In Fruchter v. Fruchter (29 AD3d 942, 816 N.Y.S.2d 525 [2006]), the Appellate Division, Second Department, held that since it was undisputed that plaintiff did not finish the required courses to obtain an MBA degree and did not take all three CFA examinations required to receive that certification, and his MBA and CFA studies were not completed, any enhanced earning capacity which may result upon completion of these studies would not constitute marital property.