I have reviewed the proposed regulations to repeal 18VA C5-21-10 through 18V A C5-21-170 and add 18VA C5-22-10 through VA C5-22-170.  I applaud the effort of the Board to allow some flexibility in enforcement of the current statues.  However, I am concerned that the removal of the definition of a CPE hour may create some uncertainty.  I am also concerned that the requirement for annual CPE for attest or compilation will now require a sole practitioner  to obtain sixteen hours every year in these two areas in order to be able to offer both of these's services.  Thus, a sole practitioner who generally practices in the area of  taxation would not be able to prepare a compiled financial statement requested by a taxation client, unless he had completed eight hours of CPE related to compiliation services during the year of the request.  However,  the unlicensed accountant may prepare a compiled financial statement.   Would the adoption of these regulations require the annual requirement for 2010?  If so, I would request that the Board notify all practitioners by mail in time for them to complete the CPE requirement in 2010. 

Thank your for considering my comments.

Sincerely,

Cheryl Brown Biondolillo, CPA