VSCPA Comments on UAA Exposure DraftApril 30, 2007 NASBA UAA Committee Dear UAA Committee members, The Virginia Society of Certified Public Accountants (VSCPA) welcomes the opportunity to comment on the exposure draft of proposed revisions to sections 7, 14 and 23 of the Uniform Accountancy Act (UAA). Thank you for your hard work on the UAA and your dedication to find solutions to best protect the public. The VSCPA has received feedback from its members on the exposure draft, and the VSCPA Board of Directors supports this important initiative. The VSCPA encourages all state boards of accountancy to adopt the UAA sections on no notification. States should model their systems after that used by the Virginia Board of Accountancy (BOA), which has been tremendously successful andallows for ease of practice without notification and still protects the public. There is no notification requirement for firms or individuals, so long as that person or firm is licensed in a substantially equivalent state or otherwise meets the Virginia BOA's substantial equivalency requirements. The VSCPA and its members greatly value the Virginia BOA's dedication to protect the public while allowing CPAs to easily practice in an increasingly fast-paced business environment. The VSCPA supports revisions to the UAA that do not require notification to state boards by CPAs with valid licenses. We feel these changes are necessary to adapt the CPA profession to today's business climate, and the proposed revisions do not hinder a state board's ability to protect the public. We do ask the Committee to reconsider provisions that require firms to register in conjunction with performing certain services. The VSCPA asserts that these provisions are not necessary to protect the public. There is no hindrance to enforcement by not requiring notification or licensure by any firm or individual, so long as that firm or individual complies with substantial equivalency requirements. That scenario has worked well, without problems, in Virginia. Furthermore, the VSCPA believes that adding such detail into the model act increases the likelihood of distinctions among states — and thus decreases the chance of achieving uniformity among all states. CPAs must be able to work within the new global economy, facilitated by instant communication. The CPA profession and regulatory bodies must work together to make that level of service a reality. No notification is the biggest step in that process. Please join Virginia in emphasizing the efficiency of automatic jurisdiction consent, and the ability to vigorously protect the public while increasing professional mobility. Again, the VSCPA thanks the UAA Committee for its efforts and the time invested in examining this and other issues. Thank you for the opportunity to convey our thoughts on the exposure draft. Should you have any questions or need additional information, you may contact me or Erin Collins, VSCPA government affairs director, at (800) 733-8272 or ecollins@vscpa.com. Sincerely, Bradley M. Roof, CPA, Ph.D. |
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