Skip to main content
News Release

CFP Board Publishes Guidance for CFP® Professionals Subject to NAIC Model Regulation #275

November 14, 2023

CFP Board has released a comprehensive guide comparing CFP Board’s Code of Ethics and Standards of Conduct (Code and Standards) to the National Association of Insurance Commissioners’ (NAIC’s) Suitability in Annuity Transactions Model Regulation (MO-275-1) (Model Regulation).

This comparison guide is designed to help CFP® professionals understand some important similarities and differences between the Model Regulation and the Code and Standards. If the Code and Standards sets a higher standard than the Model Regulation, then CFP® professionals are obligated to adhere to the Code and Standards.

“The foundation of the Code and Standards is its fiduciary duty,” said CFP Board CEO Kevin R. Keller, CAE. “As this guide makes clear, a CFP® professional makes a commitment to CFP Board to act as a fiduciary and, therefore, to act in the best interests of the client at all times when providing financial advice.”

Summary of Key Differences

The key differences between the Code and Standards and the Model Regulation are as follows:

  • The Code and Standards imposes a fiduciary duty. The Model Regulation does not.
  • The Code and Standards treats compensation as a material conflict of interest. The Model Regulation does not.
  • The scope of the Code and Standards is broader than the Model Regulation.
  • The Code and Standards applies a prudent professional standard. The Model Regulation does not.

Download CFP Board’s Codes and Standards Comparison Guide to NAIC’s Model Rule

More compliance resources — including FAQs, videos, fact sheets, case studies and other guidance resources to help CFP® professionals understand and comply with the Code and Standards — can be found at

about cfp board

CFP Board is the professional body for personal financial planners in the U.S. CFP Board consists of two affiliated organizations focused on advancing the financial planning profession for the public’s benefit. CFP Board of Standards sets and upholds standards for financial planning and administers the prestigious CERTIFIED FINANCIAL PLANNERTM certification — widely recognized by the public, advisors and firms as the standard for financial planners — so that the public has access to the benefits of competent and ethical financial planning. CFP® certification is held by nearly 100,000 people in the U.S. CFP Board Center for Financial Planning addresses diversity and workforce development challenges and conducts and publishes research that adds to the financial planning profession’s body of knowledge.


Joseph Feese
Director of Public Relations
X: @CFPBoard