My name is Jeffrey L. Saltzer, I'm a Certified Public Accountant licensed in the State of New York and I am Managing Director and a Member of SALTZER LASSAR PICCINNINI & COMPANY LLC, a CPA firm in midtown Manhattan. I am also President of SLP BUSINESS SERVICES, INC., a wholly-owned subsidiary of Century Business Services of Cleveland, Ohio, a publicly-owned company now referred to as CBIZ. I appear before you this afternoon to testify in support of Assembly Bill A-8600, and to specifically discuss the issues of 49% ownership of CPA firms by non-CPA's.

By way of background, I guess you might say that accounting and Certified Public Accountants are in my heritage and in my blood.

My father, the middle of three sons of an immigrant family, two months shy of his q0th birthday and only 4+ years since his retirement, worked his way through the City University system at night during the Great Depression to obtain his accounting degree and his CPA certificate which, by the way, has only three digits. By way of comparison, New York State is now at 82,000 in its issuance of Certificates.

My uncle, my dad's kid brother as he referred to him, was a public accountant under the G.I. Bill after the end of World War 11. He practiced in public accounting and I'm only sorry that he isn't alive to have reaped the benefits of his lifetime of work and education to receive the designation as CPA as one of the provisions under this proposed UAA Bill.

My mother's only brother is also a CPA practicing in his own firm, originally in Brooklyn before relocating to Florida, where his only child, my first cousin, is a Florida CPA, carrying on the family tradition.

So as you see, when I say that accountancy is in my genes and in my blood, you can just imagine what discussions were like around the dinner and holiday table, growing up in my family.

I figured out fairly early on that I wanted to become a Certified Public Accountant and I entered the State University System in this state with the intention of receiving my accounting degree. After college and while working for what was then one of the Big Eight, I continued my studies with a specialization in Taxation in the Masters program, right here, at Baruch College, which we fondly used to call "UCLA" because it's the "University on the Corner of Lexington Avenue."

My father was always in public practice and ran his own small firm located here in Manhattan until my mother's unexpected and premature death in 1975 and due to his advancing age, asked me if I was ready to leave the ivory tower of the Big Eight and join his practice in 1976. 1 have built that practice in the intervening years from a small solely-owned firm to one of 30 employees with many diverse areas of expertise, to the point where we were attractive enough to become the New York City flagship acquisition of a national firm such as Century Business Services, almost one year ago.

My father, though almost 90 and only in his fifth year of retirement, maintains his own homes in Long Island and Florida and still drives and is mentally and physically quite active. He is well aware of and endorsed the actions we took somewhat as pioneers, to be the first New York City firm to sell its non-attest assets to Century Business Services, and only the second firm in New York State, shortly after Goldstein, Golub & Kessler, a firm more than ten times our size, had accomplished the same thing only a few months earlier.

With that history as a backdrop and the many discussions I've had as the current chairman of the New York State Society Committee on Practice Management and with my colleagues within the State, with my partners and staff, and the inculcation of my father's generation of accounting rules and regulations, I think, with all due respect and in all honesty, I have earned the right to speak before this assemblage.

The current rules which my father became certified to practice in this State were last changed significantly before I was born. Clearly, in my opinion, they have not kept up with the changes in the economics of the world around us. We owe it to the public, to the private sector and even to the government to modernize and to change, not just for change's sake, but because change is long overdue, to allow us to be flexible enough to maintain our integrity in the changing financial world order. If CPA's do not adjust to the constant fluidity of finances, financial services, taxation, business and communications revolutions, we will become an anachronism that will clearly diminish our capacity, our respect and our ability to have a meaningful voice in public policy.

Today, as required under existing rules, our CPA firm is owned only by CPA's. All of the other services we provide are through an entity wholly-owned by Century Business Services. These services include incoming tax compliance; estate and gift taxes; use of trusts in appropriate circumstances; business and financial planning advice and consultation; information technology installation and training services; financial products and services under the auspices of wealth management; consultation in areas of specialization such as the AICPA's WebTrust and in ISO 9000 qualification for Certification are just some of the activities promoted by our mid-size firm here in midtown Manhattan.

Though the non-majority ownership of CPA firms by CPAs, often referred to as the "49% ownership rule" is different than the Alternative Practice Structure (APS) issues that are not presently being discussed before this forum, many of the same issues and realities of practice exist today in the bifurcated APS structure that exists in New York and most other states.

Many of my partners and I come from what was once the Big Eight, now the Big Five, and who knows, maybe soon the "Final Four" or even less. We still have many friends and colleagues who work within these giant entities and whether there is uniformity of agreement or not, they are still the leaders in our industry and set the standards of operation as our most direct competition.

These behemoth multi-billion-dollar operations are either approaching or exceeding half their gross revenue from services other than the traditional core competencies that were always the exclusive domain of CPA firms, i.e., auditing, accounting, and income tax services.

My partners and I recognized several years ago, to be able to compete for our best clients, we needed to provide an expansion of services outside those core competencies or we would be reduced to a very narrow available line of services, many of which have already been replaced (better, faster, more accurately and cheaper) by the computer. You might be interested to note that, by way of background, we have always been great believers in automation and in a firm that was one quarter its present size, we were fully automated, preparing tax returns and financial statements with licensed software totally inside our offices by 1985, at least five years before it became accepted practice for firms ten times our size.

I am not suggesting that my partners and I are great visionaries, however, I do believe that we are able to see the evolution of the performance and delivery of professional and business services, and it is clear that we are not afraid to be in the forefront of those changes, whether it was automation in the early '80s or realizing we needed the resources of a large national presence by joining CBIZ in the late '90s.

Depending on which publication you read, when it was written and how they gathered their statistics, two of the trade publications that produce such information on a national and worldwide basis have very recently shown CBIZ to be the sixth largest accounting firm in the world. Obviously, that would put us directly behind the Big Five, though the chasm in size between the Big Five and everybody else is a chasm larger than the Grand Canyon.

However, more importantly, to call CBIZ an accounting firm at all, is technically, legally and practically incorrect since, by law, CBIZ can't be an accounting firm, certainly not in the State of New York.

But all of that truly begs the question. To provide our clients, a very varied and we I I-rep resented mixture of the general public, both in terms of business entities and individuals, with an appropriate service, I do not believe that you need 100% CPA ownership to maintain the independence, objectivity and integrity that has been instilled in me since I learned to speak.

My father, of whom I've already spoken about too much, was also an attorney, licensed in the State of New York. His practice was limited to tax law as an adjunct to servicing his clients. I remember discussions as a youngster about lawyers being "officers of the court" though in my father's mind, the professional ethics and integrity required of a CPA surpassed even those of the legal profession. The public places its confidence in us. I don't know how much more sincerely I can indicate my lifetime inculcation in valuing the public's right to believe in the ethical integrity and professional standards that I bring to my daily function. I don't stop during the day and think, this is an attest function, I have one level of standards to follow; and this is business advice or tax minimization and therefore I'm free to think with the other side of my brain. That's logically and practically an impossibility that defies any rationalization. As a CPA I am who I am, I've had my training, and I am not about to minimize, jeopardize or sacrifice those ideals for money, success, power, authority or greed. Neither are my colleagues

Life within CBIZ has been a somewhat dizzying 11 months. Candidly, I will tell this esteemed assemblage that my partners and I have never been able to provide higher-level, more professional, well-constructed, competitively priced business and professional solutions to our clientele than we could during this 11 months. The marketplace demands it and I have been astounded by the acceptance of our clients, existing and newly-found, to the model of the one-stop-shop for providing professional services. In many ways, this was a natural expansion of the accounting and limited legal services that my father provided to his clients for 60 years.

Because of my position as President of a CBIZ subsidiary, I interact constantly with the leaders of the other non-accounting disciplines owned by Century Business Services. I can tell you, Mr. Chairman, un-categorically, that the ability to bring to my client services from non-accounting disciplines that are owned by the same entity that owns our non-attest functionality and has the same standards of acceptance, reporting and compliance, has allowed us to provide our clients with a level of professionalism, expertise and service that was unparalleled before this affiliation almost one year ago. Were my clients here today, they would most assuredly confirm to you that where they have interacted with other CBIZ subsidiaries, their satisfaction approaches delight. I can also tell you, from my partners and staff who have had CBIZ national training and education in other skill sets; that they are now better-qualified professionals to answer the myriad of issues that affect the small to mid-size business, issues that we never previously contemplated or considered as they are far outside the traditional accounting core competencies.

It is elementary and almost axiomatic to say that the plethora of regulatory requirements, business sophistication, automation, knowledge of available products and services that is required could never be accomplished had we remained as simply a mid-size accounting firm in midtown Manhattan providing traditional services.

If one accepts the now-almost-overused postulate that accountants are the most trusted advisors to their clients, something that I have witnessed first hand since I was a youngster and that I know is true, then expanding my ability to have non-CPA's participate as equity and voting owners of my firm will be the only way to continue to maintain that vaulted pinnacle that my clients have come to expect from their CPA.

The most recent signing of the President of the repeal of Glass-Steagall Act of 1933, something I'm sure this assemblage has and will hear many times today, has already caused and will continue to really cause greater confusion and concern among our clientele. Deregulation means change and this causes uncertainty and is unsettling to most businesses. More than ever, they will look to their most trusted professional to respond to where they might seek the best answers in a complex and evolving marketplace where the rules have yet to be written and the game plan has yet to be formulated, not to mention executed. Staying mired in our thinking as traditional CPA's only will hinder us and make us useless thinkers at the time when the greatest demands are being made upon us to be visionaries. Still with a dose of conservatism and a high degree of integrity, we need some freedom and independence to remain the ultimate purveyor of best practices and advice, who will be able to serve the public and the public interest as has come to be expected of us.

Thank you for this opportunity which allowed me to express my views.