I WOULD PREFER TO KEEP THE INTERIM REPORTING SYSTEM.  ACTUALLY WE NEED NO MORE CHANGES TO THE SYSTEM.  HAVING 6 MONTH CERT PERIODS COULD POSSIBLE CAUSE MORE PAPER WORK (WHICH COULD BE MORE COSTLY) AND WOULD ALMOST CERTAINLY DOUBLE OUR WORKLOAD.  CLIENTS SHOULD KEEP SOME RESPONSIBILITY TO REPORT TIMELY AND RETURN IR'S WITH VERIFICATIONS.