Honorable Chair and Members of the Committee, I am Michael Gleespen, Vice President of Regulatory Compliance for Century Business Services. I am here to speak in favor of the bill.

Prior to coming to Century, I was counsel to the Ohio Accountancy Board when it became the first state to consider the propriety of what have become known as Alternative Practice Structures. These business organizations are essentially an association between a registered CPA firm and an. unlicensed business services company. In the Century model, only the registered CPA firm provides audit, review and compilation services and other services that can only be provided by a licensed CPA. The business services company associated with the CPA firm provides all other services that can be provided by any unlicensed person. Most, if not all the owners of the CPA firm become the employees of the business services company as well. These structures were found acceptable. - last year by the Office of the Professions in several opinions that closely resemble the opinion issued by the Ohio Board in 1997. Based on the opinions of the Office of the Professions, Century undertook an association with Saltzer, Lassar & Piccinnini, a New York CPA firm, earlier this year.

I am here because Century supports the profession's efforts to adopt the Uniform Accountancy Act. We believe these amendments foster the principles of conduct and standards of practice that differentiate Public Accountancy as a profession regardless of the context of the CPA's employment. Whether in a CPA -firm, or in any unlicensed company, these amendments ensure that a CPA will always act like a CPA.

Consistency in the professional conduct of CPAs regardless of the nature of the employer has always been a principal concern of Century Business Services. From the time the founders of the company first visited with the Ohio Board to determine what regulatory principles would govern Alternative Practice Systems, to the present when the corporate operations of Century are undergoing the first peer review of its kind to determine its compliance with independence and other professional standards, the CPAs who run and work in CBIZ companies have taken great pains to design compliance systems and encourage conduct that meet standards. The proposed legislation honors these same principles.

The amendments do nothing to diminish conduct standards applicable to CPAs working in any type of business organization. On the contrary, they make it clear that individual licensees must honor the public perception that, no matter where he or she works, a CPA is a CPA is a CPA. Moreover, it reserves to registered CPA firms the services most uniquely identified with the public accounting profession-attestation engagements, including audits and reviews. In this way the amendments perpetuate the protection present in the current law. Only autonomous registered firms, undergoing the additional scrutiny to which such firms are subject, can provide those special services. CBIZ companies do not offer such services, and in accordance with our 10-year agreements with the CPA firms that associate with us, we cannot.

The CPA firms that associate with CBIZ are all 100% CPA owned, and therefore we have no self-serving reason to favor non-CPA ownership. Even under the non-CPA ownership provisions of the proposed legislation, CBIZ could not become a non-CPA owner of a CPA firm. That night would be given only to individual people, and not to a public corporation such as CBIZ. Frankly, non-CPA ownership should not be a particularly troubling idea since most of the Big Five and many other smaller national and regional firms functionally have had such ownership for many years. What is the difference between a licensed CPA who is a "partner" and a non-CPA "principal" in such firms? The only practical difference is in the spelling of the word. In payment and influence, unlicensed persons have been and are the equals of the CPAs who are the legal owners of such firms. The quality control systems and requirements that govern any individual working in a CPA firm apply to non-CPA service providers in firms as well. These requirements and processes are effective in preserving conduct and practice standards. I am not aware of any research that suggests that current quality control standards are insufficient to ensure that non-CPAs who provide services through a CPA firm obey the rules of conduct that apply throughout the firm.

CBIZ supports the commissions and fees provisions of the bill. This legislation puts New York CPAs on the same footing with practitioners in the majority of jurisdictions, and is consistent with the profession's standards of conduct. Where there is no compelling reason to prohibit such fees, their payment and acceptance should be a matter of discussion between CPAs and their clients. Where a CPA provides attest services, it is the rule in most jurisdictions that the principles of independence, integrity and objectivity require more. The bill also recognizes this fact, and does not allow New York CPAs to accept such fees. In other words, New York CPAs will be held to the same standard that prevails throughout the profession. Requiring this consistency does not diminish the professionalism of New York CPAs.

By permitting CPAs to refer to the fact that they are licensed CPAs, the legislation does nothing new. As the Office of the Professions stated in its opinions last year, such references are protected by constitutional free speech guarantees and are permitted under current law. CBIZ also supports the proposed legislation's provision that only registered CPA firms should be allowed to refer to the CPA title, or to call itself a CPA firm. That right should be reserved to registered firms. To allow otherwise could create confusion in the minds of current and prospective clients, and in the public, regarding the differences between a registered firm and unregistered business services companies. The proposed legislation avoids that confusion.

Thank you for your time and attention. I truly appreciate the opportunity to appear before you.