Mark Koziel5:38
Well, you know, we had this, we created an OCBOA, you guys are both familiar with an alternative comprehensive basis of accounting, saying we don't have to use GAAP, we can use something else, tax basis. AICPA created FRF for SMEs, a financial reporting framework for SMEs, 10, 12 years ago. I was involved in that, and so it's there already. And I think that one of the it is underutilized in a lot of ways. We know some firms that have taken strategic advantage of it and they've promoted it to their client, which has actually given them additional marketing opportunities with the banks. When that first launched, I had a firm call me and say, 'We want you to come down and we want you to help talk to the banks with our people we're going to send in there.' I said, 'Well, as AICPA, I'm not going to go in there on behalf of the firm and sell it for you, but I would love to be a fly on the wall. So I'd love to go to that meeting of all the banks and just listen to what the bankers were saying.' And I thought going in there, all of the community banks would be all over it, saying that that would be a strategic advantage for them. And actually, the opposite became true. It was the larger banks who made local loan decisions up to about $10 million in revenues, Bank of America, SunTrust, all the like at the time, versus the community banks who said we are so scared of CFPB that we are not deviating from anything that's going to be standardized, and so therefore we're not going to be able to use it. And so it was just great learning for me and I think great opportunities for people to figure things out. The CFPB's Nelson has been eliminated, so who cares. SSARS 27 came out for client accounting services, that was approved I think in late December. That is to say that if you are doing strictly a CAS project for a client, you can follow the consulting standards, not SSARS 21. SSARS 21 says you do a duplicative review, you got to have all of these standards in place and potentially be subject to peer review, which scared a lot of small firms away. And so I think with that change, incredibly positive to understand what the business is. Firms were saying in their engagement letters because in SSARS 21 it said if you are not engaged to prepare a financial statement, you do not have to follow SSARS 21. So they would specifically put in their engagement letter, 'You are not engaging us to provide a financial statement.' Well, in our terms that means a full set of financial statement footnotes. You know what a proper financial statement package is, not here's a balance sheet and income statement that I just popped out of QuickBooks, right? And so, but clients look at this, they don't know what the difference is, and they're saying, 'Well, wait a minute. I thought you are giving us a financial statement.' Well, no, we are giving you a financial statement, but we're not really hired to prepare a financial statement. I mean, these I'm like, what? And our standards just kind of, the ARSC committee did a great job with everything and it just there was confusion in the marketplace. I think the standards were good, but it just there was confusion out there and that people wanted to kind of overread what the standards were saying. SSARS 27, I think, just cleans that up a bit from where it was before and eliminates the potential for confusion, let's put it that way. And I think that's a small firm advantage. I don't want to hear a firm saying, 'I'm not going to be a CPA firm because I don't want to follow the rules.' Right? That's what we started to hear and I think now it's a great opportunity because the CPA, that's our brand. We should be promoting being a CPA. Right. Right.