Generative Artificial Intelligence (“GenAI”)
Generative AI (“GenAI”) refers to a class of artificial intelligence systems designed to create new content such as text, images, audio, video, or code, based on patterns learned from large datasets. Unlike traditional Artificial Intelligence (AI) models that primarily classify or predict, GenAI models are designed to produce original outputs that resemble human-created content.
The purpose of this notice is to provide guidance to CFP® professionals and QAFP® professionals (“Certificants”) regarding the use of GenAI. This bulletin establishes best practices for Certificants who leverage GenAI in financial planning activities, client communications, marketing, analytics, and internal workflows. It provides practical guidance on how to use GenAI in a manner that is ethical, client-centric, and reflects professional judgement. This guidance may also assist Certificants in complying with the FP Canada Standards Council Standards of Professional Responsibility (the “Standards”).1
Certificants and GenAI use
When considering the use of GenAI, a Certificant should take the following guiding principles into consideration:
Client-Centricity & Suitability
Certificants should use GenAI to augment not replace the requirement to exercise prudent and professional judgment. Consistent integration of AI tools to enhance workflows enables Certificants to dedicate more attention to complex planning, analysis, client relationship management and behavioural coaching, all areas where human expertise and professional judgement remain essential for client trust and decision-making.
Certificants should always ensure GenAI outputs are context-appropriate, accurate for each client’s circumstances and do not incorporate or reflect bias. The use of GenAI may embed historical biases that perpetuate through AI outputs. Certificants can safeguard against bias by ensuring thorough review of the inputs and outputs applying a client-centric lens.
Explainability & Transparency
Certificants should disclose when GenAI is used in analysis or communications and provide plain-language explanations of its role and limitations to the client. Certificants should explain to the client when GenAI is being used, how it is being used and what is being used to produce its output.
Validation & Documentation
The Standards require Certificants to always act diligently, which includes when using GenAI. Certificants should always cross-check GenAI outputs against authoritative data; record prompts, assumptions, sources, and final human edits to support the GenAI output; and always communicate material assumptions to clients. In validating the accuracy of a GenAI output, Certificants can safeguard against AI hallucinations. AI hallucinations occur when an artificial intelligence model generates plausible but false or nonsensical information. Certificants can ensure accuracy by verifying sources, validating the output and explaining outputs to clients, which can enable informed decisions.
Governance & Oversight
Certificants must consistently ensure that human oversight is applied to all GenAI outputs, by, for example carrying out regular audits; providing ongoing staff training on effective prompt use as well as best practices and cautions when working with GenAI; and actively monitor for bias or inaccuracies in AI-generated outputs.
Applying these guiding principles may help the Certificant comply with their professional obligations set out in the Standards with regards to the use of technology. This can also help Certificants fulfil their obligation to place the client's interests first when using GenAI. Certificants should advance their knowledge and technological proficiency, enabling them to use AI tools competently, verify outputs effectively, and appreciate the ethical considerations involved to comply with the above guiding principles and use GenAI responsibly.
Privacy and Confidentiality
Certificants must ensure GenAI usage aligns with privacy laws and their professional obligations set out in the Standards.
Certificants have an obligation to maintain client confidentiality, including when utilizing GenAI. Although GenAI can be convenient, Certificants must prioritize client confidentiality over convenience. Certificants should not use personal data in prompts; they should use anonymization/de-identification; have secure storage of client data; and conduct thorough vendor due diligence to ensure their clients’ confidentiality is preserved in accordance with the Standards, specifically the Principle and Rules pertaining to confidentiality.
GenAI Use Cases
By using Gen AI safely and knowledgeably, Certificants can improve how efficiently they deliver services to their clients. The following cases show ways Certificants might consider implementing GenAI into their practice, while ensuring that controls are in place to protect both clients and comply with their professional obligations.
