CFP BOARD OF STANDARDS
GENERATIVE AI
ETHICS GUIDE
A CHECKLIST FOR UPHOLDING THE
CODE AND STANDARDS
GENERATIVE AI HAS THE
POTENTIAL TO TRANSFORM THE
WAY CFP® PROFESSIONALS SERVE
THEIR CLIENTS.
This guide is designed to help
CFP® professionals address CFP Board recognizes
ethical issues that may arise
the importance of
under CFP Board’s Code of
the broader ethical
Ethics and Standards of Conduct
implications of AI for
(“Code and Standards”) when
society at large. This
using Generative AI in their
professional services.
checklist, however,
focuses on the specific
Generative AI is a type of AI that ethical obligations
creates textual, audio or visual articulated in the Code
content in response to a prompt and Standards.
or input based on the data on
which it was trained. Generative
AI is one type of technology
addressed in CFP Board’s Guide to CFP Board’s Technology
Standard (the “Technology Guide”), which includes a sample
technology evaluation checklist and extensive questionnaires to
use when evaluating technologies.
This guide focuses on “off the shelf” Generative AI platforms that
are available free or for purchase, and does not focus on custom-
built platforms. These “off the shelf” platforms vary by their ability
to offer privacy protection mechanisms and how much the user may
configure the data that is used to train the program. Some platforms
are for general use, while others are tailored specifically for financial
professionals and may produce more useful work products.
2
Ways a CFP® Professional Might
Use Generative AI
Used appropriately, Generative AI can offer significant benefits, enhancing
efficiency and allowing CFP® professionals to dedicate more time on aspects of
their business that Generative AI cannot replace, such as improving relationships
and providing personalized value to their Clients. Generative AI can be a good
starting point for idea generation, synthesizing information and refining work
product. Some ways a CFP® professional may use Generative AI platforms in their
professional services include:
Gathering information about a Client, such as taking and
summarizing Client meeting notes or aggregating and
summarizing Client documents, so long as the information
may be kept confidential;
Conducting initial research to assess strategies and
investments that are in the Client’s best interests;
Improving the clarity and comprehensibility of
communications to the Client and other constituents;
Creating or refining public-facing content, such as educational
information, articles, blogs or marketing materials; and
Generating ideas for building or improving a successful brand,
such as idea generation for business names.
3
RELEVANT STANDARDS
CFP Board’s Technology Guide examines the Duty When Selecting, Using and
Recommending Technology (the “Technology Standard”) set forth in the Code
and Standards (Standard A.14). The Technology Standard, which incorporates key
components of the Duty of Care and the Duty of Competence, applies to a CFP®
professional’s use of Generative AI. Other relevant standards include:
Confidentiality and Privacy: Integrity:
The obligation to keep confidential The obligation to act with
and take reasonable steps to secure integrity, including the prohibition
non-public personal information on making untrue or materially
about Clients. misleading statements.
Comply with the Law and Comply Duties When Communicating
with the Lawful Objectives of the with a Client:
CFP® Professional’s Firm: The obligation to provide
The obligation to comply with accurate information to the
the laws, rules and regulations Client in accordance with the
governing professional services, as engagement and in response to
well as policies and procedures of reasonable Client requests.
the CFP® Professional’s Firm.
4
ETHICALLY INTEGRATING
GENERATIVE AI INTO YOUR PRACTICE
A CFP® professional must comply with the Code and Standards, legal requirements,
and their firm’s policies and procedures. Determining whether the use of
Generative AI is appropriate, and what safeguards to take, depends on the facts
and circumstances, or “use case.” Generative AI is a tool. It cannot replace a CFP®
professional’s care, skill, prudence and diligence.
As with any technology, CFP® professionals using Generative AI remain responsible
for their final work product and must account for Generative AI’s limitations
and risks. In particular, CFP® professionals should be aware of the potential for
Generative AI to produce inaccurate, or even fictitious, output, often referred to as
hallucinations, such as presenting an outdated forecast for industry performance for
a year as the industry’s actual performance.
CFP® professionals must
Generative AI aids account for AI limitations and
CFP® professionals, but risks, including inaccuracies
doesn’t replace expertise. or "hallucinations."
Helpful for idea CFP® professionals are
generation, synthesizing responsible for the final
info and refining work. work product.
CFP® professionals should exercise caution when using Generative AI for work
that requires a reasonable understanding of assumptions and outcomes, such as
developing recommendations for Clients, if there are limitations in accessing the
data and algorithms that Generative AI platforms use for the output.
CFP Board developed the checklists below to help CFP® professionals uphold the
Code and Standards when using Generative AI.
5
ETHICS AND
GENERATIVE AI CHECKLIST
Before any use of Generative AI, I have:
Reviewed and complied with my firm’s policies and procedures relevant to the
use of Generative AI.
In the absence of firm policies and procedures, developed and followed
standards or guidelines for the reasonable use of Generative AI in my business,
such as appropriate use cases and limitations.
Performed appropriate due diligence on the vendor (or have a reasonable
basis to believe my firm has performed appropriate due diligence).
I have critically evaluated any output from a Generative AI platform for:
Accuracy (i.e., there is no inaccurate or misleading output).
Completeness, such as ensuring that an automated Client meeting summary
did not omit important information.
Material Conflicts of Interest, such as an automated recommendation of a
product that benefits the CFP® professional or the firm of the Client.
Inappropriate Bias, such as output skewed toward a particular investor
demographic that does not match the needs of the Client.
Before entering materials that contain, or reasonably may contain, Client
information, such as transcripts or notes of Client meetings or Client documents,
into a Generative AI platform, I have:
Chosen (or the firm has chosen) a Generative AI program that has privacy
protection mechanisms to protect confidential Client information, including
encryption of data sent to and from the Generative AI platform.
Ensured compliance with relevant laws and regulations concerning Client
information, particularly privacy regulations.
Considered and, where appropriate, adopted additional privacy protection
mechanisms, such as:
• If available, opting out of permitting the Generative AI platform to use my
data inputs to train the Generative AI model;
• Using pseudonyms, anonymization or other means to remove confidential
information before uploading materials.
6
Confirmed that the Generative AI platform stores output in a manner that
complies with applicable recordkeeping regulations.
Confirmed that the Generative AI vendor has committed to taking reasonable
steps to make me or my firm aware of any data breaches.
Provided Clients with information about my use of Generative AI, whether
through an updated privacy policy or a separate disclosure.
If recording Client meetings, gained the Client’s advance consent.
Confirmed the accuracy, completeness and reliability of the output, such as
by testing the Generative AI platform using a sample data set.
Before publishing materials, including articles, social media posts, marketing
material and branding, created with the assistance of Generative AI, I have:
Reviewed and followed my firm’s policies and procedures for using
Generative AI for advertising and social media.
Verified that the Generative AI’s terms and conditions permit publication of
the output.
Reviewed any underlying sources cited in the Generative AI output to ensure
they exist and the use of the source is accurate.
Added citations to appropriately attribute the work product of others.
Ensured that no portion of the output infringes upon another person’s
intellectual property (copyright protections).
Gained a reasonable understanding of the limitations on claiming copyright
protection on AI-generated materials.
Upon integrating Generative AI into my practice, I have developed a plan to:
Review updates to the Generative AI platforms I use, such as changes to its
data privacy provisions or the data it uses;
Periodically reevaluate the uses and outputs of Generative AI for accuracy
and appropriateness as my business needs evolve.
7
©2025 CFP Board Center for Financial
8 Planning. All rights reserved.
