My background:

I am a CPA with twenty-three years of experience providing advice to the public.

As the director of US Trust's personal planning and tax practices I work with app 100 CPA's and CPA candidates who provide services to over 2000 clients.

I am Vice President of the New York State Society of CPA's and a member of the Personal Financial Specialist Executive Committee of the AICPA.

I began my career with small accounting firms gradually moving into larger firms. I spent sixteen years with Ernst & Young serving as a New York Office and National Partner.

Basis for my underlying view:

The majority of CPA's are not working inside CPA owned firms. This trend will continue as the shape of the "Big Five" and Financial Service Industry adapts to serve the. advisory needs of clients into the next millennium, Regulations should be designed to include CPAs wherever they perform a service to the public.

Advice not assurance services is where the majority of CPAs focus their skills.

The speed of which clients make decisions and reliance on technology make many existing rules obsolete. Rules historically written regulating what a CPA does each quarter to perform assurance related functions constrict her ability to respond to a clients email with "'today's" financial information.

UAA Issues which I have specific comments:

Compilation as an attest function

The Experience Requirement

Commission and Fees

Compilation as an attest service:

If a compilation is the lowest form of written communication to a client, how can a CPA in a non-attest firm communicate to her client?

In other words, CPAs need a way to communicate information to their clients wherever they work. A compilation can not be included as an attest service as long as it remains is the lowest form of communication allowed by a CPA

However, more thought needs be given to regulating individual CPAs performing compilations under the UAA.

The Experience Reguirement:

Our experience requirement has focused on two key points:

• The length

• Assurance Services

The length has been lowered to one year for holders of advanced d egrees without any discernable lowering of quality. In fact, the mandating of the 150-hour curriculum makes this point moot.

Eliminating the need for a CPA to receive experience specifically in assurance services is the thorny issue. This proposed change ties directly into the reality that assurance is an area of specialization in which a minority of CPAs are qualified and in fact, do perform.

Commission and Fees

The negative slant comes from the perception that this mostly applies to those CPMs who want to line their pockets with revenue from sales of investment and insurance products. With full disclosure the public can direct their marketing power to those CPA!s who can meet their needs and their pocketbooks. For instance in the case of financial planning, pure fee based advice by a CPA is not affordable the much of the population. CPA's who can not receive commissions are forced to refer these clients to commission based professionals who may be less qualified.

Secondly, I'd like to describe what's already happening in the larger CPA (Professional Service) firms. Services have become it products" and the sale of these "products" results in additional revenue to the professionals that have sold them. Is this a commission or a more sophisticated version of allocating revenue to those that grow the business?

Take this further, imagine CPA's continuing to venture, merge, and otherwise connect with law firms, consulting firms and the financial service industry. What constitutes a mere allocation of income within a firm and what is commission? By dictating different rules for internal allocations versus external allocations we are not being fair to the public and we will be enforcing a trend for CPA's to merge their businesses with others.

To protect the public our rules should provide disclosure on:

How the CPA personally gets compensated from selling, delivering or referring the service or transaction.

How the CPA's firm get compensated from selling, delivering or referring the service or transaction.

The impact of any direct and indirect compensation arrangements on the cost to the buyer.

In conclusion

The shape, style and structure of a CPA and a CPA firm are vastly different today than yesterday. Debating at the state level about what is already happening nationally and globally will leave most CPAs out of our regulatory framework.

Our CPAs of tomorrow need to be educated, licensed and regulated in this new world of information and technology.