When Institutions Fail the Test: A Case Study in Accommodation Denial and Structural Blindness

In January 2024, I requested a standard testing accommodation from the Association for Financial Counseling & Planning Education (AFCPE): remote proctoring, due to a long-term, well-documented disability.

This same accommodation has been granted without issue by regulatory bodies like FINRA, the NMLS, and the Florida Department of Financial Services—each governing far more sensitive licensure regimes.

AFCPE denied it.

They demanded new medical documentation, closed the dialogue without resolution, and ultimately refused to engage in the kind of good faith, interactive process the ADA (42 U.S.C. § 12189) explicitly mandates.

When I filed a complaint with the U.S. Department of Justice, the DOJ declined to intervene—not for lack of merit, but due to resource constraints. The case was never dismissed on grounds of legal insufficiency. It simply didn’t make the triage cut in a gutted civil rights division.

Free legal clinics took no action. Pro bono counsel never responded. The systemic failure wasn't just within AFCPE. It extended across the very mechanisms meant to safeguard civil protections.

This Isn’t About a Credential

I no longer seek to hold the AFC designation. I’ve since outgrown the need for externally conferred legitimacy.

Today, my work is followed by professionals managing over $28.5 trillion in capital—nearly a quarter of global AUM. AFCPE’s refusal to engage says more about institutional rigidity than individual merit.

This is about structural accountability.

If institutions gate access to careers or credentials, they must be capable of honoring the rights of those they evaluate.

AFCPE failed.

What Comes Next

I’ve formally requested a refund per their own written offer. That will be the final transaction between us.

But this incident will remain part of the public record—not as a grievance, but as a case study in how systems collapse when they prioritize procedure over principle.

If you're an aspiring financial professional facing similar barriers, know this:

You don’t need gatekeepers who can’t see your value. Build systems. Reframe narratives. Or, if necessary, design a new credentialing logic entirely.

That’s what we’ve done at Causality Partners.

We credential relevance, not compliance.

And we see you.

— J.S. Faulkner

Causality Partners

St. Petersburg, FL