Testimony of
David E. Reid, Esq.
Carr Public Affairs, Inc.
The Coalition for Affordable Accounting
515 King Street, Suite 300 Alexandria, VA 22314 703-684-1110 (FAX) 7703-684-7912
before the
Committee on Higher Education of the
New York State Assembly
concerning
Proposed Amendments to the State Accountancy Statute (A.8600)
November 16, 1999

Good afternoon Majority Leader Bragman, Chairman Sullivan and distinguished members of the New York State Assembly. My name is David Reid and I am legislative counsel to Carr Public Affairs. I am here today representing the Coalition for Affordable Accounting and I will be making a brief statement on their behalf.

The Coalition for Affordable Accounting was formed by the National Society of Accountants (NSA), the National Association of Tax Practitioners (NATP), the National Association of Enrolled Agents (NAEA), the Accreditation Council for Accountancy and Taxation (ACAT), and H&R Block Tax Services in December 1998 to address the concerns these groups have with proposed legislation that would, if enacted, affect the rights of non-CPAs to practice and use their earned credentials.

The mission of the Coalition is to assure that consumers have access to an array of accounting services that are consistent with their needs at prices they can afford, and to preserve the legal right of all non-CPAs to offer these services on a competitive and marketable basis.

The Coalition respectfully requests that any state legislation that is introduced contain the following three provisions:

1.) Acknowledgment of the right of all accountants to prepare compilations and reviews;

In layman's language, a "compilation" (compiled financial statement) is prepared from checkstubs, worksheets or other information provided by management. It carries with it no assurance of any kind, so no real degree of reliance should be accorded the statements by outsiders. In addition, no substantial effort has been made to verify the accuracy of the figures being compiled. The compilation is helpful for interpreting business trends, the performance of product lines, analyzing cash flow and making management decisions.

A "review" (reviewed financial statement) is prepared after the accountant has made certain inquiries and checked the validity of certain figures that appear on the statement to assure that they are correct. A review, therefore, carries with it a significantly greater reliance than a compilation.

2.) Statutory provisions for the use of acceptable safe harbor language;

Safe harbor language is needed for those who provide compilation and reviews but are prohibited from using the standard "reports" language provided in the Statement on Standards for Accounting and Review Services (SSARS).

3.) Recognition of the right to use language and titles appropriate to services rendered and to state and advertise earned credentials.

The Coalition will oppose any proposal that attempts to disenfranchise non-CPA accountants by restricting their ability to practice in those areas that current law permits. The legislation supported by the NYS Society of Certified Public Accountants would restrict the ability of non-CPAs to perform compilations and reviews, as well as advertising their earned credentials.

With me here today is David Silverman from the NYS Society of Enrolled Agents; Jacqueline LaBarge from the National Association of Tax Practitioners; Harlan Boyd from the Accreditation Council for Accountancy & Taxation; and Michael Connors from the National Society of Accountants. H&R Block will not have a representative in attendance today; however, they have provided written testimony. These representatives will explain in greater detail the effect that legislation could have on their practices as well as their clients and will be available for questions following their testimonies.

Thank you.

Respectfully Submitted,
David E. Reid, Esq. Carr Public Affairs, Inc.

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