To: Nicola Neilon, CPA
Chair, NASBA Uniform Accountancy Act Committee
Re: Exposure Draft: Uniform Accountancy Act’s Model Rules, Rule 5-7 Retake and Granting of Credit Requirements
The Board of Directors (the “Board” or “we”) of the Indiana CPA Society (INCPAS) appreciates the opportunity to comment on NASBA’s proposed amendments to the Uniform Accountancy Act’s Model Rules, specifically the rewrite of Rule 5-7 Retake and Granting of Credit Requirements. The comments and recommendations within this response represent the position of the Board rather than any individual members of the Board or the organizations with which such members are associated.
We value the informed and thoughtful proposal brought forth in the most recent version of the UAA Exposure Draft (ED). The coordination between the NASBA CBT Administration Committee, NASBA Uniform Accountancy Act Committee (the “Committee”) and the NASBA Board provides substantive, immediate support to those wishing to enter the CPA profession.
Our Board supports the Committee’s proposal to expand the length of the 18-month rolling window. We believe the 18-month window creates an unnecessary burden for those wishing to enter the profession as it does nothing to enhance quality or quantity. However, while we encourage expansion, we don’t think the proposed exposure draft is ambitious enough.
We encourage the Committee to consider a 36-month to 60-month window. A five-year period aligns with firms’ expectations for licensure while also giving the candidates the flexibility they need and want. If 60 months is beyond the comfort level of the Committee, we recommend expansion to 36 months, at least. Thirty-six months represents a substantive change that aligns with temporary expansions now in place in many states as we transition to the new CPA Exam, which reduces confusion.
This change, though it appears simple, will be beneficial for the profession. Thank you for your leadership for the benefit of the profession. And thank you for allowing us to respond to this Exposure Draft.
Sincerely,
Courtney J. Kincaid, CAE, IOM
President & CEO
Indiana CPA Society
Diane Sturek, CPA
Chair of the Board
Indiana CPA Society
Read the full exposure draft. You may send your comments or recommendations to the UAA Committee at uaacomments@nasba.org by April 17, 2023.