| 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 The 40 per year requirement like the 150 hour requirement is outdated and obsolete especially for job appeal.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 Improve the accounting profession, reduce the outdated CPE hours requirement!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. | ||||
| 8 | 10/17/25 | Aarin |
| ACFE | 7.02.1. | 19 | Are nano courses permitted to have more than one learning objective? | ||||
| 9 | 10/17/25 | Aarin |
| ACFE | 5.01.1. | 8 | Are group programs delivered online required to have elements of engagement in addition to their attendance polls? | ||||
| 10 | 10/17/25 | Aarin |
| ACFE | 4.04.1. | 7 | Do we need to solicit instructor feedback per 4.04.1? | ||||
| 11 | 10/23/25 | Matthew |
| Encoursa LLC | 6.01.1. | 11 | Hello, In the current standards, there is clear language about the need for a real time subject matter expert facilitator for a recorded program presentation. There does not appear to be clear language in the updated standards as it only references a "real time instructor" in 6.01.1. My question would be: For a webinar rebroadcast, which bullet point would this fall under in 6.01.1? (see bullet points below): • Participation in watching a live broadcast or rebroadcast of a program facilitated by a real time instructor • Webcast/webinar facilitated by a real time instructor It seems more applicable to bullet point 2 (Webcast/webinar facilitated by a real time instructor) but the term "rebroadcast" is used in the first bullet point. | I would suggest updating both bullet points under 6.01.1 to: • Participation in watching a live broadcast or rebroadcast of a program facilitated by a real time instructor or subject matter expert • Webcast/webinar/webinar rebroadcast facilitated by a real time instructor or subject matter expert This would 1) Make it clear which are a webinar rebroadcast falls under and 2) Make the language more clear that the original instructor does not need to be on the rebroadcast under either bullet point as long as a subject matter expert facilitates it. | |||
| 12 | 10/29/25 | Chrys |
| Redpath & Company, LLC | Section 1 | 3 | The definition of "instructor" seems to allow for an AI chatbot to count as an instructor. If that is the case, I would strongly urge re-evaluation. We have tested some CPE where webinar rebroadcasts come with an AI bot that is "answering questions" from the participants, as opposed to a real person, and the results are underwhelming. An AI bot cannot provide professional context or the benefit of professional real-world experience. This may be convenient for CPE providers who do not have to pay humans to facilitate, but using a chatbot is just a fancier version of self-study. It's useful, but it shouldn't be confused with an actual person as an instructor. | Instructor: A human who guides, facilitates, instructs, coaches, models, and/or evaluates learning activities. | |||