| Date Submitted | First Name | Last Name | Organization Affiliation | Section | Page # | Full Comment Text | Suggested Language | ||||
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| 1 | 09/17/25 | Jen |
| Warner Bros Discovery | 6.01.1. Section 6 | 11 | For Webcast/webinar facilitated by a real time instructor, the guidance is to use real-time monitoring mechanisms to ensure participants are engaged throughout the program. However, the standards do not specify a requirement to ensure the user was present for 50 minutes in addition to answering at least 3 polls per hour. It would be helpful to specify if the 50 minute duration check is actually required for group-internet trainings or if the poll responses alone (if scattered unpredictably) are enough. The standards are currently much more clear for the physical classroom setting with the sign in sheet and could be clarified for group-internet with a live presenter, such as trainings via Zoom. | ||||
| 2 | 09/18/25 | Robert |
| Many | General Comment | All | Addressing learning mechanisms is fine. However, the industry has a pipeline and staff problem because young people with analytic skills have many more options than 50 years ago. If you truly want to address CPE, address the number of hours annually. Lawyers, insurance executives, AI experts have far fewer CPE hours to do annually. The 40 per year requirement like the 150 hour requirement is outdated and obsolete especially for job appeal. We live in a modern AI driven world and having the ability to think critically and access professional answers on the fly and quickly is now more important than attempting to have all the answers memorized in the brain. Improve the accounting profession, reduce the outdated CPE hours requirement! | ||||
| 3 | 09/26/25 | Rosemarie |
| Member | General Comment | N/A | Thanks for sharing the Proposed Statement on Standards. Perhaps I am looking for content that is not included in this Statement. However, I was looking to see what the annual requirement for CPEs was for a member and also was looking to see if there was a requirement that a certain number of the annual CPEs had to come from AICPA. I think your proposed methodologies look good and also the responsibilities of providers of education were appropriate. Thanks, Rose | ||||
| 4 | 09/26/25 | Alan |
| Independent thought | 3.01. 3.01.1. 3.02. 3.02.2. | N/A | Article III is proposed to focus exclusively on standards for Formal Learning Programs, removing all references to Independent Study due to the current lack of support from State Boards. In my view, this represents a step backward - widening the gap between bureaucratic processes and the evolving realities of professional development. For new financial professionals, the most effective learning method is experiential - on-the-job training. For seasoned professionals, learning is driven primarily by research, which may be supplemented by formal programs. With the rise of AI-powered research tools, that tailor insights to specific client scenarios, Independent Study (research) is only going to become increasingly relevant, efficient, and cost-effective. Continuing to prioritize older formal learning modalities modeled after more expensive, less efficient, academic systems (where grades are the primary measure of success), risks overlooking the value of real-world deliverables associated with research. If our goal is to expand the pipeline of financial professionals and attract new talent, we must also consider profitability and compensation. In this context, NASBA should be leading the charge in embracing Independent Study - not retreating from it. | ||||
| 5 | 10/10/25 | Joanne |
| Pinion, LLC | 2.02.1. | 4 | By moving all group into one delivery method, I am curious how that will work with an LMS (such as LCvista), as currently group internet based vs group live indicated to individuals whether they would need to travel/be in-person for a training, or just schedule time for a Zoom call/webinar. | ||||
| 6 | 10/10/25 | Joanne |
| Pinion, LLC | 6.01.1. | 9 | Currently, we use polling questions to monitor group internet based engagement/participation (minimum 3 per 1.0 CPE) to document engagement. With the combining of all group programs, can we now count breakout rooms, shared whiteboards, etc as engagement instead of polling questions? And if so, how should those be documented - what would NASBA want to see if they audited that course? | ||||
| 7 | 10/14/25 | Pelagia |
| Wiss & Company LLP | 2.02.1. Section 2 | 4 | Changing this specification will allow conferences IO to sync seamlessly with LCVista; two programs that are heavily relied on within numerous firms across the accounting spectrum. This will allow L&D professionals more time and less manual uploading as we advance in our field. This is an important change as we update with the times. | ||||