PREPROPOSAL STATEMENT OF INQUIRY
Subject of Possible Rule Making: (1) WAC 4-25-710 What are the education requirements to qualify to apply for the CPA examination?; (2) use of the title "enrolled agent" or the designation "EA"; and (3) WAC 4-25-640 Client's confidential information.
Statutes Authorizing the Agency to Adopt Rules on this Subject: (1) RCW 18.04.055(5) and 18.04.105(1); (2) RCW 18.04.350(9); and (3) RCW 18.04.055(2).
Reasons Why Rules on this Subject may be Needed and What They Might Accomplish: (1) In November 1995 the board expanded the education requirements for licensure to include one hundred fifty semester hours (a fifth year) and requiring fifteen semester hours in upper division courses. The expanded education requirements became effective on July 1, 2000. Given the magnitude of the impact of these requirements on applicants, institutions of higher education, community colleges, and the public, the board believes a review is appropriate to consider:
|•||Whether the intended results (from elevating the education) were achieved,|
|•||If unanticipated results occurred and the impact of those results (if any),|
|•||Whether elevation of the education requirements erected an inappropriate barrier to entry,|
|•||The impact on Washington's CPA and candidates from having the education requirements align with national standards (the Uniform Accountancy Act),|
|•||Whether the 1.5 multiplier for upper division courses should be reestablished, and|
|•||Other relevant factors identified during the research phase.|
(2) The board considered new statutory language effective July 1, 2001, and believes public input and discussion on the merits of rule making in the area of enrolled agents is appropriate. To accomplish: Clarification on the board's role in assuring that enrolled agents are authorized to use the title by the United States Department of Treasury to ensure that the public is not misled.
(3) The rule needs to include firm owners in the confidentiality requirements and, while requiring CPAs to maintain information as confidential, ensure a client relationship is not established by way of preengagement discussions with prospective clients. To accomplish: Public protection by ensuring privacy and record accessibility.
Other Federal and State Agencies that Regulate this Subject and the Process Coordinating the Rule with These Agencies: None.
Process for Developing New Rule: Agency study.
Interested parties can participate in the decision to adopt the new rule and formulation of the proposed rule before publication by contacting Dana M. McInturff, CPA, Executive Director, Washington State Board of Accountancy, P.O. Box 9131, Olympia, WA 98507-9131, (360) 586-0163, fax (360) 664-9190, e-mail firstname.lastname@example.org. The board plans to distribute the CR-101 to key stakeholders asking for preliminary comments/input by June 15, 2002. The board will discuss initial comments at its regular board meeting scheduled for July 26, 2002.
January 31, 2002
Dana M. McInturff, CPA