State Board Report
NASBA representatives have met, held conference calls and/or exchanged email regularly since 2014 with staff of the IRS, DOL, SEC and PCAOB, gaining a better understanding of the enforcement process at each agency, reported NASBA Regulatory Affairs Manager Stacey Grooms at the ED Conference. These meetings have resulted in the creation of various resources now housed in NASBA’s web page’s Enforcement Tools section. State Boards can find descriptions of the enforcement process, helpful links and contacts, and the Quarterly Enforcement Reports overview with links to the archived reports. The page also includes federal enforcement tutorials that provide background on the DOL, IRS and SEC, an explanation of their enforcement process, forms and contact information.
Through NASBA, State Board Executive Directors have received: the IRS Preparer Tax Identification Number (PTIN) holder list separated by state; the Quarterly Enforcement Reports, based on information from AICPA, SEC (A&A reports and litigation releases), PCAOB and IRS; the Federal Clearinghouse Audit report; and the DOL Employee Benefit Plan auditor list released in June 2014.
Ms. Grooms reported the Department of Labor has discussed drafting language to propose specific continuing professional education requirements for performing the audits it requires. The DOL is also preparing a frequently asked questions document to assist the State Boards in understanding the information in the Employee Benefits Plan auditor list.
A plan to permit State Boards to share the investigative resources of the AICPA is being considered, Ms. Grooms stated. This would coordinate the AICPA’s investigations of the Department of Labor and other governmental audit cases with the individual State Board’s enforcement efforts. The concept was approved by the NASBA Enforcement Resources Committee in November 2014 and was discussed at the March 2015 Legal Counsel Conference, for the participants’ input.
Ms. Grooms encouraged the Executive Directors to contact her to assist the NASBA Enforcement Resources Committee with its development of guiding principles for enforcement. The Committee is looking to facilitate the sharing of best practices among the Boards.
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