As president of the Empire State Association of Public Accountants and as a practicing public accountant, I would like to state our position as to why this bill should be passed.

Without wasting your time as to how this bill came about, because I'm sure that you are aware how the birth of the enrolled public accountant came about in 1959. 1 would like to focus more on the present.

Presently, we have two classes of public accountants:

a) Enrolled Public Accountants

b) Certified Public Accountants

Both with the same rights, duties and responsibilities - both have the same continuing education requirements - both can perform the attest function with the same assurance and testing requirements - both can train CPA candidates to gain the experience required to qualify as "Certified Public Accountant." Therefore, it is unclear why we should have two classes of public accountants. We are only confusing the general public.

Chairman Sullivan, you and I have both heard that the enrolled public accountant should take and pass the CPA exam to qualify as a Certified Public Accountant. I ask you this "Is it fair to ask an enrolled public accountant to take an exam when he has provided his clientele with certified financial statements for forty years? I would like to remind you that the enrolled public accountant has been practicing public accounting for at least forty-six years. Shouldn't that count for something?"

At the present time we have registered approximately six hundred enrolled public accountants. Some would believe that by allowing six hundred public accountants to be grandfathered as CPA's would create problems for the present CPA. With more than thirty thousand CPA's , six hundred more would be like adding a glass of water to Lake Erie. Furthermore, they are already there except for the title.

I believe that it is time to stop the discrimination that has existed for many years. it is time to have One Class of Public Accountants "CERTIFIED PUBLIC ACCOUNTANTS" and stop the confusion that the general public has been experiencing. Assembly bill A8600 and Senate bill S4402 would do just that.

There is a great deal of confusion on who can prepare a compilation of a financial statement. The bill clearly states that only a CPA shall engage in the practice of public accountancy as defined by section seventy-four hundred one. Also the bill classifies the compilation of a financial statement as an attest engagement. Well, I don't believe that legislation should be passed that would restrict non licensees from performing a compilation statement, provided, however, that the standard AICPA accountants letter is now used. Some sort of safe harbor language is used disclosing that they are not licensed.

Finally on the matter of experience, I believe that if the law is changed requiring a bachelor's or higher degree with at least one hundred fifty semester hours of college education, the CPA candidate must then have one year of experience in auditing under the direction of a certified public accountant.

I trust that my position is clear and I would be happy to answer any questions that you may have of me. Thank you.

Joseph J. Renda
President E.S.A.P.A.