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Substantial Equivalency = Tough Work

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I think Lou Grumet’s December 2006 Publisher’s Column (“Interstate Commerce Versus Public Protection: Why Cross-Border Licensing Must Be Handled with Care”) summarized well the constitutional challenges related to the noble objectives of state protections and interstate commerce. Grumet’s middle-ground (my term) approach between where we are in our struggles with substantial equivalency and the newly rolled out exposure draft touting the “no notice, no fee” version is one that’s been discussed by the National Association of State Boards of Accountancy (NASBA).

It’s not that we disagree with Grumet’s well-stated approach; it’s the matter of effectiveness. To reach the substantial equivalency objectives that meet both constitutional mandates that Grumet described, we must no longer kid ourselves that some compromise approach will result in a grand reception by the states. We’ve tried that under the current version of the Uniform Accountancy Act (UAA), and it can be argued that we have more diversity and nonacceptance of substantial equivalency than we experienced before the revised UAA was adopted in 1998. So, we have determined that because compromise measures have not been at all effective for substantial equivalency, we would then be bold and go for the ideal situation and hope and trust that we will encourage our states to reach more nobly for a higher standard of substantial equivalency. As you know, it’s tough work—whether it’s New York, California, or Tennessee.

Thanks for the commentary and for being involved in the debate.

David Costello
President and CEO
National Association of State Boards of Accountancy (NASBA;

Raising Issues Not Enough

While I agree with Lou Grumet’s points in his February 2007 Publisher’s Column (“Social Security and the U.S. Tax Code: Ripe for Reform”), my feeling is that raising issues isn’t enough. I was always taught not to bring up a problem unless you offer a solution. That always forced me to think harder, and although the problem sometimes disappeared on its own, whenever I did come up with an idea the results paid off.

With all the resources available within the Society, it seems to me that you could develop a think tank on hot issues affecting the profession. Let the group conduct research and ask the members for input, then publish the findings/solutions/ideas for tackling the issue. We might not always hit the bull’s-eye, but I’ll bet we’d hit the target every time.

Barry F. Doll, CPA (Retired)
New York, N.Y.




















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