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The department states no rule changes were made in response to comments from NYSSCPA, NYSSEA, the EA/CPA, or the preparer, while changes were made in response to Assembly Members’ comments. The document summarizes Task Force recommendations on CPE, competency exams, and requirements supporting both federal and New York State tax competence, addressing concerns about credits, phase-in timing, exam waivers, and client-record return provisions.",{"@graph":69,"@context":123},[70,84,106],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":20,"@type":76,"position":81},"https://docshare.wps.com/document/exam/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/assessment-of-public-comment-department-of-taxation-and-finance/394569/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/assessment-of-public-comment-department-of-taxation-and-finance/394569.png","ImageObject",300,407,{"name":92,"@type":93},"dhado","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-11-04","2026-09-26",true,{"@type":102,"interactionType":103,"userInteractionCount":105},"InteractionCounter",{"@type":104},"ViewAction",14,{"@type":107,"mainEntity":108},"FAQPage",[109,115,119],{"name":110,"@type":111,"acceptedAnswer":112},"Which proposal and who submitted comments on it?","Question",{"text":113,"@type":114},"Comments were submitted on proposal TAF-38-13-00002-P by NYSSCPA, NYSSEA Government Relations Committee, New York State Assembly Members including Kenneth P. Zebrowski, Helene Weinstein, and Herman D. Farrell Jr., as well as an individual who is both an EA and CPA and a tax return preparer serving a small number of clients.","Answer",{"name":116,"@type":111,"acceptedAnswer":117},"Were changes to the rule made after reviewing all comments?",{"text":118,"@type":114},"No changes were made in response to comments from NYSSCPA, NYSSEA, the EA/CPA, or the tax return preparer. The department indicates changes were made in response to comments by the Assembly Members.",{"name":120,"@type":111,"acceptedAnswer":121},"What was the dispute over continuing professional education (CPE) and exam phase-in timing?",{"text":122,"@type":114},"NYSSEA recommended increasing initial annual CPE credits and proposed strict criteria for defining “experienced,” while also urging that the competency examination be phased in over 1 year rather than the proposed 3-year period. The Task Force concluded the proposed approach balanced competency, honesty, and avoiding undue barriers.","https://schema.org",{"og:url":83,"og:type":125,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":127,"canonical":83},"index,follow",{"doc_id":129,"site_id":62},394569,1790517559,{"code":4,"msg":5,"data":132},{"doc_id":129,"user_id":133,"nickname":92,"user_avatar":134,"doc_module":4,"category_id":19,"category_name":20,"doc_title":65,"doc_description":67,"doc_content":135,"file_id":136,"file_url":137,"file_type":138,"file_size":139,"view_count":105,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":24,"language":140,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":67,"update_tm":144,"read_time":145,"preview_page_count":4},5909893218464,"https://ap-avatar.wpscdn.com/davatar_085a072bc5b1113ac321206ff7593b45","ASSESSMENT OF PUBLIC COMMENT  \nDEPARTMENT OF TAXATION AND FINANCE  \nWritten comments were received regarding proposal TAF-38-13-00002-P from the New York State Society of Certified Public Accountants (“NYSSCPA”), the New York State Society of Enrolled Agents (“NYSSEA”) Government Relations Committee, and New York State Assembly Members Kenneth P. Zebrowski, Assembly Chair of the Administrative Regulations Review Commission, Helene Weinstein, Chair of the Judiciary Committee, and Herman D. Farrell, Jr., Chair of the Ways and Means Committee. The department also received comments from an individual who is both an enrolled agent (“EA”) and a certified public accountant (“CPA”) and from a tax return preparer who prepares returns for a small number of clients, including senior citizens. As described below, no changes to the rule were made in response to the comments from NYSSCPA, NYSSEA, the EA/CPA, or the tax return preparer. Changes were made, however, in response to the comments by the Assembly Members.  \nSection 4 of Part VV of Chapter 59 of the Laws of 2009 required the Commissioner of  \nTaxation and Finance to convene a Task Force on Regulation of Tax Return Preparers (the “Task Force”) to prepare a report (the “Report”) regarding the regulation of tax return preparers, and authorized the Commissioner to promulgate regulations to implement any of the recommendations of the Task Force. This rule was proposed pursuant to this authority to implement certain of the recommendations of the Task Force set forth in its report dated September 28, 2011. The Report makes recommendations regarding the scope of the regulatory scheme and appropriate professional qualifications for tax return preparers, including, but not limited to, educational qualifications and continuing professional education requirements (“CPE”) .  \nBoth NYSSCPA and NYSSEA expressed support for the regulation of tax return preparers generally but articulated concerns with certain provisions of the proposed rule. NYSSEA is of the opinion that the number of credits of continuing professional education (“CPE”) required for commercial tax return preparers should be  \n-2-  \nincreased from the proposed initial 16 credits annually for beginning tax return preparers and 4 credits a year thereafter, and 4 credits annually for experienced commercial tax return preparers. NYSSEA also recommended strict requirements for determining whether a preparer would be considered “experienced”. The Task Force reviewed the CPE requirements imposed on tax preparers by other states and the IRS and concluded, as does the department, that the proposed requirements achieved the appropriate balance between ensuring competency and honesty in the field of tax preparation and creating undue barriers to working in the field. (Task Force Report, page 13)  \nNYSSEA recommended that, in the interest of the tax paying public, the competency examination requirement should be phased in over 1 year, rather than the proposed 3-year phase-in period. The tax return preparer, on the other hand, advocated for a “grandfather” clause waiving the exam for tax return preparers with an extended record of preparing New York State tax returns without errors or client complaints. The Task Force examined the CPE requirements for tax return preparers in other states and at the federal level, and determined that a 3-year phase in period would appropriately balance these competing concerns—the taxpayers’interest in competent tax preparation and the need to avoid unduly burdening tax return preparers. (Task Force Report, page 14) The department concurs.  \nThe EA/CPA took the view that the department should dispense with its exam entirely and require all commercial tax return preparers to pass the IRS enrolled agent exam. New York State recognizes the professional requirements applicable to EAs by exempting them from the registration and exam requirements. However, it was the opinion of the Task Force, which is shared by the d","cbCaiuD7lwKbU5mO","https://ap.wps.com/l/cbCaiuD7lwKbU5mO","pdf",17490,"English","# ASSESSMENT OF PUBLIC COMMENT\n## Proposal TAF-38-13-00002-P and commenters\n## Task Force authority and regulatory recommendations\n## CPE credits, phase-in timing, and competency examination\n## EA/CPA perspective and New York State tailored testing\n## Client records provision concerns and clarification","[{\"question\":\"Which proposal and who submitted comments on it?\",\"answer\":\"Comments were submitted on proposal TAF-38-13-00002-P by NYSSCPA, NYSSEA Government Relations Committee, New York State Assembly Members including Kenneth P. Zebrowski, Helene Weinstein, and Herman D. Farrell Jr., as well as an individual who is both an EA and CPA and a tax return preparer serving a small number of clients.\"},{\"question\":\"Were changes to the rule made after reviewing all comments?\",\"answer\":\"No changes were made in response to comments from NYSSCPA, NYSSEA, the EA/CPA, or the tax return preparer. The department indicates changes were made in response to comments by the Assembly Members.\"},{\"question\":\"What was the dispute over continuing professional education (CPE) and exam phase-in timing?\",\"answer\":\"NYSSEA recommended increasing initial annual CPE credits and proposed strict criteria for defining “experienced,” while also urging that the competency examination be phased in over 1 year rather than the proposed 3-year period. The Task Force concluded the proposed approach balanced competency, honesty, and avoiding undue barriers.\"}]","ASSESSMENT OF PUBLIC COMMENT - DEPARTMENT OF TAXATION AND FINANCE | PDF",1790406332,13]