hard · Certified Financial Planner Professional Conduct

Elena, a dual-registered certificant, meets with the Ruiz household to discuss a $580,000 rollover from Mr. Ruiz's former employer's 401(k). Elena’s firm is currently running a sales contest for a proprietary variable annuity that offers a higher payout than the firm's standard advisory accounts. Mr. Ruiz expresses interest in the annuity's 'guaranteed' features.

According to the CFP Mindset hierarchy, what is Elena's required first step?

  1. Analyze the internal expenses of the proprietary annuity against a low-cost IRA rollover to satisfy the Duty of Care.
  2. Recommend the annuity if Elena's analysis shows the 'guaranteed' features meet Mr. Ruiz's stated goal of principal protection.
  3. Disclose the material conflict of interest regarding the firm contest and the higher compensation associated with the annuity.
  4. Gather additional quantitative and qualitative data regarding the Ruiz family’s overall tax picture and liquidity needs.

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