The Mutual Fund Dealers Association (MFDA) is considering restrictions on who may hold themselves out to the public as a "financial planner".

In a consultation paper published on Sept. 4, the MFDA notes that, in most of Canada, advisors can call themselves financial planners without having met any minimum proficiency standards. As a result, the regulator suggests that investors can be easily misled about the actual abilities of those who use the title.

"To address these and related concerns, the MFDA is currently considering Rule proposals that would prohibit Approved Persons from using the title 'financial planner' unless they have appropriate proficiency," reads the paper.

As a first step MFDA staff have compiled a list of four of the more commonly used financial planning designations, namely Certified Financial Planner (CFP), Personal Financial Planner (PFP) and Registered Financial Planner (RFP), as well as the Planificateur Financier (Pl. Fin) designation that is regulated by the Quebec government through the Institut Québécois de planification financière and the Autorité des marchés financiers. The regulator is now asking for feedback from people in the industry about whether these four designations would be appropriate to serve as proficiency standards.

Commenters are being asked to explain the reasons behind their support of a particular designation (e.g. course work, exam requirements, related work experience, continuing education requirements, etc.). The MFDA also wants to know if there are other designations which might be appropriate for those who wish to hold themselves out to the public as "financial planners".

In addition, the paper contemplates the possibility of a grandfathering provision; if some advisors are to be grandfathered and allowed to use the title without having one of the approved designations, what criteria should apply? For example, should they be grandfathered and allowed to call themselves financial planners based on a certain amount of prior work experience, or according to other credentials and designations they hold?

Comments are to be submitted to the MFDA's director of communications and membership services Ken Woodard at [email protected] by Dec. 4, 2015.