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    The War on Small Practitioners

    I just attended a webinar for Comps and Reviews. Long on Comps, very short on reviews but still worth the money. All seminar / webinars are deadly dull and this one was no different although less painful than others I've attended.

    An interesting point was brought up regarding the fact that the AICPA is supposedly there to "protect the interests" of CPAs. However, they cater to the large firms and seem complicit in the move to eradicate the small practitioner. I feel the fact is that the IRS and the FASB (with the aid of the AICPA) are actively working to push the small practitioner out of business. The speaker pointed out that the small practitioner has no voice, and he is right.

    Why? Several reasons come to mind - large firms have the large lobby (AICPA) to push FASB and the congressionally controlled IRS into creating more and more requirements and regulations and standards that make compliance heinously difficult for smaller CPA firms and especially sole practioners. They use their power to eradicate competitors. There are a few very large firms and many small firms.

    The speaker also pointed out that there was some talk of "Big GAAP" vs. "Small GAAP". Big GAAP would apply to very large and publically owned companies and Small GAAP would apply to small and privately owned companies. FASB doesn't like the idea and wants the smallest company to be subjected to the same reporting rules for attest (audit) engagements as the largest publically traded entity.

    This is a shame. Small businesses are the economic engine that drive our economy. They all need good solid financial reporting at some level - compilation, review, audit. I think banks are going to be demanding higher level financial statements more frequently in order to approve lending. Some small business are going to need loans just to afford the services from the large auditing firms.

    We have seen the effects of large companies paying huge fees to large CPA firms - collusion and shoddy work. It isn't that a small practitioner cannot do excellent work, it is that they perform for a lower fee. It's all about the money, and consolidating an entire engagement industry (attestation) into the hands of a very few has resulted in nothing except higher fees from lack of competitiion and lower integrity of financial reporting.

    Through SSARS 19, changes have been made to the preparation and perception of reviews. Reviews are now considered to offer "limited assurance". New requirements for "evidence gathering", new requirements for analysis, and of course those annoying changes to required wording that forces all preparers to change engagement letters, management rep letters, etc. Very time consuming for the sole practitioner. Very ineffective for anything else except to make it harder for a small practitioner to comply. Changes have been made to peer reviews. The result? Push the small practitioner out of reviews in the same manner as has worked in pushing them out of performing audits. In fact, just get rid of us entirely.

    If you are a CPA and perform compilations - including "Management Use Only" - you are required to undergo a peer review every 3 years. Do I "learn" anything from the peer review? No. Sometimes I find out that I've mis-worded some sort of note, but otherwise it's just all about paying the fees and climbing over the barrier so that I can perform engagements for clients who need my services at a price they can afford. And, I'm not underpriced. But, I sure don't charge like a large firm.

    The PTIN registration and other barriers are not to improve the tax profession. That is a "straw man" argument. Nothing is going to turn a bad preparer into a good preparer - PTIN registrations, tests, regulations, FASB, required CPE, peer reviews - none of these things force a bad preparer to become a good preparer. None of these things force or even encourage a bad preparer to choose a different line of work. If they are incompetent at what they are doing, they are probably not competent to do anything else that pays as well.

    This constant barrage of more fees, more regs, more rules, more requirements is going to push good preparers who want very much to comply to start figuring out that the cost / benefit isn't there anymore.

    I used to write technical manuals for the aerospace manufacturing industry and it paid well. I've always thought teaching college accounting or writing classes would be fun.

    Thanks for listening.

    #2
    Originally posted by BHoffman View Post

    Thanks for listening.
    Thanks for writing.

    And...I agree.

    P.S. I took a college writing course once and it was fun.

    Comment


      #3
      Just Beginning

      Tax preparer registration is just beginning to be seen for what I have predicted, when most of you were welcoming it with open arms. It was supported on the premise that we could rid our profession of sleazy and incompetent preparers.

      Mr. Hewitt, co-founder of Jackson Hewitt, and founder of Liberty Tax Service has stated that the large firms have nothing to fear from registration and regulation -- that it's effects will ultimately weed out the smaller firms and leave more opportunity for the storefront operations.

      Whereas you have the perspective of quality tax work and superior customer service, economically speaking he is correct. Bank regulators only enforce regulations on small banks, health inspectors only on smaller hospitals, FCC only on smaller radio/tv stations, Dept of Labor only on smaller employers, etc. etc. There is nothing to suggest that tax preparer regulations will be any different.

      And it is NOT about quality. The large companies who have the resources to fight regulators do not spend these resources on customer service as you might think. Call your giant phone company (for example) and talk to "Peggy" or call your large credit card company and talk to Saieed, or whatever. The resources are much more likely to be spent on lobbying and public relations than to provide service to the customer.

      Watch and see - BHoffman will be proved correct. It's all about the large institutions, govt and private.

      Comment


        #4
        I agree with all of the above, plus the fact that the ultimate goal of registration, preparer regulation, and efile mandates is to create a vast bureacracy of unpaid auditors for the IRS, just a step or two below the real thing. Eventually tax prepares will be little more than highly-trained clerks entering data into the system while looking for reasons NOT to claim deductions unless they're a slam dunk. The fear of losing one's precious permission from the government to continue in his/her profession will completely overwhelm any tendency to decide gray areas in the client's favor. As it is now, we're already more than 75% there.
        Last edited by JohnH; 07-01-2011, 03:36 PM.
        "The only function of economic forecasting is to make astrology look respectful" - John Kenneth Galbraith

        Comment


          #5
          The last

          audit I did was 1993 and the last review I did was 1999. I issue only compilations without notes and list I am not independent. I still have my "peer" next year... It is not much, but when everyone of my financials say I am not independent and it has no disclosures I still will have a $800+ charge for next year.

          While I do not like it I guess it may make our overall profession better. We have "created" more and more jobs. I think it is great to have local, state and national groups for representation of most CPAs. I just find it hard to figure out exactly what they do for me. Yes, the larger firms have the biggest influence, if your a big firm your happy with that. I have never had an outside person (banker, attorney etc) ever say this is really neat that you guys started doing that. Everything goes in cycles and eventually the tide will change, I think.

          Comment


            #6
            Bart - or Someone

            I know Black Bart does this from time to time, but I don't know how and would invite anyone to create a poll:

            Question: Do you think tax practitioner registration and enhanced regulations are good for the industry?

            Choices:

            ** Yes. Registration badly needed to rid our industry of unscrupulous and incompetent preparers who give us a bad name by association.
            ** Sorta. Needed to purge our industry of shoddy preparers and increase quality work but may turn into a Trojan horse because of bureaucratic regulations.
            ** No. Incompetent and sleazy preparers will scarcely be affected, regulations will create a burden of hoops for us to jump through and quality will not be the primary concern of the regulators.
            ** Not sure at this point.

            Comment


              #7
              Aicpa

              We've converted the discussion to tax practitioners as Ms. Hoffman began with CPA practice and transferred the allegory to tax practice regulation.

              Whereas I agree with her parallel, can we avoid this by maintaining our composition in NATP and NAEA? In the CPA practice, the AICPA (not the government) is calling the shots, and running the show to cater to the big nationwide CPA firms. We used to call them the "Big 8" but I don't know how many of them are left now.

              NAEA and NATP lack the regulatory authority, so the parallel is not exactly the same. I can foresee a preponderance of regulation for the mom 'n pop shops and largely ineffective for the big storefronts, but do the NATP and NAEA give us alternatives to what has happened in the CPA industry?

              Comment


                #8
                NAEA yes

                The NAEA has been helpful to many a member who was having a problem with the IRS - I hear about such cases from time to time without seeking them out.

                Comment


                  #9
                  Audits/ Reviews/ Compilations

                  Originally posted by BHoffman View Post
                  ...Through SSARS 19, changes have been made to the preparation and perception of reviews. Reviews are now considered to offer "limited assurance". New requirements for "evidence gathering", new requirements for analysis, and of course those annoying changes to required wording that forces all preparers to change engagement letters, management rep letters, etc. Very time consuming for the sole practitioner. Very ineffective for anything else except to make it harder for a small practitioner to comply. Changes have been made to peer reviews. The result? Push the small practitioner out of reviews in the same manner as has worked in pushing them out of performing audits...
                  Originally posted by JON
                  last audit I did was 1993 and the last review I did was 1999. I issue only compilations...
                  Audits - gone/ Reviews - going/ Compilations - targeted. I think that's the way it's headed.

                  Like JON I quit audits several years ago. Averaged 1-2 per year for very small contractors -- total assets typically were (as a painter put it) pickup, Purdy, and ladder. Advised last one it was just no longer worth the trouble to me. He bid a small, government housing job requiring an AR contractor's license (requiring an audited financial statement). No other licensed accountants around so he went to nearby metro area and returned in shock (my usual fee was about $300); saying "Those guys want $ 2,500 which is almost as much as I'll clear." He dropped out and a large outfit (charging twice his price) got it.

                  Comment


                    #10
                    Audits and Reviews

                    By requiring peer reviews, it discourages smaller firms from doing audits. I used to do Gas Revenue Audits which are nothing like the audits of financial statements. At one seminar, I mentioned that no one would actually be qualified to do a peer review of that type audit, but I was told that someone would be able to do it--which is very unlikely since very few people have ever done that kind of work which involves use of chromatograph analyses, analysis of gas flow schematics, contract settlement terms and has very little to do with debits and credits.

                    Comment


                      #11
                      It's a Global thing.

                      CFO.com provides essential analysis and expert advice for Chief Financial Officers to tackle organizational challenges, manage major risks, drive organizational value, and maximize their personal career potential.


                      GAAP accounting....going.

                      International Financial Reporting Standards....coming.

                      How will we report business operations on tax returns - GAAP or IFRS?

                      Will we have to re-invent the wheel in order to perform bookkeeping services?

                      Comment


                        #12
                        There may be HOPE

                        AICPAŽ & CIMAŽ is the most influential body of accountants and finance experts in the world, with 689,000 members, students and engaged professionals globally. We advocate for the profession, the public interest and business sustainability.


                        It looks like the AICPA is trying hard to get Private Company Financial Reporting standards out from under the crushing behemoth of FASB, and they seem serious about it:

                        AICPAŽ & CIMAŽ is the most influential body of accountants and finance experts in the world, with 689,000 members, students and engaged professionals globally. We advocate for the profession, the public interest and business sustainability.


                        The link above explains there may be a way for you to help by sending a letter to the FAF (Financial Accounting Foundation) that oversees the FASB and is currently "studying" the standards problem. They expect to make some decision in the fall of 2011.

                        If you're interested, here is a link to a video and I think it's worth the entire 11 minutes:

                        Comment


                          #13
                          I did my last compilation in 2006; I just won't do them because of the peer review and extra hours of gruelingly dull CPE required to perform even a compilation for a small firm. I do tax, biz consulting and audit rep only. Seems a waste of a CPA license, but....

                          I am actually looking forward to IFRS. It should make the form 5471 a lot easier (translating just from the international format to GAAP gives me a headache) even if I do have to take a class or two or three for it.

                          Comment


                            #14
                            You are so correct in your assessment!

                            Originally posted by BHoffman View Post
                            I just attended a webinar for Comps and Reviews. Long on Comps, very short on reviews but still worth the money. All seminar / webinars are deadly dull and this one was no different although less painful than others I've attended.

                            An interesting point was brought up regarding the fact that the AICPA is supposedly there to "protect the interests" of CPAs. However, they cater to the large firms and seem complicit in the move to eradicate the small practitioner. I feel the fact is that the IRS and the FASB (with the aid of the AICPA) are actively working to push the small practitioner out of business. The speaker pointed out that the small practitioner has no voice, and he is right.

                            Why? Several reasons come to mind - large firms have the large lobby (AICPA) to push FASB and the congressionally controlled IRS into creating more and more requirements and regulations and standards that make compliance heinously difficult for smaller CPA firms and especially sole practioners. They use their power to eradicate competitors. There are a few very large firms and many small firms.

                            The speaker also pointed out that there was some talk of "Big GAAP" vs. "Small GAAP". Big GAAP would apply to very large and publically owned companies and Small GAAP would apply to small and privately owned companies. FASB doesn't like the idea and wants the smallest company to be subjected to the same reporting rules for attest (audit) engagements as the largest publically traded entity.

                            This is a shame. Small businesses are the economic engine that drive our economy. They all need good solid financial reporting at some level - compilation, review, audit. I think banks are going to be demanding higher level financial statements more frequently in order to approve lending. Some small business are going to need loans just to afford the services from the large auditing firms.

                            We have seen the effects of large companies paying huge fees to large CPA firms - collusion and shoddy work. It isn't that a small practitioner cannot do excellent work, it is that they perform for a lower fee. It's all about the money, and consolidating an entire engagement industry (attestation) into the hands of a very few has resulted in nothing except higher fees from lack of competitiion and lower integrity of financial reporting.

                            Through SSARS 19, changes have been made to the preparation and perception of reviews. Reviews are now considered to offer "limited assurance". New requirements for "evidence gathering", new requirements for analysis, and of course those annoying changes to required wording that forces all preparers to change engagement letters, management rep letters, etc. Very time consuming for the sole practitioner. Very ineffective for anything else except to make it harder for a small practitioner to comply. Changes have been made to peer reviews. The result? Push the small practitioner out of reviews in the same manner as has worked in pushing them out of performing audits. In fact, just get rid of us entirely.

                            If you are a CPA and perform compilations - including "Management Use Only" - you are required to undergo a peer review every 3 years. Do I "learn" anything from the peer review? No. Sometimes I find out that I've mis-worded some sort of note, but otherwise it's just all about paying the fees and climbing over the barrier so that I can perform engagements for clients who need my services at a price they can afford. And, I'm not underpriced. But, I sure don't charge like a large firm.

                            The PTIN registration and other barriers are not to improve the tax profession. That is a "straw man" argument. Nothing is going to turn a bad preparer into a good preparer - PTIN registrations, tests, regulations, FASB, required CPE, peer reviews - none of these things force a bad preparer to become a good preparer. None of these things force or even encourage a bad preparer to choose a different line of work. If they are incompetent at what they are doing, they are probably not competent to do anything else that pays as well.

                            This constant barrage of more fees, more regs, more rules, more requirements is going to push good preparers who want very much to comply to start figuring out that the cost / benefit isn't there anymore.

                            I used to write technical manuals for the aerospace manufacturing industry and it paid well. I've always thought teaching college accounting or writing classes would be fun.

                            Thanks for listening.
                            I think you wrote this for me. These are my sentiments exactly. Thanks for thinking about me and the others trying to do the right thing and getting charged at every turn. I found out the other day I pay an additional $135 a year for sanitation because I have a home based business. What sanitation? I am slowly coming to the conclusion I'm not wanted as a good professional tax preparer and may have to look at going underground. Why should I have to? I don't mind paying my fair share in taxes but this is too much.

                            Peachie

                            Comment


                              #15
                              I think the real problem is our poor billing habits. We as a profession seem to have a hard time billing our clients for our time. We are still stuck charging someone a couple of hundred dollars for a tax return when the rest of the professional world won't even shake your hand for under $500.

                              Rather than complain about all the new regulations, why not capitalize on them as an excuse to double or triple our fees? I wrote a letter to all my clients a few years back explaining why everyone's fee was going up 30% due to e-file mandates. I lost one or two clients that year.

                              To prove my point, ask yourself why you object to more regulation? Is it because the rules are too hard? No. We are in the business of understanding and following rules. Then is it because of too much paperwork? No. We are in the business of filling out paper work. We all enjoy paperwork. Then what REALLY is the problem?

                              The REAL problem is we act like all this regulation should be at our own expense. We, as a profession, have a hard time billing our customers for all this new work.

                              Comment

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