Regulation and Oversight Update
October 29, 2014
Curtis B. Lee, RTP Admin Chair
Stephen Haworth & Sharron Cirillo
Regulation and Oversight Committee
State Issues Pending/Anticipated
UAA Issues
AICPA Issues
How to Read and Analyze a Bill
PENDING / ANTICIPATED ISSUES
Montana
Wisconsin
Ohio
Delaware
Arkansas
Alaska
Illinois
Colorado
North Carolina
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Montana
MT 6558 2014 – Rule Changes
Lots of definitions
No public participation on licensing decision
Anonymous Complaints from “shall review”
to “may accept”
CPE not required to meet NASBA standards
unless self study
Wisconsin
• 2013 Act 210 Enacted 4.8.2014
• 120 hours to sit
• Attest service – SAS SSARS SSAE ASB of PCAOB
– Audit or other engagement
– Review or Compilation
– Examination of Prospective Financial Information
– Updated Code of Conduct
• Engagement Review
– Highest level of service SSARS SSAE and not peer reviewed
– Ascertain whether “Documents Conform” to Standards
• System Review
– Highest level of service GAS, Examinations, non public audits
– Designed to determine whether firms system of quality control …is
designed & enforced …reasonable assurance …conformity with
Standards No. 8 – all material respects
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Ohio
Effective June 2014 – pending Joint
Agency Review
Incremental CPE – first state in the
county
10 minute increments
Now working on conforming to UAA
February 2015 – Discuss Peer Review
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Delaware
At discussion stages now – not yet introduced
or written
PAs a dying class – December 31 2015
Peer Review for all (not currently required)
Codification to UAA
Arkansas
• Poll of states regarding requirement for Peer
Review and Quality Review for Public
Accountants
• Peer Review(CPAs) vs. Quality Review(All)
• Retirement of Quality Review?
• Access to program for PA’s?
Alaska
• Board of Accountancy is discussing the
definition of attest in Statute vs. UAA vs.
common knowledge and Approved Quality
Review Programs (compilations exempt).
• UAA does not classify Compilations as an
Attest Function.
• Quality Review(Any) vs. Peer Review (CPA)
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Illinois
SB 2774 HB 4381
Tax Preparer Registration Bill
“Commercial Tax Preparers”
Tax Franchises behind it?
Started as a Task Force Type Bill then
grew horns
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Colorado
HB 1285 – Died in the senate
Tax Preparer Registration Bill
Exempted Employees of CPAs
Lobbyist and Executive Director
North Carolina
• NC Board is drafting a response to the
proposed changes to the peer review
standards
• Plain paper financials not part of peer review
• Require language “no assurance”
• Preparation does not equal issuance vs.
“associated with” concept
• NC Board Supports the proposed changes
UAA Changes
Definition of Attest unchanged
Peer Review Standards Exposure Draft
AICPA
• SSARs 21
• Special Purpose Framework
• Updated Code of Conduct
The Responsibility Poem by Charles Osgood
There was a most important job that needed to be done,
And no reason not to do it, there was absolutely none.
But in vital matters such as this, the thing you have to ask
Is who exactly will it be who’ll carry out the task?
Anybody could have told you that Everybody knew
That this was something Somebody would surely have to do.
Nobody was unwilling; Anybody had the ability.
But Nobody believed that it was their responsibility.
The Responsibility Poem by Charles Osgood
It seemed to be a job that Anybody could have done,
If Anybody thought he was supposed to be the one.
But since Everybody recognized that Anybody could,
Everybody took for granted that Somebody would.
But Nobody told Anybody that we are aware of,
That he would be in charge of seeing it was taken care of.
And Nobody took it on himself to follow through,
And do what Everybody though that Somebody would do.
The Responsibility Poem by Charles Osgood
When what Everybody needed so did not get done at all,
Everybody was complaining that Somebody dropped the ball
Anybody then could see it was an awful crying shame,
And Everybody looked around for Somebody to blame.
Somebody should have done the job
And Everybody should have,
But in the end Nobody did
What Anybody could have.
Don’t be a Nobody.
Be a Somebody.
For the good of Everybody.
Now let’s ROC…
Regulation and Oversight
Analysis and Action
Or Analysis in Action…
Gather Materials
Homework 1-4
NSA 911 Contact
ASO Understanding and Consensus
Jeopardy
Gather your materials
• Copy of proposal
– Bill #
– Is it in the House or the Senate
– Regulation (usually from board website)
• Copy of the existing information
– Law
– Rules
• Computer
– With Microsoft Word
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Homework from next page
Caffeine
Three of your favorite practitioners
NSA 911
Homework
1. Create a secret decoder ring
– Summary of Each Section of Law
– Open MS Word (2 computers side by side)
• On computer 1 – open the existing law
• Click Review and New Comment to add sticky
notes on areas of concern or to summarize
• On computer 2 – list the law down the left by
section number
• Repeat for rules. List the sections on the same
page as the law
Homework
2. Create a Red Line Version
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Open MS word
Click review
Click track changes
Select show: final with changes
Make each change just like the bill or regulation
states
– Strikethough = delete – strike
– Underline = new
– Add comments as you go – i.e. does this effect that,
oppose because… check with Sally re…
3. Have a friend check the redline version
4. Print and distribute to 3 besties and / or our committee – See NSA 911
• Considerations
– with comments or without?
– revision with dates in the footer
– To turn comments/changes on/off for printing – review tab
Contact NSA Committee
• What issues do we see?
– Missed issues
– Validation
– Presentation – word smithing
• Background we can provide
• Testimony resources
• Strategy ideas
Develop ASO position and Strategy
• Is there a concrete position or set of positions??
• Impact on “special” populations
• Congruent with mission statement?
• OMB statement – financial impact
• Other states
• Consistency or Non Consistency with UAA
• What would your consider caving on? SHHHHHH!
• Who is the sponsor and “who” are they
– Who are they connected to?
• Committees, regular jobs, spouse/kids, volunteer boards
• Other Major Players
• Impact of similar legislation on fees – NFIB
• Related organizations to consider
This is Jeopardy…