Authoritative Guidance Issued for CPA Personal Financial Planners
Personal financial planning is projected to grow at a rate double that of the accounting profession through 2017. The expansion of services in areas such as estate, retirement, risk management and investments and the increased demand for these services have led the AICPA to further enhance its authoritative guidance in the delivery of personal financial planning services for the benefit of AICPA members' clients and practices.
The AICPA Statement on Standards in Personal Financial Planning Services provides AICPA members with comprehensive, enforceable guidance and a roadmap for delivering PFP services consistently and confidently. The standards are built on the cornerstone of the CPA profession – the public interest – and align with the AICPA Code of Professional Conduct, which upholds the highest levels of integrity, professionalism, objectivity and competence. Following the statement ensures that members’ clients receive the information they need to make sound financial decisions and that the standard of care expected of members holding out as trusted advisers is met.
A robust toolkit has been developed to help members understand the depth of the statement and put it into practice by the effective date of July 1. The toolkit is available to PFP Section members and CPA/PFS credential holders as a member benefit. It is also available for purchase.
This informative podcast covers the ins and outs of the standards and how you will benefit from having a framework to guide your work with clients. (Email subscribers can listen to the podcast and see the slides on our website.)
SARAH G. BRADLEY: On behalf of the AICPA Personal Financial Planning Division, this is Sarah Bradly here to talk about the Statement on Standards in Personal Financial Planning Services. I'm joined by two members of the Responsibilities and PFP Services Task Force, Dirk Edwards and Clark Blackman, along with the leader of the PFP division, Andrea Miller.
This recording is brought to you by the AICPA PFP section, the premier provider of information, resources, advocacy and guidance for CPAs who specialize in providing estate tax, retirement, risk management and investment planning advice to individuals and their closely held entities.
Let me take a moment to introduce our task force members. Dirk practices as the firm Edwards Consulting, LLC in Oregon. His practice is devoted to the field of personal financial planning, serving clients throughout the US and Western Europe. Dirk has been a longtime volunteer at the AICPA, serving on various committees and task forces, and he is currently the chair of the Responsibilities and PFP Services Task Force, the group who wrote the PFP standard we are discussing today.
Clark is the founder and owner of Alpha Wealth Strategies based in Texas. He is a fee-only financial planner who provides investment advice and financial guidance to a small number of wealthy families. Clark has also been a longtime volunteer of the AICPA and is the immediate past chair of the responsibilities and PFP Services Task Force.
I can't say enough about these two amazing volunteers who have led the PFP standards effort, and we have another amazing leader with us today, and that's Andrea Miller from the PFP division. She'll be moderating with me today. She started her career with the firms Ernst & Young and KPMG. Along the way, she discovered her passion for personal financial planning and eventually came to work for the AICPA to help fellow CPAs understand the opportunities available in this full-service area of the profession.
So let's get right down to why we're here today. That's because the AICPA is promulgating the statement on standards and PFP services. Dirk, walk us through what we're going to cover in today's session.
DIRK EDWARDS: Absolutely. Thank you Sarah, and on behalf of both Clark and I thank you both for introductions, and to you all listening, thank you for spending a few moments trying to learn about the new standard that is getting ready to roll out for us all.
You'll notice on the list there that what we really want to accomplish in just a few moments is really to whet your appetite on what the standard and this new standard is all about, why it's there, how it came about, the types of requirements that are outlined in the standard, and particularly why you should care about what that is and how it can impact both your practice and your clients for what you're doing as you deliver personal financial planning services.
In addition, we hope to, again, just expose you to the beginning process of not only when would the standard be applicable, but all of the tools and resources that have been developed and are continuing to be developed to assist you in actually implementing the new standard into your practice.
So with that as background, let's actually move into what -- how we got to where we're at. You'll notice on the slide that when the PFP division began, we started as coming from the tax executive committee. Back in 1986, so over a quarter of a century ago, a core group of volunteers and very committed CPA financial planning practitioners, wanted to bring together the best folks to share ideas and resources as to what people were doing in the practices.
From that we developed what would be a practice aid to really summarize and talk about what would be good financial planning practice for a CPA. You'll note in that four-year process between 1992 and 1996 those, in essence white papers, were then published to really describe as a practice aid what does good financial planning process look like; not the specifics of how you do financial planning, because that's clearly always up to each individual practitioner, but what are the components and what are really the best things that would be contained within the planning process?
What we discovered after the publication of those practice aids is that some states -- in fact, seven different states -- actually adopted the statement of responsibilities, the SORs, as part of their board of accountancy requirements. So with what had started out as really a practice aid kind of morphed into a de facto standard.
In addition, we saw many practitioners really trying to apply what was the practice aid as if it was a standard, and so it became clear that we really needed to try to provide actual standards in a language in a way that would be using language and in a manner that would be really helpful to delineate the difference between just good practice and what would be a standard for financial planning.
The first step of that process was to go to the AICPA Council to elevate the personal financial planning executive committee to have standard-setting authorization. And so that occurred in the end of 2012, and as part of that, we simultaneously were taking the SOR and revising that to reflect both the basic concepts, but to put them into a framework that would actually be standards language for providing specific guidance and not just as a practice aid.
In the summer of 2013, that draft exposure was put out for public comment, and after a 90-day exposure period, the PF -- Personal Financial Planning Executive Committee on December 13 unanimously accepted and voted for the adoption of that new standard, which we refer to there with that very long acronym of the SSPFPS. And the standard, which has now been adopted, is rolling out with an effective -- indeed July 1 of 2014.
Depending upon when you are listening to this information, there is a variety of data that's available and tools that are ever-expanding to help you understand both what the standard says and how to implement it in your practice.
SARAH G. BRADLEY: Thank you, Dirk. Let's change gears here and get into the standard itself now. Clark, can you tell us a little bit about the foundation on which the standard is built?
CLARK M. BLACKMAN II: Sure, Sarah. The Foundation of these standards really starts with the code of professional conduct that all CPA members are required to follow, and the reality that as trusted advisors we have a fiduciary obligation to always act in our clients' best interest.
The code lays out a very high standard of behavior regarding competence, due care, disclosure and objectivity, to name a few. The highest degree of professional behavior is expected and required at all times. For example, a conflict that impairs objectivity cannot be disclosed away. It is either avoided or the engagement terminated.
With this as a backdrop, we attempted to capture the essence and spirit of the code in defining appropriate minimum behaviors for members providing PFP services. Listen, we all know that every planner has their own approach and no one should try to dictate exactly what goes into a financial plan or define how a financial plan is done. However, key and important aspects of interacting with and communicating to a client are essential to ensuring appropriate professional behavior.
I believe the statement does that effectively, and believe that the professional and the profession is well served by following the standards set for them in the statement. Sarah.
SARAH G. BRADLEY: Thank you, Clark. Now let's talk a little bit about the objective of the statement.
CLARK M. BLACKMAN II: Well, the statement accomplishes a number of things, but let's focus here on the most important. One, it provides clear guidance in key areas fundamental to the delivery of financial planning services. It addresses the key areas of communication, disclosures and documentation, as well as the basics of planning the engagement and the developing of recommendations and working with and recommending other professionals.
This will accomplish the following three things, though there are clearly ancillary benefits as well. First, it ensures that the client receives the information they need to make decisions. Second, it ensures that the member is meeting minimum standards of behavior expected of a trusted advisor, and finally it provides a clear path for members to implement and deliver the level of planning services that clients need today.
SARAH G. BRADLEY: Clark, let's talk about the impact on personal financial planning professionals. Why should they care about the standard?
CLARK M. BLACKMAN II: Well, technically, in theory at least, the statement only applies to members of the AICPA. However, many states will adopt the statement by their state boards of accountancy, and as Dirk mentioned earlier, states were adopting the statement on responsibilities as standards in their states.
It's fairly typical for states to adopt AICPA standards as their own. And obviously in those states, the statement becomes enforceable as law, and it becomes a violation that could lead to a loss of a CPA's license. So clearly, these are essential standards for any CPA who is practicing financial planning to become familiar with.
In other states without clear standards, if they don't adopt these, CPAs will probably find that they are going to be held to these standards in a court of law, should they get sued by a disgruntled client. So again, understanding these standards, whether or not you believe they specifically apply to you in your situation or not, is important.
The statement is going to have applicability to virtually any CPA who practices and delivers financial planning services. The statement can provide clear guidance for any financial planning professional that is concerned about meeting a fiduciary level of behavior. We believe that if followed as they're laid out, that the financial planning professional can be comfortable that they're doing what any good fiduciary would be required to do in delivering these services to their client.
I believe the impact is going to be very public -- very positive for the public. It's going to be very positive for the CPA profession, and it's going to be very positive for the financial planning professional as well. And though we don't have time to get into all the reasons why, I think most are obvious and don't need to be enumerated here. Clearly, these are the kinds of outcomes that we expect once we roll these standards out.
SARAH G. BRADLEY: Thank you, Clark. Dirk, let's change gears now and come back to you. Tell us about personal financial planning services and what activities are included?
DIRK EDWARDS: Let me try to do that, maybe, in a two-step process Sarah. With this first slide, you'll notice that what we've really tried to do is identify what are personal financial planning services. That really comes down to a process of identifying with your client their personal financial goals, what resources they have, designing strategies -- financial strategies for dealing with trying to accomplish those goals using those resources and then making personalized recommendations.
You'll note that all of that we have highlighted on this one slide for your reference, which comes directly from the standard. It's also important to recognize that the -- those services can be delivered either in writing, or it could be an oral discussion, an opportunity where you're just one-on-one talking with your client and it still could be the delivery of personalized recommendations which would then be covered by the standard.
Notice also that under the standard, that implementation of the recommendations or monitoring of the client's progress and/or updating the engagement are really separate engagements. Those engagements are covered by the standard, but by default you would not have as the CPA practitioner under the standard an obligation to do implementation or monitoring or updating unless you have specifically gone into that agreement with the client.
Now the normal types of activities that are covered are things like cash flow planning, risk management planning, which often can involve insurance, retirement planning, investment planning, estate wealth transfer planning, elder planning, charitable planning, education planning and income tax and overall tax planning. All of those are the normal typical types of activities that may be part of the financial planning process itself that would potentially all be covered by the standard as you deliver those services.
On the next slide, you'll note that what we've really tried to do is provide a quick, graphical summary to help you as the CPA practitioner understand when would the standards really be applicable to you in the delivery of financial planning services. It's important to note also that these activities -- you'll notice on the left-hand side, what I just mentioned, the types of components that go into normal personal financial planning, if you're doing any of those -- and it's important to hear, any of those -- it doesn't necessarily mean that the standard -- in fact, it specifically does not mean that the standard only applies if you are doing investments and are an investment manager. That's not the case. The standard could apply as you're doing any of those financial planning activities.
Then as you move to the center, if you're doing that type of activity, you'll notice there is a three-pronged test. First, are you representing to the public or your clients that you do financial planning services? So in other words, have you created the correct impression on your clients that they should expect you to have expertise in financial planning, that you really are doing personal financial planning?
If you're doing those activities on the left and you have represented to your clients or the public that you do financial planning, then the standard would apply to the delivery of those services. The next prong is if you're doing one of those financial planning activities, either one or more of them. Is that activity that you're doing, would it have required you to register as an investment advisor, and an investment advisor either under federal law or state law? If the answer to that is yes, then the standard would apply to you in the delivery of those services.
The third time that -- the third prong of when the standard would apply to you is if you're doing one of those financial planning activities and it results in you selling a product as a result of that activity. Then that would bring that activity under the coverage of the statement on standards in personal financial planning services.
Now if you have not represented to the public, if you don't engage in an activity that doesn't require you to register and you don't -- are not involved in an activity that results in the sale of a product, then while the standard on statements in personal financial planning services may not apply, it's also vitally important for you to remember that as a CPA, the entire rest of the code of professional responsibility does still apply to what you're doing as a CPA. That's a very important distinction for you to always keep in mind, that this new standard for financial planning is really based upon the foundation that's provided by the rest of the code of professional responsibility and the decades of experience of ethical activity and behavior and professional confidence that we have within the AICPA.
CLARK M. BLACKMAN II: Could I add something here, Dirk?
DIRK EDWARDS: Absolutely.
CLARK M. BLACKMAN II: -- just so that we're crystal clear on that flowchart. You know, the last one there says, "Do you sell a product as a result of the engagement?" If you look closely into the standards and explanatory material, it becomes clear that you don't actually have to sell the product, but the mere possibility of selling a product is enough.
Clearly, if there is any potential when you're financial planning process is done that the client is going to end up buying a product from you or an affiliated party, then you would be subject to this statement.
ANDREA MILLAR: I have a question. So if I'm a CPA and I'm just doing something like elder planning and I'm providing -- I'm giving personalized recommendations, are you saying that even if I don't have these other prongs of this flowchart I'm not required to follow this statement? Should I not follow these standards if I'm providing that service and giving personalized recommendations, but I'm not required to register as an investment advisor and I don't sell products? And what do you mean by do I represent the public or the client that I provide PFP services? Maybe I'm just describing them as elder planning services?
CLARK M. BLACKMAN II: That's a very good question. The first question that you asked is, "Does this apply to you if you're not selling a product, you don't intend or plan to sell a product and you don't need to register as an investment advisor." Yes, absolutely. And so the vast majority of CPAs who are doing financial planning for their clients are going to be subject to the statement, whether they sell anything or not, whether they give investment advice or not. So that's the first aspect of that question.
Then the second aspect is what do we mean by holding out or representing to a client or to the public that we're doing financial planning. First of all, you don't actually have to use the specific phrase "personal financial planning," or "I'm a personal financial planner." Literally any statement that would lead a person to believe that you're going to be -- or that you are holding out as providing advice, council, consulting relating to financial planning topics is going to require you to follow the statement."
It relates to you specifically and not to your firm. So you might be a tax person for a firm that does personal financial planning, but you just work with your clients on a tax basis and give them tax advice. Along the way from time to time you give them advice that could be construed to be personal financial planning, but you never have held out to do that. Your clients don't look at you as a personal financial planner, but as their tax advisor. As long as you're not selling products and as long as you're not giving investment advice that require you to be registered with the SEC, then this statement would not apply to you.
Of course, you've got other statements on standards that you otherwise need to follow because of the tax work that you're doing, and, of course, all of the code of professional conduct would apply to you as well.
ANDREA MILLAR: Okay, in the beginning --
DIRK EDWARDS: Andrea, let me just add one more thing too. Clark, you've done a great job of kind of summarizing when the potential is that the standard would apply to you. But keep in mind that even if the standard because you have not represented it to the public -- represented that you do financial planning doesn't apply, there is absolutely nothing that would keep you from still wanting to understand and apply what's in the standard because it truly is reflective of good practice.
Even though the standard may not specifically apply to a specific activity you're doing, you still would want to know what's in the standard as you're providing that type of advice.
CLARK M. BLACKMAN II: Yeah, that's an excellent point, Dirk. Thank you.
ANDREA MILLAR: Right. Because if I'm doing something on the left, these services that a lot of CPAs engage in, retirement planning, estate gifts, wealth transfer planning -- and Clark you had mentioned at the beginning that we have a fiduciary duty to our clients. Things may go beyond what we do at the AICPA. What happens if I do those services and somehow one day I have a client -- hopefully not, but what if they take me to court? Would I have been -- would it have been good for me to know these standards and follow them even if I don't meet the prongs of this test where they actually apply to me?
CLARK M. BLACKMAN II: Sure, I think that's absolutely true.
DIRK EDWARDS: And as an attorney, I can -- while not providing to any of you listening to this webcast specific legal advice, I can pretty much assure you that when you talk to your counsel, you don't want to be on the other end of that equation, where you don't know what these are and you have not followed them. The question is clearly, potentially going to be posed, "Why have you not?"
If you are doing the activities that would traditionally be part of personal financial planning, all those things that are on the left-hand slide -- or left-hand side of that slide number 10, you clearly are going to want to have an understanding of what the standard is and when it would be applicable. And it truly can help you in your practice with all of the practice guidance and aids that are coming up.
The type of question that Andrea posed is also addressed in a list of frequently asked questions that are a part of the standard itself, which is not the authoritative literature, but it's all the interpretive information to help you understand what's in the standard.
ANDREA MILLAR: And then on that first prong, do you represent to the public or clients that you provide PFP services, can you give a little bit more detail there? I know that we get a lot of questions from members saying, "Well, my firm puts it on their website that they provide financial planning services. Does that mean that I have to follow these standards?"
CLARK M. BLACKMAN II: Well, it certainly would if you were a sole proprietor. But if that isn't the case, and it typically isn't, if your client would not reasonably assume that you are a financial planning and doing financial planning, that you haven't specifically held yourself out to be that person, if it's clear that there is a financial planning person or department in your firm and you're not -- you're not in that department and you're not that person, then that would not -- you would not be deemed to be holding out as providing personal financial planning services.
To a degree, there is a common sense that we need to bring to the table in thinking through this. The important part here is -- and Dirk brought it up earlier, so I will bring it up again -- and that is if you get pulled in to court because of some bad advice or some advice that the client felt was bad advice and you were now defending yourself, you would need to be comfortable that you're in a position that you did not hold out, nor did your client -- nor should your client have believed that you were holding out to be a financial planner.
So that's the key element here, is common sense and your own good professional judgment. Would someone believe you are the financial planner that the firm is advertising or not.
DIRK EDWARDS: And two additional comments. I absolutely agree, Clark, with what you just said. And remember too that this standard really sits on top of to supplement and is based upon the entire code of professional responsibility that we all follow and actively support in the realm of competence and objectivity.
Everything that we're talking about here is specific to the financial planning activity, but it's still based upon the overall code of professional responsibility.
Last quick comment on it. Remember too that we do have frequently asked questions or FAQs that address these specific types of queries that Andrea is posing, if you want to look at additional information to see how would this statement apply to me and when would it potentially apply.
ANDREA MILLAR: Right. And it just goes back to reemphasize that if you were an AICPA member and the statement applies to you, then clearly you have to follow it. But then the additional element that the vast majority of state boards of accountancy adopt these standards, so if you're a CPA -- a licensed CPA, then this standard would apply to you even if you're not an AICPA member. The standard will likely apply to you because likely your state will adopt this standard.
Also can one of you speak a little bit more about if you're not a CPA in a firm, but you are an AICPA member? Would you need to follow these standards if they're applicable to you?
DIRK EDWARDS: Clark, do you want to address that?
CLARK M. BLACKMAN II: I would like to, but I missed part of your question, Andrea.
ANDREA MILLAR: Okay. Well, a lot of firms out there, as you all know, have a mix of CPAs and non-CPAs working in this area. If I happen to be a non-CPA and I have joined the AICPA PFP section because I need the resources, but I'm not a CPA, do I need to follow these standards?
CLARK M. BLACKMAN II: Well, sure because you're a member. All of the rules that are promulgated by the AICPA apply to their members. And so membership alone would constitute that requirement. Now, you know, again, I would suggest that this -- in reality makes sense to follow regardless of whether or not you fall within one of these definitions whether you're a member or not, because one, it's good practice, and two, it is a way to protect yourself in the event that there is a problem and you find yourself defending your actions, your process and your advice to your clients.
Yes, it applies to all members regardless of CPA status or not. But that really should be the secondary issue, and the first question is, "Am I doing financial planning for my client? If I am, I should follow the best practices possible in delivering that service." I think that statement does lay that out.
ANDREA MILLAR: Okay. Let's talk a little bit more about the second prong. Do you engage in activities that would require registration as an investment advisor under federal or state law? I often hear from members, they just assume that that would never be -- they would never need to register as an investment advisor unless they are picking and choosing stocks and bonds for their clients. Could you speak a little bit more about how I understand if I need to register as an investment advisor?
CLARK M. BLACKMAN II: Yeah. There are a lot of situations where a financial planner will cross the line and should be registered, including CPAs who do have an exemption for solely incidental advice for the other things that they're doing. But they cross the line without really being aware that they're crossing the line because it isn't just about picking stocks and bonds.
An investment advisor is any person who engages in the business of advising others as to the value of securities. Advising somebody on the value of security is a far cry from actually recommending stocks and bonds to a particular client. It also includes advising someone in investing in purchasing or selling securities specifically, but that can include mutual funds, which is deemed to be a security, and it actually can include providing specific advice as to particular money managers to invest in that are specific to a client's needs, because those money managers are going to be, in fact, buying and selling securities for the client's account.
The exemption for CPAs is there for those guys who maybe are doing generally tax work or audit work or whatever and they -- a client asks them their advice on something and that is clearly incidental to what they do for the client. But once you start holding out as being a planner/advisor, there is an SEC publication that came out many years ago called IHN-92, that lays out the ways that a CPA can lose that solely incidental exemption, and holding yourself out as an advisor in this area is the quickest way possible to lose that solely incidental exception when you're giving some investment advice.
DIRK EDWARDS: For you all that are listening, if this is triggering all sorts of questions in your mind, there is an extensive and excellent paper that the Institute has prepared for you for your use to address those questions. It really is about registering as an investment advisor. That's available. I think both Sarah and Andrea may reference this later on, but that's part of the materials that are available to you through your membership and your activity within the PFP division of the Institute.
But as Clark has mentioned, there is very, very detailed and comprehensive information and potential application to you in your practice depending on how you've held yourself out with the services that you provide to your client.
ANDREA MILLAR: Great. And that guide that Dirk mentioned, it's called the CPA's Guide to Investment Advisory Business Models and we will have that on the site that we talk about here in a second with all of the other resources. And that's available to all AICPA members, like Dirk said to help you in understanding this.
I know when I was in practice, I really had no clue about all of this and how quickly you crossed the line, so it's a very good read to help you in understanding this.
Before we get to the resources, let's just hit on maybe at least one example of do you sell a product as a result of the PFP engagement. I know a lot of the questions that we get along these lines of "What if I refer a client? I don't do the work in terms of managing assets, but I have clients that once they get to that point, I refer them to a broker and then I get a piece of the compensation from that." Is that considered selling a product?
DIRK EDWARDS: Under the statement --
CLARK M. BLACKMAN II: Yes it is.
DIRK EDWARDS: Yes, it would be. You are, in fact, being compensated for -- you as the CPA are, in fact, being compensated for that client purchasing that product.
ANDREA MILLAR: But if I went to, say, an attorney -- if I am doing this work and then I refer my clients to an attorney to draft the documents, and I have a referral fee arrangement with that attorney, is that also considered selling a product?
DIRK EDWARDS: Well, the attorney is, in fact, not delivering a product, per se. they're really delivering a service in the way of those documents that are being drafted. So that would not be the same as your referral to, say, an insurance broker who then implements recommendations and has the client specifically purchase coverage of some sort and then provides a referral fee back to you. It's a different type of setting.
CLARK M. BLACKMAN II: But clearly -- and whether or not -- let's take the attorney example. It would not constitute your selling a product, and you may not be subject to these -- the statement on standards. However, under the rules that you otherwise need to follow in terms of our code of professional conduct, you would need to disclose that compensation arrangement very clearly to your client.
DIRK EDWARDS: And while we're not going to, just due to time limitations in this presentation, we don't -- we're not really going to address in detail the provisions of the new standard related to referrals, there is a specific section where we do talk about and try to address issues that can come up with you as a CPA making referrals and what your obligations are under the statement.
SARAH G. BRADLEY: Well thank you all for that very important information and all of those questions that we get from our members. I know it will be helpful for them to have a better understanding of where to go from here.
We mentioned several resources throughout this session. I would like for Andrea to just recap what those are. Our AICPA's PFP division provides resources to support its members practicing in this area. So Andrea, can you tell us a little bit about what will be available to assist members in complying with the statement and where they can turn for more information?
ANDREA MILLAR: Sure. We have a standards and PFP services compliance toolkit that will be released as soon as the standards are issued or shortly thereafter at some point in January. This will consist of checklists, engagement letters, white papers, the frequently asked questions. That's where you will definitely want to go if you were listening in and any of those questions resonated with you that we just went through, that's where all of those are listed and recapped.
Again, we tried through all of the vetting with the tax division and with members and with small firms over the years of vetting the standard, a lot of this came from the questions that came from the constituencies that would be interested in this, as well as the PFP practitioners. I highly encourage you to look at those frequently asked questions in conjunction with the standard and then the checklists are really just the standard but done in a checklist format. You should not use that on its own. But it's just something to look at so that you can make sure that you're complying with all of the requirements of the standard.
The engagement letters are just templates, so that it can help you to give your clients the engagement letters they need. But clearly you need to customize for your own situation, your own practice, your own clients. We're just trying to help you understand some of the language that would need to be in there in order to comply with the statement. But again, you really need to read the statements on standards and PFP services as your foremost priority and ensuring that you understand it and apply it. These are simply practice aids in helping you to do that seamlessly.
You will be able to find all of this content at AICPA.org/sspfps, and if you have any questions -- because all of this is a work in progress. This is just the beginning of getting this out to members. We focused on what we felt was more important -- most important to help you all implement these standards as seamlessly as possible. But, of course, things will come up.
If you have further questions that aren't addressed in those FAQs, if you have anything that you need clarity on, if you have resources that you feel like, "Wow, it would be great if AICPA created those," so that, you know, you don't have to create it yourself at your firm. I'm sure if you have that thought, probably a lot of other firms have that thought.
Our goal here is to create these things for you so that every firm around the country is not having to recreate the wheel. So please if you have any questions at all, contact us at firstname.lastname@example.org. And again, all of this content will be delivered shortly after the standards are issued in January.