UPDATE: Payment pause and interest waiver extended until January 31, 2022 for student loans. (August 2021)
On August 6, 2021 the Biden administration directed the U. S. Department of Education to extend the freeze on federal student loan payments for an additional six months. The Education Department said this would be the “final extension” of the respite, which has not been in effect since March of last year. Private student loans are not eligible for the government’s break.
UPDATE: The PPP Extension Act of 2021 has become law (March 2021)
The Paycheck Protection Program (PPP) application deadline formally changed from March 31 to May 31 on Tuesday when President Joe Biden signed the extension into law. The AICPA praised the passage of the PPP Extension Act, which provides an additional 30 days for the SBA to finish processing applications received by May 31. Read the Journal of Accountancy article.
ADVOCACY: AICPA provides congress with recommendations for COVID-19 relief (July 2020)
Recently, the AICPA shared six recommended policy solutions for the next phase of federal COVID-19 relief legislation. Read more in the press release.
UPDATE: New bill (HEROES Act) introduced by congress in response to the coronavirus pandemic (May 2020)
On May 12, the US House of Representatives released the proposed Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act to provide additional relief from the impact of the coronavirus pandemic. Some of the provisions include additional stimulus payments to households, forgiveness of student loan debt, assistance to state and local governments, strengthening of Medicaid and Medicare, and relief to essential workers. Dig deeper in the Title-By-Summary.
UPDATE: Department of Education announces student loan relief (March 2020)
On March 20, the Department of Education announced terms for student loan relief for tens of millions of borrowers in response to COVID-19. The new rules apply to borrowers with federal student loans. Learn more in this Broadridge client alert and on the Federal Student Aid website.
ADVOCACY: AICPA-led coalition urges expedited small business funding via payroll processors (March 2020)
An AICPA-led coalition issued a letter to President Trump and other leaders emphasizing the importance of supporting small businesses and keeping their employees on the payroll during this time. The group called for a federal funding mechanism to help with this issue.
UPDATE: SECURE Act is passed (December 2019)
On December 20, 2019, President Trump signed the Further Consolidated Appropriations Act, 2020, which included the Setting Every Community Up for Retirement Enhancement (SECURE) Act. This new law will impact retirement and estate planning for individual clients including eliminating the stretch IRA in favor for the 10-year rule and moving required minimum distributions to age 72.
UPDATE: New Form ADV Requirements Take Effect (October 2017)
In accordance with Release No. IA-4509, on October 1, the SEC stopped accepting amendments to Form ADV until firms complete the new Form ADV, which is designed to provide additional information regarding advisers and their practices. Firms with a Dec. 31 fiscal year have until next year to implement the changes. Some of the recent changes to Part 1A include:
- Significant reporting requirements on separately managed accounts
- Registrants must include their firm website and any social media addresses
- Information about any third-party Chief Compliance Officer
- More detailed reporting of regulatory assets under management by client type
ADVOCACY: AICPA Submits Written Testimony on Small Business Burden (June 2017)
On June 14, the AICPA submitted written testimony in regard to the hearing on tax reform and removing barriers to small business growth. Part of the commentary advocated for includes an administer-able tax system which supports economic growth, involves minimal compliance costs and allows taxpayers to clearly understand their tax obligations.
UPDATE: DOL Announces Final Rule on State Payroll Deduction IRAs (August 2016)
On August 25, the US. Department of Labor’s Employee Benefits Security Administration made public a final rule that assists states that create IRA programs for employees who do not have access to workplace savings arrangements. The department is also making public a proposed rule that could facilitate a limited number of cities and other local governments doing the same. The program will provide a safe harbor from ERISA coverage to reduce the risk of ERISA preemption of the relevant state laws. The proposal to expand the safe harbor to include a limited number of larger cities and counties will be open for 30 days of public comment after its publication in the Federal Register. The notice of proposed rule making can be found here.
UPDATE: Protecting Access to Retirement Advice (February 2016)
The House Committee on Education and the Workforce this week will consider legislation to strengthen the retirement security of working Americans. On Tuesday, February 2, the full committee, chaired by Rep. John Kline (R-MN), held a markup of the Affordable Retirement Advice Protection Act (H.R. 4293), introduced by Rep. Phil Roe (R-TN), and the Strengthening Access to Valuable Education and Retirement Support Act (H.R. 4294), introduced by Rep. Peter Roskam (R-IL). The complementary, bipartisan proposals will require financial advisors to serve their clients’ best interests and protect access to high-quality, affordable retirement advice. The proposals provide a legislative alternative to the Department of Labor’s fiduciary proposal. The markup took place Feb. 3.
UPDATE: Congress Eliminates Social Security “File-and-Suspend” Strategy (October 2015)
Approved by the House of Representatives on October 28th, 2015, the “Bipartisan Budget Act of 2015,” contains language that will reduce potential Social Security benefits for millions of Americans in an effort to protect the future of the Social Security program. In this podcast, Ted Sarenski, CPA/PFS discusses the proposed changes and how it will impact your clients.
UPDATE: Proposed rules would change definitions to recognize same-sex marriages (October 2015)
Following the U.S. Supreme Court’s recent decisions that the federal government must recognize and states must allow same-sex marriages, the IRS announced proposed regulations under Sec. 7701 that will amend the definitions of "spouse," "husband and wife," and "marriage" in regulations to reflect the Supreme Court's decisions in Obergefell and Windsor.
UPDATE: Medicare Rates May Increase Significantly (October 2015)
Medicare premiums are expected to rise by an unprecedented 50% for those who are not currently enrolled in Medicare and expecting to sign up in the next year, impacting your clients turning 65 this year. This would also affect anyone who has opted to wait until age 70 to start receiving their Social Security benefits through the “file and suspend” method in addition to those with high incomes. Lawmakers continue to attempt to come up with a solution. The AICPA PFP Division is monitoring legislative developments and will communicate important news and related resources in PFP News as they become available. You can also follow the latest legislative and regulatory updates on our website. *Update: See November 2016 update regarding announcement from the Centers for Medicare and Medicaid Services on 2016 premiums and costs.
UPDATE: SEC Aims to Ensure Cybersecurity Preparedness (September 2015)
On Sept. 15, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued another in a series of National Exam Program Risk Alerts, on OCIE’s 2015 Cybersecurity Examination Initiative. This follows up on the Apr. 15, 2014 Risk Alert launching its cybersecurity preparedness initiative. In the Sept. 15 Risk Alert, OCIE provide additional information on the areas of focus for OCIE’s second round of cybersecurity examinations, which will involve more testing to assess implementation of firm procedures and controls, identifying the following areas for examination: firm governance and risk assessments relating to cybersecurity, controls on access rights, data loss prevention, vendor management, training and incident response.
UPDATE: AICPA Guidance on Holding Out as “Fee-Only” (June 2015)
Fee-only advisers are compensated only by the fees charged directly to their clients and not via the sale of financial products. Fee-only compensation includes hourly, fixed, flat project-fee basis, retainer or percentage fees based on assets under management.
It was recently highlighted that several of the firms identified in CNBC’s “Top 100 Fee-Only Wealth Management Firms” share in insurance commissions, own an insurance agency, or are under common ownership alongside an insurance affiliate to which advisory clients are referred.
Importantly, an AICPA member would be in violation of the AICPA Code of Professional Conduct’s “Advertising and Other Forms of Solicitation Rule” [1.600.001] if the member’s promotional efforts are false, misleading, or deceptive. Holding out as “fee-only,” but not acting as such would be a violation of the code of conduct and could result in an ethics investigation. State boards of accountancy have similar rules in place. Additionally, the Statement on Standards in PFP Services requires full transparency on how members are compensated [para. 22 and 23].
UPDATE: NASAA Releases Model Rule on Business Continuity and Succession Planning (April 2015)
The North American Securities Administrators Association recently approved a model rule requiring advisers to plan for how to keep their practices going in the event of a natural disaster or the death of an executive. Plans must indicate how firms will limit business disruptions by preserving records, communicating with clients and taking other steps. States must adopt the model rule before it takes effect.
UPDATE: Achieving a Better Life Experience Act - ABLE Act of 2014 (December 2014)
On December 19, 2014, the Achieving a Better Life Experience Act (ABLE Act of 2014) was signed into law. The vote concluded a campaign that first began in 2006 to approve the use of tax-free savings accounts for individuals with disabilities to cover expenses not covered by government sponsored programs. The ABLE Act allows for those with disabilities to have a supplemental source of income beyond those provided by governmental programs, such as Medicaid and social security. The passage of the ABLE Act is significant given that the National Disability Institute estimates that there are 58 million individuals with disabilities in the United States.
WealthCounsel, ElderCounsel, and its authors, Jeremiah Barlow, JD and Stephen Dale, JD, LLM share a whitepaper outlining what the ABLE Act of 2014 accomplishes, its significance, eligibility, when the accounts will be available, and what this means from a planning perspective and more.
UPDATE: SEC Issues Guidance on Advisers' Use of Social Media Testimonials (March 2014)
The SEC issued Guidance Update 2014-4, which provides guidance concerning RIAs’ use of social media and their publication of advertisements that feature public commentary about them that appears on independent, third-party social media sites.
The guidance allows advisers to feature public testimonials from third party social media sites on their own websites, as long as all testimonials are included. The staff of the Division of Investment Management has defined “testimonial” as a “statement of a client’s experience with, or endorsement of, an investment adviser,” which includes positive and negative experiences.
Further, advisers who direct clients to their social media sites (e.g., advertisements that say “Check us out on Facebook!”) will not be deemed as soliciting testimonials from clients. Lists of friends/contacts/followers on social media will not be construed as testimonials or endorsements, provided that they are not grouped or listed as current or past clients and the adviser does not create the inference that these contacts have experienced favorable results.
The guidance also covers social media fan pages created by third-parties. The SEC strongly cautions advisers that such sites may be viewed as testimonials if the adviser has a material connection to the page and/or is not deemed independent. Read additional commentary on the new guidance from Michael Kitces.
ADVOCACY: Fewer Types of Retirement Plans and Simpler Rules Would Help Small Business Owners (October 2013)
Congress should consolidate and simplify the types of tax-favored retirement plans now available to small business owners in order to minimize the cost and administrative burden imposed by the plans, the AICPA said in written testimony submitted for the record of the House Small Business Committee’s Oct. 2 hearing entitled The Challenge of Retirement Savings for Small Employers.
Jeffery Porter, chair of the AICPA Tax Executive Committee, identified the following possible measures for simplifying the number and complexity of the various types of retirement plans in the testimony:
- Create a uniform employee contributory deferral type plan.
- Eliminate the nondiscrimination tests based on employee pre-tax and Roth deferrals for 401(k) plans.
- Create a uniform rule regarding the determination of basis in distributions.
- Create a uniform rule of attribution.
- Create a uniform definition for terms to define owners.
- Eliminate the required minimum distribution rules.
- Create uniform rules for early withdrawal penalties.
UPDATE: FinCEN Makes FBAR Changes, Provides New E-Filing Form and Info (August 2013)
To facilitate the e-filing of FBARs, the Financial Crimes Enforcement Network has released a new FBAR e-filing authorization form. The new form, FinCEN Form 114a, Record of Authorization to Electronically File FBARs, is to be used by filers who submit FBARs jointly with their spouses, or through third-party preparers. The form should not be filed with the FBAR but copies of it must be maintained by both the filer and the account holder and made available upon request by FinCEN or the IRS. FinCEN also announced changes to their originally issued BSA Electronic Filing Requirements For Report of Foreign Bank and Financial Accounts (FinCEN Report 114), which details the requirements for the e-filing of FBARs.
UPDATE: Financial Crimes Enforcement Network Extends FBAR Filing Date for Select Filers (December 2012)
On Dec. 26, 2012, the Financial Crimes Enforcement Network (FINCEN) issued Notice 2012-2, which further extends the due date for filing the Report of Foreign Bank and Financial Accounts (FBAR), form TD F 90-22.1, from June 30, 2013 to June 30, 2014 for select filers. The additional time extends both to certain individuals and employees or officers of investment advisers registered with the SEC who have signature authority over but no financial interest in one or more foreign financial accounts.
UPDATE: IRS Announces Third Offshore Voluntary Disclosure Program (January 2012)
On January 9, the IRS reopened the offshore voluntary disclosure program to help people with unreported offshore accounts get current with their taxes. The IRS also announced the collection of more than $4.4 billion so far from the two previous international disclosure programs.
The program is similar to the 2011 program in many ways, but with a few key differences. Unlike last year, there is no set deadline for people to apply. However, the terms of the program could change at any time going forward. For example, the IRS may increase penalties in the program for all or some taxpayers or defined classes of taxpayers – or decide to end the program entirely at any point. The overall penalty structure for the new program is the same for 2011, except for taxpayers in the highest penalty category. Visit IRS for more information.
UPDATE: SEC Issues Risk Alert on Investment Adviser Use of Social Media (January 2012)
On January 4, 2012, the staff of the SEC’s Office of Compliance Inspections and Examinations issued a National Examination Risk Alert, which provides staff observations based on a review of investment advisers of varying sizes and strategies that use social media. In growing numbers, registered investment adviser firms are using social media to communicate with existing and potential clients, promote services, educate investors, and recruit new employees.
“As investment advisers increasingly utilize social media to communicate with clients and potential clients, firms need to be mindful of the applicable standards governing those communications,” said Carlo di Florio, Director of the Office of Compliance Inspections and Examinations (OCIE).
The alert reviews concerns that may arise from use of social media by firms and their associated persons, and offers suggestions for complying with the antifraud, compliance, and record keeping provisions of the federal securities laws. The alert notes that firms should consider how to implement new compliance programs or revisit their existing programs in the face of rapidly changing technology.
UPDATE: Additional Extension Until September 9th for Various OVDI and Certain Other Filings Previously Due August 31, 2011 (August 2011)
Due to Hurricane Irene, the IRS announced that it has extended the deadline for the 2011 Offshore Voluntary Disclosure Initiative (OVDI) filing to Friday, September 9, 2011 (from August 31, 2011). The IRS further announced that the September 9, 2011 extended due date will also apply to certain late filed information returns that are officially excluded from the OVDI, but that are permitted to be filed without late filing penalties per the IRS’s OVDI’s Frequently Asked Questions (FAQs) numbers 17 and 18. For more information, see AICPA’s OVDI resource page.
UPDATE: Treasury and IRS Issue Guidance Outlining Phased Implementation of FATCA Beginning in 2013 (July 2011)
On July 14th, the Treasury Department and the IRS issued a notice announcing plans to phase in the requirements of the Foreign Account Tax Compliance Act (FATCA). The new law targets noncompliance by U.S. taxpayers through foreign accounts. Under the notice’s phased implementation approach, foreign financial institutions and U.S. withholding agents are given adequate time to build the systems needed to fully comply with FATCA. Read Notice 2011-53.
ADVOCACY: Clarification Requested on FBAR (July 2011)
The AICPA has written to the Financial Crimes Enforcement Network (FinCEN) regarding reports of foreign financial accounts (FBAR) to request clarification whether the following signatories are required to file an FBAR for pre-2010 calendar years:
- Officers or employees of a domestic corporation listed on a U.S. national securities exchange (or the officers or employees of its more than 50-percent owned domestic and foreign subsidiaries), or
- The officers or employees of a corporation with over $10 million in assets and 500 or more shareholders (or the officers or employees of its more than 50-percent owned domestic and foreign subsidiaries).
UPDATE: IRS Issues Foreign Financial Account Reporting Guidance (April 2011)
The IRS issued a second notice giving guidance on various reporting requirements under the Foreign Account Tax Compliance Act (FATCA) (Notice 2011-34). The notice responds to concerns raised by commenters following the issuance last August of Notice 2010-60, which contained preliminary guidance on implementation of the FATCA rules, including procedures for participating foreign financial institutions to follow in identifying U.S. accounts among their pre-existing individual accounts. For more information on the scope of the notice, click here to read more from Journal of Accountancy.
UPDATE: SEC Model Privacy Form (April 2011)
In December 2009, the SEC and seven other federal agencies published final amendments to their rules that implement the privacy provisions of Subtitle A of Title V of the Gramm-Leach-Bliley Act. These rules require financial institutions to provide initial and annual privacy notices to their clients. The Agencies adopted a model privacy form along with Sample Clauses that financial institutions (including registered advisers) may rely on as a safe harbor to provide disclosures under the privacy rules.
ADVOCACY: AICPA Weighs in on Foreign Trust & HIRE Act (March 2011)
Congress made several changes last year to the laws governing foreign trusts in the Hiring Incentives to Restore Employment (HIRE) Act enacted in 2010. The AICPA Foreign Trust Task Force submitted a letter to IRS requesting guidance regarding some of the changes to avoid undue burden on taxpayers.
UPDATE: SEC’s Pay to Play Rules (March 2011)
The SEC’s new "pay to play" rules for investment advisers took effect on March 14, 2011 and FAQs were released by the SEC last week. Pay to play is the practice of making campaign contributions and related payments to elected officials in order to influence the awarding of lucrative contracts for the management of public pension plan assets and similar government investment accounts. The rule adopted by the SEC last summer includes prohibitions intended to capture not only direct political contributions by investment advisers, but also other ways that advisers may engage in pay to play arrangements.
The new SEC rule has three key elements:
- It prohibits an investment adviser from providing advisory services for compensation — either directly or through a pooled investment vehicle — for two years, if the adviser or certain of its executives or employees make a political contribution to an elected official who is in a position to influence the selection of the adviser.
- It prohibits an advisory firm and certain executives and employees from soliciting or coordinating campaign contributions from others — a practice referred to as "bundling" — for an elected official who is in a position to influence the selection of the adviser. It also prohibits solicitation and coordination of payments to political parties in the state or locality where the adviser is seeking business.
- It prohibits an adviser from paying a third party, such as a solicitor or placement agent, to solicit a government client on behalf of the investment adviser, unless that third party is an SEC-registered investment adviser or broker-dealer subject to similar pay to play restrictions. Compliance with this requirement goes into effect on September 13, 2011.
Investment advisers subject to the new rule (those with clients who are government entities) must begin to maintain records of all persons who are covered associates under the rule and keep records of political contributions they make on and after that date. Advisers must also make and keep a record of all government entities that they provide advisory services to on and after March 14, 2011. Advisers are not, however, required to look back for the five years prior to the effective date to identify former government clients. Advisers that pay regulated persons to solicit government entities for advisory services on their behalf must make and keep a list of those persons beginning on and after September 13, 2011. Click here for the full rule.
UPDATE: SEC Compliance Date Extension of Part 2B of Form ADV (January 2011)
On December 28th, the SEC extended the compliance date for Part 2B of Form ADV, the brochure supplement, and for certain rule provisions that relate to the delivery of brochure supplements. The SEC extended the compliance date generally for 4 months to provide certain investment advisers additional time to design, test and implement systems and controls to satisfy their obligations to prepare and deliver brochure supplements. Note that the extended compliance date does not affect the delivery of Part 2A, which must be delivered to existing clients by May 30 for advisers with a December 31 fiscal year end. The new ADV must still be filed with the SEC by March 31. Click here to read more.
UPDATE: CPA & PFS Descriptions for Part 2B of Form ADV (January 2011)
Recent amendments to Part 2B of Form ADV require advisers to prepare narrative brochures written in plain English which contain, among other things, information on the educational and business background of management and key advisory personnel of the adviser. The SEC permits, but does not require, advisers to list the professional designations held by such persons. SEC instructions require, however, that any listing of professional designations held must provide a sufficient explanation of the minimum qualifications required for the designation to allow clients and potential clients to understand the value of the designation.
To assist you in completing Part 2B of Form ADV, the AICPA has written descriptions of both the CPA and PFS designations. These descriptions are provided by the AICPA as guidance to its members who choose to list their professional designations on Part 2B of Form ADV, the uniform form used by investment advisers to register with the Securities and Exchange Commission (SEC). Listing the CPA license and/or the PFS credential, and the descriptions thereof is optional and is solely at the discretion of the individual licensee and/or credential holder.
ADVOCACY: Foreign Bank Account Reporting (November 2010)
On November 19th, the AICPA provided additional comments to the Internal Revenue Service and Department of Treasury in response to proposed rulemaking related to amendments to the Bank Secrecy Act Regulations – Pertaining to Foreign Trusts. Click here to read the comments. They supplement prior FBAR comments submitted in November 2009 and April 2010 .
UPDATE: New ADV2 Resources from NASAA (October 2010)
SEC regulations that became effective October 12th require investment advisers to use the new “plain English” Form ADV, Part 2. For states that have adopted the new ADV 2, the North American Securities Administrators Association (NASAA) has guidance on their web site to help advisers comply with the ADV 2. Blank templates are available on the NASAA Form ADV webpagefor free download and use by investment advisers.
UPDATE: AICPA’s State Legislative Update – Fall 2010 Edition (October 2010)
The fall 2010 edition of the State Legislative Update, a publication by the AICPA’s State Regulation and Legislation Team, is now available. This publication is designed to provide regular updates to state CPA societies and other interested parties on state legislative and regulatory activity impacting the CPA profession. This quarterly newsletter discusses crucial state elections, tax on service proposals, UAA Committee exposure draft, firm names, mobility passage, and the Hawaii firm permit requirement. Click here to read the newsletter.
UPDATE: New Form ADV Part 2 (October 2010)
New SEC regulations effective October 12th require investment advisers to use a new Form ADV, Part 2, which includes supplemental information not previously required in the current “check-the-box” format. New investment advisers filing with the SEC after January 1st, 2011 must use the new form. Existing advisers with a calendar year-end must file the new Part 2 by March 31st, 2011. Within 60 days from filing, advisers must deliver to its existing clients the brochure and brochure supplement that meet the requirements of the amended ADV.
Form ADV, Part 2 explains to the investor an investment adviser’s qualifications, investment strategies, and business practices. The current form requires advisers to respond to a series of multiple-choice and fill-in-the-blank questions organized in a “check-the-box” format. The new form is in a more narrative format, which requires expanded content, greater disclosure and discussion of conflicts of interest and mitigation of those conflicts, and supplements. Furthermore, the forms must be filed electronically with the SEC so they are more accessible by investors.
If advisers choose to list their professional designations on the form, they must include information about the minimum qualifications necessary to earn and maintain the credential. If the adviser loses a designation for reasons other than non-payment of dues, they must disclose the circumstances of the event. We will provide a description of both the CPA and PFS to use on the new form in a later issue of PFP News.
Contact your attorney or compliance advisor to ensure you meet the new requirements, including those for state registered advisers. For more information on the new ADV Part 2, click here. Read the final rule on amendments to Form ADV Part 2 here.
UPDATE: Foreign Account Tax Compliance Act (August 2010)
The Foreign Account Tax Compliance Act (FATCA) was enacted March 18, 2010, as part of the Hiring Incentives to Restore Employment (HIRE) Act. It carries far-reaching disclosure and reporting requirements for U.S. taxpayers with foreign accounts and assets, as well as foreign financial institutions with accounts owned by U.S. taxpayers. Read more about the FATCA and its implications for your clients with foreign accounts and assets from Journal of Accountancy
UPDATE: AICPA’s State Legislative Update – Summer 2010 Edition (September 2010)
The summer 2010 edition of the State Legislative Update, a publication by the AICPA’s State Regulation and Legislation Team, is now available. This publication is designed to provide regular updates to state CPA societies and other interested parties on state legislative and regulatory activity impacting the CPA profession. This quarterly newsletter discusses mobility, changes to the mobility act’s definition of “attest” (standards specific to SAS 70), consolidation of licensing and accountancy boards in various states, and a reference to the state trend of regulating “debt counselors” or “credit counselors.” Click here to read the newsletter.
UPDATE: President Signs HIRE Act (March 2010)
On March 18, 2010, President Obama signed the Hiring Incentives to Restore Employment (HIRE) Act. This Act includes a temporary payroll tax exemption for qualifying new hires plus a tax credit for retaining new employees. It also extends Section 179 increased expensing limits. Visit Forefield Advisor to read an alert that summarizes the provisions of the HIRE Act.
UPDATE: Bankruptcy - The Scope of SIPA Protection (March 2010)
The Bankruptcy Court ruled in favor of Trustee Irving Picard, who is responsible for the Securities Investor Protection Act (“SIPA”) liquidation of Bernard Madoff. The Court’s ruling determines the scope of the Securities Investor Protection Corporation’s liability for investor accounts. The Court ruled in favor of the Net Investment Method, which the Trustee had used to calculate the defrauded customer’s “net equity” in order to begin liquidation proceedings under SIPA.
ADVOCACY: Comments on Electronic Filing by Investment Advisers; Proposed Amendments to Form ADV (May 2008)
The AICPA's PFP Executive Committee has provided a comment letter to the Securities and Exchange Commission regarding the proposed rules to the Investment Advisers Act of 1940 and Part 2 of Form ADV.
View all related Comment Letters
View the PFP Executive Committee's Comment letter