too long but knew you would eventually have to face the music.
The time has finally arrived: you need to choose a financial planner/adviser to guide you through the complex maze of investing.
It can be an overwhelming process trying to choose the best financial advisor to hire for you–and that's the key: “For You.”
The absolute most important item is making sure you can find someone you can trust.
But is it really so easy? How do you avoid hiring the next Bernie Madoff?
Given all the headlines about Ponzi schemes and fraud over the years, you may be wondering – how can you avoid getting duped by a shady financial advisor?
The key is being better informed and doing some homework.
Here are some tips on helping you choose the best financial advisor for the job:
1. Find out how long they have been in the business
I don't know about you, but I'm not extremely comfortable letting a newbie handling my retirement dreams. You don't need a 20-year seasoned veteran, but you want somebody who has some experience in financial planning matters.
Somewhere in the 3-5 year range should suffice, but also get an understanding of what they're upbringing is.
If they are a third generation financial advisor, then it might just be in their blood.
2. Make sure they are CERTIFIED
The financial services are laden with alphabet soup after their names. Even I have three certifications, but only one really matters.
If you are looking for a serious financial planner, then make sure you find one who has the CFP® designation.
One who has taken the extra effort to become a CERTIFIED FINANCIAL PLANNER™ is held to a higher standard than your typical financial advisors.
A CFP® must adhere to the CFP Board’s Code of Ethics and Professional Responsibility and Financial Planning Practice Standards.
In the summer of 2009, there were more than 60,000 CERTIFIED FINANCIAL PLANNER™ certificants. In an average year, the Certified Financial Planner Board of Standards, Inc. conducts about 80 ethics code investigations.
This means 99.9% of CFP® practitioners are abiding by the Board’s ethical and behavioral standards.
3. Do a background check
Remember when you were younger and you could always hide your grades from your parents?
That was until the report card was sent home.
The U4 is the “report card” of your financial planner’s background. This means if he’s done anything wrong and a complaint has been filed against him, it will be shown here.
By asking the financial planner if there’s anything on his U4, you’re finding out if he’s committed any wrong-doing.
The best part is, if you don’t believe the financial planner’s answer, you can always log on to finra.org to find out if the financial planner is telling you the truth.
It’s amazing the percentage of people who don’t do a background check on a financial advisor before they hire them.
If you want to check out an investment advisory firm, visit the SEC’s website.
That is the website at which the Securities and Exchange Commission keeps Form ADVs – the forms which reveal disciplinary actions taken against the advisory firm and/or its key employees. You can also make sure a firm is properly registered there.
If you want to check up on a specific investment adviser, go to the FINRA BrokerCheck website tool.
Here you can learn about the professional backgrounds of advisers and firms through the Financial Industry Regulatory Authority.
Since it’s been mentioned, let’s accentuate the positive.
Visit the websites of the Financial Planning Association and the National Association of Personal Financial Advisors. Search functions on both sites will allow you to find a respected independent financial adviser near you.
4. Find out their investment philosophies
Do you want an advisor who believes in a buy-and-hold strategy or someone who has more of tactical approach?
Maybe you have an interest in a socially responsible investing and want someone to keep you abreast of its everyday happenings.
If that's the case, then you better make sure you find the right person for the job. Ask specific questions on the investment strategies they have implemented in good times and bad.
They should be able to show you some examples of portfolios which have been used with other clients in a similar situation. The interview process is all about fact-finding, so find out as much as you can.
5. Completely comprehend how they are compensated
You would think this would be a common question. But many folks feel it’s impolite to ask how much a financial planner charges.
If you were getting your car worked on, wouldn’t you ask the mechanic how much it was going to cost?
If you go see a lawyer or CPA, you know how much you are being billed.
Why is hiring a financial planner any different? Don’t be shy in asking this question.
There are many different ways financial planners make money. They may be commission-based, fee-only, fee-based — or a combination of the three. (more on this in a moment)
Asking what the planner charges will help you know exactly what you are paying throughout the working relationship. If she explains but it still doesn’t quite make sense, have her put it on paper so it’s crystal clear.
6. Lean towards choosing independence
When you search for an independent adviser, you have a better chance of finding someone who gets paid for their advice and/or their fee-based asset management, instead of deriving the bulk of their income from trades or product sales.
Many of these independent advisors set flat or hourly fees for specific services.
Some earn a fee which corresponds to a small percentage of the invested assets they manage for you. If your portfolio does well, they do well.
Once again, make sure you completely understand how they get paid.
7. Know how important you are to them
If you have an annual check-up from your doctor, would you expect the same from your financial advisor?
How about twice a year?
One of the biggest breakdowns in any relationship is communication and this is no different. If you expect to hear from them a least once a month, then let them know. This way your expectations are clear from the onset.
If they over promise and under deliver, it's time to start looking for another financial advisor.
What’s the Difference Between a Financial Advisor/Planner vs. Insurance Agent?
Here’s a question I had from a client of mine:
Recently, I was introduced to a new Financial Planner in my area.
I asked all the right questions but did not receive any of the right answers. I was becoming concerned.
It turns out, the Financial Planner is not a Certified Financial Planner (CFP), let alone even registered with FINRA or the SEC.
After doing some additional homework, I learned the Financial Planner is an insurance agent selling only annuities. But the Financial Planner walks, talks, introduces themselves as a Financial Planner (not CFP — which can be unclear to the uneducated client) and a full-blown website talking about the merits of comprehensive financial planning… but really only selling Fixed and Indexed Annuities for one of the larger insurance companies.
Can the agent call himself a financial planner?
What's the difference between a financial planner/advisor or life insurance agent?
So, let’s take a moment and actually break this down because it’s very important.
And there you have it. But even once you identify the type of advisor, does it really matter how they get paid?
In my opinion, yes, but each has its own advantages and disadvantages, especially when we pit them against you and your retirement fund goals and ambitions.
Let’s dive deeper.
Fee-Only Vs. Fee-Based Financial Advisor – What the heck is the difference?
Potato, potahto. Tomato, tomahto. Fee-Only Vs. Fee-Based. The same difference, right?
If you've ever interviewed or hired a financial advisor, chances are you have no idea how you are paying them. Advisors can get paid way in many different ways.
Mainstream media loves the “fee-only” advisor. No conflict of interest, no commissions, the certainty of what you are paying.
But, then you have the “fee-based” advisor.
The fee-based advisor earns a fee, but then can also earn a commission. Say what?
Yes, it's altogether confusing and that's why I attempt to explain it in greater detail here:
Definition of Fee-Only Vs. Fee-Based Advisors
If you're looking for a true fee-only advisor, then check out this article about NAPFA which is an association of true fee-only financial advisors.
Another good resource is an article on Moolanomy.com where they interviewed me on the difference between a fee-only vs. fee-based advisor. Miranda did a good job explaining the differences (much better than I could.)
And finally, you can read about Phil Taylor's experience of meeting with a fee-only financial planner. PT (as we like to call him) does an awesome job giving you a play by play of meeting with a fee-only planner. You almost feel like you are in the meeting with him.
How To Do a Background Check on Your Financial Advisor
Before you make a major purchase – car, television, refrigerator – most likely you've done some extensive research to ensure you are making the right decision.
One of the most important decisions investors make is choosing the right financial planner to work with.
Yes, approximately 1/3 of people who decide to work with a financial planner do not check the background of the person they are getting ready to hand over their life savings to.
With the names of Madoff and Sanford making headlines over the years, it's even more important to, at least, double check your advisor's background. It may not be a sure all prevention method, but you can easily find out if the advisor has had any prior wrongdoings on his or her record.
To show you how easy it is to get information on a financial advisor, I thought I would do a little experiment.
Today's experiment is doing a background check on myself. I'll show you the different sources you can go to do various background checks and what information to look for.
Taking just a little bit of time can save you tens of thousands of dollars from going with an unscrupulous advisor. Yea, one of the seven kinds of financial advisors I would like to punch in the face.
First things first: the unfortunate thing of me doing this is I have a bit of confession to make…
My real first name is not Jeff. *Gasp*
I know, I know. You might be shocked.
As you can see if you do a background check on myself, my parents blessed me by naming me Jan Jeffrey Rose. There is no family history behind the name, it was just one they liked. (Thanks, Mom and Dad…!)
Growing up I opted to go by my more masculine middle name, Jeff. You don't know how much of a pleasure it is to get phone calls from telemarketers asking for “Mrs. Jan Rose.”
Now that it’s out in the open, we'll continue.
This is a pretty good example of what information you'll be able to find when doing a little homework on your financial advisor.
1. Is Your Financial Advisor a Certified Financial Planner?
Before choosing a financial planner, one thing you might want to consider is if they are a Certified Financial Planner™ professional.
Only those who have fulfilled the certification and renewal requirements of the CFP Board can display the CFP®certification marks.
CFP®practitioners agree to abide by a strict code of professional conduct, known as CFP Board’s Code of Ethics and Professional Responsibility, who sets forth their ethical responsibilities to the public, clients and employers.
By going to the CFP.net website, you can use their search tool to find out if the planner has had any disciplinary actions against them.
As you can see with me, I'm squeaky clean. I would also like to thank the CFP board for allowing to abbreviate my first name with an initial.
2. FINRA Broker Check®
A financial advisor who is considered to be a registered representative is regulated by FINRA (Financial Industry Regulatory Authority).
Typically if the advisor works for a brokerage firm, they will be regulated by FINRA. I was considered to be a dually registered representative since I held both hold the Series 7 and 66 licenses. I dropped my Series 7 in 2011 when I founded my registered investment advisory firm, Alliance Wealth Management, which means I'm no longer under FINRA rule.
To help investors keep tabs on financial advisors, they developed a service called FINRA BrokerCheck®. All you need is the person's name and you'll soon have all the background information of the advisor available to you in a PDF format.
Here's what pulls up when you first search for my name:
To get the full PDF, you click on the Broker link under my name in the search and then “Detailed Report” on the next page.
I was really quite impressed with the amount of information they provide.
For my report, it listed the following:
- Previous firms I was licensed with (I worked for LPL Financial and A.G. Edwards & Sons before starting my own financial planning firm)
- Any disciplinary actions which had been filed against me (once again – none)
- States which I'm licensed to transact business in
- Industry exams I've passed and when I passed them (Series 7 and 66)
- All my previous employment history for the previous 10 years
- Outside Affiliations/Other Business Interests – this will show if the advisor is involved with any outside business activities. (As you can see on mine, I had listed my revenue from my Google Adsense)
It also shows I am not currently registered with FINRA because dropped my Series 7 to start my own registered investment advisory firm which I mentioned above.
3. Securities Exchange Commission- Investment Adviser Search
This is where the term Registered Investment Advisor (RIA) comes into play.
More from GFC, Below
People or firms who get paid to give advice about investing in securities generally must register with either the SEC or the state securities agency where they have their principal place of business.
If they manage less than $25 million, they generally must register with the state securities agency in the state where they have their principal place of business.
I hate to use this an example, but good ol' Bernie Madoff was an investment advisor. That's why the SEC has taken a lot of heat over the matter.
When I was a registered rep, my parent firm, LPL Financial, fell under the SEC's watch (as well as FINRA's).
You can do a search on brokers and advisors on the SEC's website. The only information I could find on the SEC's site was my listing in FINRA, which the SEC links to.
If you do decide to work with an RIA, this would be your resource to do some investigating. If they are a smaller outfit, you can check with the state regulators.
One source is the North American Securities Administrators Association. The NASAA has helped in preventing investors from being subject to fraud for over one hundred years.
4. Don't Forget Social Media
Using the above resources is a great way to find some really good information on your financial advisor, but what about just using Google?
By simply “Googling” the advisor's name, you might be surprised what you might find.
If the advisor is on Twitter, Facebook, or LinkedIn, you might also be able to find out some good information, too.
For example, if the advisor has a public profile on Facebook you can see their latest updates and it may give you a clue on what type of person they are.
That goes for Twitter, too. (You would quickly find out I am a huge fan of In-n-Out Burger, so obviously I'm a great advisor, right?)
On LinkedIn, you can view all their connections and if anybody has recommended them.
As you can see, there are plenty of resources to do some homework on your financial advisor before you hire them. Don't allow yourself to be part of the 30% of people who don't take the time to do a background check and end up getting burned.
If you are already working with an advisor and never did any research, you might want to do it now.
Find something not so great? You need to heavily consider firing your advisor. (Here are 8 other warning signs which mean you probably need to fire them, even if their background turns out just fine.)
It's much easier to return a lousy TV to Best Buy with little financial recourse. Choosing a lousy, unscrupulous financial advisor could cost you your future and leave you in financial ruins.
Protect your investments by spending as little as 15 to 30 minutes researching your potential advisor before handing over your financial future to a crook.
7 Questions To Ask Your Financial Planner
As the year rolls on, risk and credit are being re-priced and financial markets remain in some turmoil.
In the last few client reviews I've had, the clients have all stated they haven't even looked at their statements. If you find yourself in this situation and retirement is creeping around the corner, this is highly not suggested.
Now, more than ever, you need to be on top of your financial situation. Your portfolio could be completely intact, but most likely there might be some opportunities to take advantage of.
When meeting with your financial planner, here are 7 questions you should ask to get a better sense of where the market dump has left you.
Watch the video to hear what is:
1. What is my true financial situation?
Re-examine your investment goals, time horizon, risk tolerance and financial circumstances. Have any of these objectives or circumstances changed?
Have you added to your bond and money market investments during this volatile time?
If so, will the more conservative investment mix still allow you to meet your long-term goals of saving for your children’s college education and funding a retirement income plan?
Allow your planner to assess your true financial situation by providing complete information on your current financial picture. Make sure to include not only your investments held by them but other investments as well, including bank savings accounts.
2. How should I be thinking about risk in this environment?
Did you use to consider yourself an aggressive investor prior to 2008? It's time to truly ask yourself what your risk tolerance is.
Has it changed — or are you just feeling natural unease following a downturn?
The hardest thing to do when markets and stocks are going down is to stay the course.
For some, it happens because they have taken too much risk at the top of the market. Many investors end up going to cash or bonds when markets are declining.
Eventually, after a recovery begins, they think, ‘What have I been missing?’ They eventually come back in but miss a good deal of the recovery.
3. Do I need to reconsider my time horizon?
How long is your time horizon?
All things being equal, you can afford to be more aggressive if you have a longer time horizon.
For example, most planners would recommend the investment mix of a 32-year-old be more heavily weighted in equities than someone who is close to retirement.
Do you have multiple time horizons?
A 32-year-old who is saving for a down payment on a house in three years would be investing a portion of her money with a three-year time horizon despite the fact retirement may be 33 years away.
Given the short time frame, it would be prudent to invest those assets more conservatively because there is little time to make up any losses.
Can you adjust your plans to retire?
Perhaps you once planned to retire early at 62 and your investment portfolio shrank in 2008. Ask your adviser to calculate how long you would have to work beyond 62 to build a portfolio which can produce a lifelong income stream.
If you could wait to retire at 65, you would add three more years of income and investing, while reducing your withdrawal phase by three years. It would also enable you to postpone the year you start claiming Social Security benefits.
If you claim before your full retirement age, your benefits would be reduced for life.
4. Does my investment strategy need readjusting?
If you are retired and withdrawing income from your investment portfolio for living expenses, talk to your financial planner about taking out less today and over the next several years.
This approach can help make your investments last longer. You can’t predict or control the stock market, but you can control your income withdrawal strategy.
5. How do changes in my personal life affect my financial situation?
If you can answer “yes” to any of the questions below, your planner may need to adjust your investment mix to provide for these changes.
- Have you changed jobs or decided to take a buyout offer or early retirement?
- Did you get married, have a child or become a grandparent?
- Has there been a divorce, or is your son or daughter getting nearer to needing money for college tuition and expenses?
- Do your grown children need temporary financial assistance?
- Are you now helping to financially support a parent or parents?
6. What if I haven’t invested enough for retirement?
Talk to your financial planner about a number of possible strategies to help build up your assets prior to or during retirement:
- Delay retirement until you are 65 or older. If you could use a few more years to invest, it may be worth thinking about staying in your current job or starting a second career.
- Work part-time in retirement. Bringing in extra income may keep you from using up your retirement savings too early. Nearly one-quarter of adults 65 to 74 years old are in the workforce.
- Reduce your spending during market declines. By cutting expenses in a down market, you can significantly lessen the financial impact on your portfolio. Retirees who move everything from stock investments to bond and money market investments risk missing out on the potential gains generated by stocks once they recover.
- Contribute as much as possible to your retirement plan. If you are 50 or older, you may be able to make catch-up contributions which set aside an additional $5,500 for a total of $22,000 401k contribution for 2012. If possible, try not to borrow or make a large withdrawal from your retirement plan.
7. Are there any tax implications for my moves?
Did you sell an investment in December, hoping you could take a loss on your next year tax return?
If you want to buy the same investment in the current year, keep in mind you must wait for more than 30 days.
Otherwise, you violate the “wash sale” rule and you will not get the benefit of the loss to offset other capital gains.
If you have never met with a financial planner before, check out my guest post at Get Rich Slowly on 8 questions you should ask before you hire a financial planner.
How To File a Complaint Against Your Broker
Big losses have left investors infuriated.
Not sure of whom to blame, some have pointed fingers at their financial advisors.
Either citing their advisors ignored their instructions or, more importantly; disregarded their risk tolerance. The result of this has seen arbitration cases against brokers up 110% in previous years.
Filing for arbitration is not end of all means for investors, though.
Pursuing a case requires painstaking proof and even winning doesn't mean you will be made whole. Typically, investors will only recover 40% of their money.
If you are looking to fight back, here's what you need to know.
First, we need to look at what a financial advisor can or cannot do.
- Can make recommendations about specific investments.
- Can buy and sell those securities for you.
- Cannot make unsuitable recommendations based on your risk tolerance and investment history.
- Cannot making trades without authorization unless they have discretion.
- Cannot make misrepresentation or omission about the investment they are recommending.
How can you protect yourself from an unscrupulous broker?
There are have been many high profile cases of late (Madoff, Stanford) which have left investors wondering how they can really protect themselves.
Unfortunately, in the Madoff case, there was no protection; at least with background checks.
In this case, the old adage of “If it sounds too good to be true…..” applies like no other.
If you feel like there has been a wrong committed, follow these steps:
1. Try the Advisor
Sometimes there can be a breakdown in communication.
If you are questioning a trade, or something doesn't quite match up on your statement, give the advisor a call. There could be simple explanation and resolution of the matter.
Before calling, make sure you have all the proper documentation in front of you (i.e. confirmation statements, brokerage statements, concerns you have written down). This way you have all the facts on hand in case you don't get the answer you are seeking.
This documentation will be much more important as we proceed through the next steps.
2. Talk to Branch Manager or Compliance Department
If speaking to your advisor doesn't get you the answer you are seeking, then work up the chain of command.
Next step will be the branch manager or the firm's compliance department. Typically, the branch manager will be forced to resolve the matter in a timely fashion.
If that doesn't work, you could call the compliance department of the firm. The more detailed you can be, the better.
Especially, if you are looking for a quick resolution to the matter.
3. File Complaint With FINRA
After you've exhausted all your means with the investment firm, you now have the option to file a complaint with the Financial Industry Regulatory Authority (FINRA).
FINRA makes it simple to file a complaint by having an online form you can complete. Before you file, they will ask you if you have completed the following steps:
Before you proceed:
- Have you contacted the firm?
- Have you been defrauded by the firm or your broker?
- When should you complain?
- Are you seeking the return of money or securities?
4. File Arbitration
Arbitration can be a long and painful process.
According to FINRA's website, the average arbitration case is resolved in 11.8 months with simplified decision being resolved in 6.9 months.
If you feel you have a case though, it is most likely worth your time in the end. Especially, if the broker deserves it. Below is taken directly from the FINRA website.
You can also read more about the overview of the arbitration process.
Although most business in the securities industry is completed without a problem, disputes and controversies will occasionally arise. Such disputes and controversies can be resolved by impartial arbitration at one of the organizations listed in the services directory. Arbitration's are conducted in accordance with the Uniform Code of Arbitration (Uniform Code or UCA) as developed by the Securities Industry Conference on Arbitration (SICA) and the rules of the sponsoring organization where the claim is filed.
There are some differences among the rules of the sponsoring organizations, such as, the time to serve and file answers to claims, who may serve as public arbitrators, arbitrator selection methods, service of award methods, the availability of prior awards, and whether your name will be made publicly available. Any questions regarding arbitration may be addressed to the Directors of Arbitration or their staff at the sponsoring organizations.
Significant differences between the Uniform Code and the procedures of the self-regulatory organizations (SROs) will be highlighted in this guide. In addition to initiating an arbitration, investors may file their complaints with the appropriate regulatory authorities, such as the Securities and Exchange Commission (SEC), state securities commissions, or one of the SROs listed in the Services Directory, when they believe there has been fraud or other investors may be at risk. The regulatory agencies may then investigate the complaint and, if warranted, censure, fine, or suspend a wrongdoer.
These agencies normally do not recover investor's losses which can be done through arbitration. This information is designed to assist prospective parties and their attorneys by explaining arbitration procedures and is not designed to give legal advice to any party or to anyone who contemplates the use of these procedures. The procedures were developed for parties who represent themselves in an arbitration proceeding as well as those represented by counsel. The information here explains the procedures set forth in the rules and answers questions regarding them but is not an interpretation of, or a substitute for, the rules. We recommend prospective parties carefully read the rules.
5. Consult Securities Law Attorney
FINRA Dispute Resolution staff members are often asked to make recommendations or referrals regarding legal representation.
Since FINRA operates in a capacity as impartial administrators of this alternative dispute resolution forum, rather than specific recommendations, they can only offer the following guidance:
For general information on obtaining legal assistance, we suggest you contact your state, county, or city bar association.
The American Bar Association provides a lawyer referral service to help individuals find the appropriate help for their legal problems. You can learn more about this legal referral service by visiting the American Bar Association or by calling (800) 285-2221.
If you need help in finding a lawyer, you can review the guidance provided by the Securities and Exchange Commission (SEC). The SEC Web Site offers information about the bar.
Prevention Is The Best Solution!
DO A BACKGROUND CHECK!
Much of this could have been prevented had some safety measures been put in place. The first thing you MUST DO before hiring a financial planner is conduct a background check. A startling figure shows 70% of all new investors do no such check.
This statistic amazes me.
Here's a list of the following sources you check to see if your financial planner has anything on his record:
- FINRA BrokerCheck
- Securities and Exchange Commission – Check Out Brokers and Advisors
- National Futures Association BASIC Investors can conduct background checks on firms or individuals by utilizing the BASIC Search. BASIC contains CFTC registration and NFA membership information as well as futures-related regulatory and non-regulatory actions about particular firms or individuals.
- Brokerage firm bankruptcy – Securities Investor Protection Corporation
- Identity theft – Federal Trade Commission
- 401(k) claims – U.S. Department of Labor
- Choosing a Financial Advisor – CFA Institute
- Fraud Center – North American Securities Administrator Association