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Audit & Accounting Alert Newsletter

Issue 5 | June 2015

At-A-Glance

Gerry Herter

The Financial Accounting Standards Board of the US (FASB) and the Financial Reporting Council of the UK (FRC) have been prolific this quarter, as our Worldwide Update at the back of this issue bears out. Much of their work has been directed at the goal of simplification and reduced complexity. Our first article highlights those efforts, along with the results that have been recommended or adopted.

 With all the attention and drama in recent years directed toward International Financial Reporting Standards for business enterprises, the non profit community has taken a back seat. Now that those efforts are subsiding, the FASB and FRC have also turned their focus toward reforming the long held standards for this sector. Our second article summarizes significant changes proposed by the FASB and enacted by the FRC for non profits.

Finally, our quarterly Worldwide Update covers news from organizations across the globe.

Editor Gerald E. Herter, CPA

In This Issue 

Simplification Efforts Continue

Standards and compliance measures make headway

Efforts are underway on both sides of the Atlantic towards more practical accounting and reporting standards. The Financial Accounting Standards Board of te US (FASB) is one year into its Simplification Initiative, while the European Union’s Accounting and Transparency Directives, first published in 2013, are now also in place in the UK.

When Russell Golden was announced as the new Chairman of the FASB in April, 2013, he conveyed a hopeful new approach toward change. The groundwork had been laid in the prior year with the new Private Company Council (PCC), newly formed to challenge questionable complexity in standards. Golden, while committed to “putting the interests of investors first” and “working to make financial reporting as clear, transparent and useful as possible,” also voiced the importance of “never losing sight of the balance between costs and benefits.”

A year ago, the FASB followed through by launching an initiative to simplify accounting standards. Even so, the then new FASB Outlook newsletter cautioned “You may think that reducing complexity and promoting simplification is, well, simple. While desirable in concept, in practice achieving both is often easier said than done.”

Now that another year has passed, the FASB recently gave an update on the progress of the simplification initiative. James Kroeker, FASB Vice Chairman noted that “dozens of potential ideas from stakeholders” have been received. All have been or will be evaluated, and more are being sought.

Included in the narrow scope projects that could be quickly dealt with, one that stood out involved extraordinary items. Separately reporting extraordinary items, those that were both unusual and infrequent, had been a requirement since 1966, when FASB predecessor, the Accounting Principles Board, issued Opinion Number 9: Reporting the Results of Operations. Though amended over the years, the complete elimination of the pronouncement through Accounting Standard Update (ASU) 2015-01 will save accountants the trouble of time consuming evaluations.

Other completed narrow scope projects cover the presentation of debt issuance costs and the measurement date of defined benefit pension plan assets. Projects in progress involve share-based payments for employee stock compensation, income taxes, measurement method for potential inventory impairment, and classification guidance for debt on the balance sheet. Of these, the income tax proposal is another notable one that would change long-standing treatment. Classifying deferred tax assets and liabilities as current or noncurrent has been a requirement for many years. The proposed ASU would combine these into a single, less burdensome noncurrent classification.

Other simplification topics on the FASB agenda will tackle aspects of the equity method of accounting and business combinations. Further easing may be considered in the future for income taxes, employee stock compensation, and employee benefit plans.

Meanwhile, the PCC has been at work, gaining the FASB’s blessing in several areas. The controversial requirement to consolidate company facilities leased under common control entities was eliminated. Also, reporting of basic interest rate swaps and the accounting for goodwill and intangible assets was streamlined.

In Europe, Commissioner Michael Barnier had commented on June 12, 2013: “I welcome today’s vote by the European Parliament on the new Accounting and Transparency Directives. Financial reporting obligations have been modernised and costs reduced, in particular for SMEs.” Those directives, which seek consistency throughout the European Union, went into effect this year for the United Kingdom.

FRS 102, The Financial Reporting Standard applicable in the UK and Republic of Ireland, was first covered in the April 2013 issue of the A & A Alert. Based on IFRS for SMEs, FRS 102 greatly reduced the size of the predecessor UK GAAP. Now, with proposed modifications, Financial Reporting Exposure Drafts (FRED) 58, 59, and 60, further simplification is anticipated, while also aligning accounting standards for all sizes of small companies more closely with IFRS for SMEs.

A significant change is in the size of a company that can qualify for small company accounting rules. The turnover/revenue limit was raised from £6.5m to £10.2m, or about $10m to $16m. The asset limit was raised from £3.26m to £5.1m, or about $5m to $8m. Micro-entity size limits remain at a turnover of £632k and assets of £312k. However, the Financial Standard for Smaller Entities (FRSSE) that applies to micro-entities would be replaced by a new section of FRS 102. Laid out in proposed FRS 105, the recognition and measurement requirements for the micro-entities would be based on FRS 102, but with less rigorous presentation and disclosure stipulations.

The new accounting thresholds are intended to apply for audits as well. In the UK, audits are required of private as well as public companies. Sensing concerns in this area, the FRC has deferred for one year the change in audit thresholds, to give more time for consultation. A practical result of the audit change is that potentially ten thousand companies would be freed up from the audit requirement. Small chartered accountant firms that service the bulk of these companies could lose a substantial amount of business.

For further information, see FASB’S Simplification Initiative: an Update and FRC consults on amendments to UK and Irish GAAP.


Attention Turns to Non Profit Financial Reporting

FASB and UK reform standards to address current stakeholder needs

Now that the projects for converging international financial reporting standards for business enterprises are winding down, attention is turning to the non profit sector. While the UK reforms parallel the IFRS for SMEs framework enacted for small businesses, the FASB is responding to the concerns of stakeholders closer to home.

For some of us, it seems almost like yesterday when the world of non profit financial reporting under US GAAP was transformed by FASB Statements 116 and 117. The reality is that the current model has been in place for over 20 years. With all that has transpired in the financial community, including calls for greater transparency and more relevant disclosures, the timing is right for reform. On April 22, 2015, the FASB issued a proposed Accounting Standards Update: Not-for-Profit Entities and Health Care Entities: Presentation of Financial Statements of Not-for-Profit Entities. The comment period goes through August 20, 2015.

The first major change to enhance clarity and usefulness for users, such as donors and creditors, impacts the statement of financial condition. The current separation of restricted net assets into temporary and permanent, along with calling the rest unrestricted, apparently has caused confusion. Consequently, those three designations are replaced by two: net assets with donor restrictions and net assets without donor restrictions. The disclosure requirements for describing types and amounts of donor descriptions are retained, as well as for board designations, which differ from donor restrictions.

Endowment fund treatment has also caused confusion. When the current fair value of the fund falls below the original donor given amount, the shortfall would now be reflected in the net assets with donor restrictions, rather than in unrestricted net assets, as is the case in the present standard.

Liquidity is an important issue with the proposal. Qualitative and quantitative disclosures are designed to help the user ascertain the availability and timing of cash and other assets to fulfil obligations as they occur. Also, the influence of donor restrictions and liquidity management policies are a focus to be emphasized.

The proposed changes in the statement of activities result from a lack of specificity in the current standard. The new rules would require showing the change in net assets for the two new above-mentioned classes. For the non-donor restricted class, the effects of internal transfers, arising from board designations, would be shown below the results of operating activities. Operating expenses would need to be shown, here or elsewhere, both by nature and function. Investment return would be reported net of related expenses.

Only the direct method will be allowed for the statement of cash flows. The direct method presents the specific cash flows, such as the amount of cash collected from customers and paid to suppliers, payroll paid to employees, interest received and paid, and income taxes paid. This method typically takes more work compared to the indirect method, which generally shows net changes in balance sheet accounts. Also, some cash flow classifications would change. For instance, purchases of fixed assets would be shown in operating cash flow, consistent with depreciation expense treatment.

In May 2015, the AICPA established a new Not-for-Profit Section that will provide a broad base of tools and resources, intended to enhance the capabilities of non profit management, board members, and financial professionals, as well as AICPA members working in the accounting, audit and tax areas.

The UK, which has been regulating non profits long before the US was formed, guides them with the Accounting and Reporting by Charities: Statement of Recommended Practice (SORP). While amended over the years, the basic SORP, like US guidance, dates back over 20 years, and is based on UK GAAP. Therefore, with the emergence of FRS 102, a corresponding update to the latest version, SORP 2005, was needed: Charities SORP (FRS 102). There was also a Charities SORP published for smaller entities (FRSSE), but that will be short lived with the withdrawal of FRSSE in 2016.

While the US standards apply only to the financial statements, SORP prescribes the content of a detailed trustee report as well. In narrative form, the trustee report basically tells the charity’s story. The new SORP requires an explanation of policies for holding reserves and a list of all trustees. In addition, larger charities must describe social investment policies, the financial effect of significant events, the presence and management of principal risks and uncertainties, and compensation arrangements of key management personnel.

The overall format of the Statement of Financial Activities has not changed under Charities SORP (FRS 102), still displaying columns for unrestricted income, restricted income and endowment, which resemble the former US approach. Terminology has been simplified using “plain English,” and comparative information is required either here or in the footnotes. Also, gains and losses on investment assets are now included as part of net income, while discontinued operations have their own column.

The statement of financial condition (balance sheet) format has not changed. But within the statement, new classes of mixed use investment property and social investments are introduced, and debts beyond one year are to be discounted if material.

The old SORP had little specific guidance on the Statement of Cash Flows. Charities SORP (FRS 102) includes templates for assistance. Though the statement format has changed to be consistent with FRS 102, there remains the option to use either the direct or indirect method, unlike the new US proposal.

Significant accounting changes affect income recognition and certain liabilities. Income should now be recognized when receipt is probable, rather than when it is virtually certain. Also, if material, accruals should be recorded for employee benefits, such as holiday (vacation) pay and sick pay.

 For further information, see FASB Proposes Improvements to Not-For-Profit Financial Statements and What are the major changes between SORP 2005 and the Charities SORP (FRS 102) for charities preparing their accounts in accordance with the Financial Reporting Standard (FRS 102).


Worldwide Update

Quarterly roundup of recent and upcoming actions and activities by audit and accounting organizations

Periodically, we summarize significant items impacting the accounting world.

International

IASBInternational Accounting Standards Board (www.ifrs.org)

  1.  Exposure Draft – Amendment to IFRS 15 -Revenue from Contracts with Customers: Deferral of the Effective Date to 1 January 2018, to provide time for clarifications and to coincide with FASB. This amendment was approved by the IASB on April 28, 2015, but has not yet been formally issued.
  2. Leases: Practical implications of the new Leases Standard – project update published March 16, 2015, indicating that the primary changes will likely be increases to assets and liabilities, higher operating profit, and reclassifications of cash flow. Also, there will be more transparency in disclosures of lease commitments.
  3.  Exposure Draft – Classification of Liabilities (Proposed amendments to IAS 1) – published February 10, 2015, “clarifying the criteria for the classification of a liability as either current or non-current.” Comment period ends June 10, 2015.

IFACInternational Federation of Accountants (www.ifac.org)

  1.  International Auditing and Assurance Standards Board (IAASB) Auditor Reporting—Illustrative Key Audit Matters, published April 22, 2015, and Auditor Reporting – Key Audit Matters published January 30, 2015 “to assist and illustrate how the concept of Key Audit Matters (KAM) may be applied in practice in accordance with ISA 701,Communicating Key Audit Matters in the Independent Auditor’s Report.”
  2. International Auditing and Assurance Standards Board (IAASB) - International Standard on Auditing (ISA) 720 (Revised), The Auditor’s Responsibilities Relating to Other Information– published April 8, 2015, “to clarify and increase the auditor’s involvement with “other information”—defined in the standard as financial and non-financial information, other than the audited financial statements, that is included in entities’ annual reports. It also includes new requirements related to auditor reporting on other information that complement the changes arising from the IAASB’s new and revised Auditor Reporting standards, issued earlier this year.”
  3.  International Auditing and Assurance Standards Board (IAASB) - Auditor Reporting on Going Concern– published January 30, 2015, “provides an overview of how the new auditor’s report will address going concern as set out in ISA 570 (Revised), Going Concern, and forms part of the Auditor Reporting Toolkit.”
  4.  International Ethics Standard Board for Accountants (IESBA) - Changes to the Code Addressing Certain Non-Assurance Services Provisions for Audit and Assurance Clients– published April 14, 2015, to “enhance the independence provisions in the Code of Ethics for Professional Accountants (the Code) by, in particular, no longer permitting auditors to provide certain prohibited non-assurance services to public interest entity (PIE) audit clients in emergency situations, and ensuring that they do not assume management responsibility when providing non-assurance services to audit clients.” Effective April 15, 2016.
  5.  International Public Sector Accounting Standards Board• (IPSASB) - IPSASs 34-38 on Accounting for Interest in Other Entities – published January 30, 2015, replace the requirements of IPSASs 6-8 that deal with consolidated and separate financial statements, investments in associates and joint ventures, and other entities. Effective generally in 2017.
  6.  International Public Sector Accounting Standards Board• (IPSASB) - IPSAS 33, First-time Adoption of Accrual Basis IPSASs – published January 29, 2015, allows first-time adopters three years to recognize specified assets and liabilities. Effective for 2017 with early adoption permitted.

ACCAAssociation of Chartered Certified Accountants (www.accaglobal.com/)

  1.  Tomorrow’s finance enterprise – joint report with IMA issued April 14, 2015, describing five key issues shaping the future of the CFO function: 1. Volatility and risk shape the future; 2. Enterprise strategy supported by smarter finance delivery; 3. Value driven and data centric; 4. New technology frontiers; and 5. People matter – it’s always about talent.
  2.  Increasing gender diversity to boost performance – briefing paper published March 10, 2015, “presents the value of gender diversity in business. It aims to help CFOs, senior finance professionals and HR professionals working alongside finance teams, to understand the value of gender diversity and make the business case for diversity to their peers.”

CIMAChartered Institute of Management Accountants (www.cimaglobal.com)

  1.  Branded-business valuations: Global Intangible Finance Tracker 2015 – report issued jointly with Brand Finance on April 14, 2015, “reinforces the importance of intangibles – reputation, brands, intellectual property – and challenges those leading the debate on our national economic policy.” 
  2.  Management Accounting in Support of the Strategic Management Process – report issued in March 2015, explores the current aspects and extent of accountants’ involvement in the strategic management process.
  3.  The Effects of Cloud Technology on Management Accounting – report issued in January 2015, concluding that cloud computing offers advantages for decision making, delivers cost savings and eases systems administration, while the collaborative advantage of cloud technology is less than expected, or not yet realized by finance, and that the primary reason for not adopting cloud technology in finance processes is data security concerns.
  4.  Human Capital Reporting - Investing for Sustainable Growth – report issued in January 2015, “explores investor views on the value and availability of human capital management (HCM) information, the main barriers to better HCM practice, and whether consistent reporting on agreed core HCM information would be useful as a means of improving the quality of narrative reporting in this area.”

Americas, Australia & Asia

FASBFinancial Accounting Standards Board (www.fasb.org)

  1.  Fair Value Measurement ASU 2015-07: Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent)  — issued May 1, 2015, to “remove the requirement to categorize within the fair value hierarchy all investments for which fair value is measured using the net asset value per share practical expedient,” and to “also remove the requirement to make certain disclosures for all investments that are eligible to be measured at fair value using the net asset value per share practical expedient. Rather, those disclosures are limited to investments for which the entity has elected to measure the fair value using that practical expedient.” Effective generally for 2016 with early application permitted.
  2.  Earnings Per Share ASU 2015-06: Effects on Historical Earnings per Unit of Master Limited Partnership Dropdown Transactions – issued April 30, 2015, to “specify that for purposes of calculating historical earnings per unit under the two-class method, the earnings (losses) of a transferred business before the date of a dropdown transaction should be allocated entirely to the general partner…Qualitative disclosures about how the rights to the earnings (losses) differ before and after the dropdown transaction occurs …also are required." Effective generally for 2016 with early application permitted.
  3.  Exposure Draft - Liabilities—Extinguishments of Liabilities: Recognition of Breakage for Certain Prepaid Stored-Value Cards (a consensus of the FASB Emerging Issues Task Force) issued April 30, 2015, provides a narrow-scope exception to the liabilities guidance to require use of the new revenue recognition breakage guidance generally for prepaid cards that do not expire. The comment period ends June 29, 2015.
  4.  Exposure Draft - Revenue from Contracts with Customers: Deferral of the Effective Date – issued April 29, 2015, allows for a one year deferral. The comment period ended May 29, 2015.
  5.  Exposure Draft - Plan Accounting: (I) Fully Benefit-Responsive Investment Contracts, (II) Plan Investment Disclosures, and (III) Measurement Date Practical Expedient (a consensus of the FASB Emerging Issues Task Force)- issued April 23, 2015, to reduce complexity, fully benefit-responsive investment contracts would be measured, presented, and disclosed only at contract value. A plan would continue to provide disclosures that help users understand the nature and risks of fully benefit-responsive investment contracts. The comment period ended May 18, 2015.
  6.  Exposure Draft - Derivatives and Hedging: Application of the Normal Purchases and Normal Sales Scope Exception to Certain Electricity Contracts within Nodal Energy Markets (a consensus of the FASB Emerging Issues Task Force)- issued April 23, 2015, The comment period ends May 18, 2015
  7.  Exposure Draft - Not-for-Profit Entities and Health Care Entities: Presentation of Financial Statements of Not-for-Profit Entities- issued April 22, 2015. See the second article in this Alert. The comment period ends August 20, 2015.
  8.  Intangibles—Goodwill and Other—Internal-Use Software ASU 2015-05: Customer’s Accounting for Fees Paid in a Cloud Computing Arrangement - issued April 15, 2015, to “provide guidance to customers about whether a cloud computing arrangement includes a software license. If a cloud computing arrangement includes a software license, then the customer should account for the software license element of the arrangement consistent with the acquisition of other software licenses. If a cloud computing arrangement does not include a software license, the customer should account for the arrangement as a service contract.” Effective generally for 2016 with early application permitted.
  9.  Compensation—Retirement Benefits ASU 2015-04: Practical Expedient for the Measurement Date of an Employer’s Defined Benefit Obligation and Plan Assets - issued April 15, 2015, for an entity whose year end is not on a month-end, “permits the entity to measure defined benefit plan assets and obligations using the month-end that is closest to the entity’s fiscal year-end and apply that practical expedient consistently from year to year.” Effective generally for 2017 with early application permitted.
  10.  Interest—Imputation of Interest ASU 2015-03: Simplifying the Presentation of Debt Issuance Costs - issued April 7, 2015, for simplification purposes provided “that debt issuance costs related to a recognized debt liability be presented in the balance sheet as a direct deduction from the carrying amount of that debt liability, consistent with debt discounts.” Effective generally for 2016 with early application permitted.
  11.  Exposure Draft - Derivatives and Hedging: Disclosures about Hybrid Financial Instruments with Bifurcated Embedded Derivatives- issued February 24, 2015. The comment period ended April 30, 2015.
  12.  Consolidation: Amendments to the Consolidation Analysis ASU 2015-02- issued February 18, 2015, provides consolidation evaluation guidance for legal entities such as limited partnerships, limited liability corporations, and securitization structures (collateralized debt obligations, collateralized loan obligations, and mortgage-backed security transactions). Effective generally for 2016 with early application permitted.

AICPAAmerican Institute of Certified Public Accountants (www.aicpa.org)

  1. Enhancing Audit Quality - A 6-Point Plan to Improve Audits, issued on May 18, 2015, summarizes responses to a 2014 discussion paper and other inputs, to provide a “roadmap to improved audits” focused on 1) pre-licensure, 2) standards and ethics, 3) CPA learning and support, 4) peer review, 5) practice monitoring of the future, and 6) enforcement.
  2.  Not-for-Profit Section (NFP), a new AICPA section announced on May 11, 2015, designed to provide a broad base of tools and resources, for non profit management, board members, and financial professionals, as well as AICPA members working in the accounting, audit and tax areas.
  3.  Assurance Services Executive Committee (ASEC)

a) How to Design a Credible Verification Program-white paper published on February 26, 2015, “identifies the essential elements of an effective verification program and the factors that should be considered when designing such a program. It also describes the advantages of including CPAs as assessors in a third-party verification program and incorporating the standards they follow into the program…The objective of a third-party verification program is to increase users’ confidence that information (including data) or services provided by others is reliable.”

PCAOBPublic Company Accounting Oversight Board (www.pcaob.org)

  1. Reorganization of PCAOB Auditing Standards and Related Amendments to PCAOB Auditing Standards and Rules (Release 2015-002)– approved March 31, 2015, provides for a topical system for standards grouped by 1) general auditing standards, 2) audit procedures, 3) auditor reporting, 4) matters relating to filings under Federal securities laws, and 5) other matters associated with audits. Effective December 31, 2016 pending SEC approval.
  2.  Observations From PCAOB Inspections Covering Five Audits of Brokers and Dealers (Release 2015-001), released January 28, 2015, summarizes the deficiencies in the initial inspections, with the most deficiencies found in revenue recognition, engagement quality review, risks of material misstatement due to fraud, and financial statement presentation and disclosures.

SASBSustainability Accounting Standards Board (http://www.sasb.org)

  1. Resource Transformation Sector Provisional Standards – issued March 25, 2015, address sustainability disclosure topics relevant for companies in the following industries: 1) Aerospace & Defense, 2) Chemicals, 3) Containers & Packaging, 4) Electrical/Electronic Equipment, and 5) Industrial Machinery & Goods. These standards join those issued for the following sectors: 1) Healthcare, 2) Financials, 3) Technology & Communications, 4) Non-renewable Resources, 5) Transportation, and 6) Services. Several more sectors are in the works.

Europe, Middle East, India & Africa

EFRAG European Financial Reporting Advisory Group (www.efrag.org)

  1.  EFRAG Endorsement Advice on IFRS 15 Revenue from Contracts with Customers, issued on March 18, 2015, gives EFRAG’s endorsement to the new IFRS Revenue Standard, stating that “EFRAG assesses that IFRS 15 meets all technical endorsement criteria of the IAS Regulation and is conducive to the European public good.”

FRCFinancial Reporting Council of the UK (www.frc.org.uk)

  1.  Exposure Draft: FRED 61 Draft Amendments to FRS 102 – Share-based Payment Transactions with Cash Alternatives– issued April 20, 2015, proposes minor changes to FRS 102 to achieve greater consistency with the equivalent requirements of IFRS 2. Comments are due by June 1, 2015.
  2.  FRS 104 Interim Financial Reporting, issued March 19, 2015, based on IAS 34, promotes informative and understandable interim financial reports based on IFRS and consistent with annual reporting requirements of FRS 102.
  3.  Exposure Draft: FRED 60 Draft Amendments to FRS 100 Application of Financial Reporting Requirements and FRS 101 Reduced Disclosure Framework – issued February 19, 2015, proposes “to reflect the revised framework of accounting standards, in particular the proposed withdrawal of the Financial Reporting Standard for Smaller Entities (effective January 2015) (FRSSE) and the proposed introduction of a new accounting standard for micro-entities, draft FRS 105 The Financial Reporting Standard applicable to the Micro-entities Regime.” Also, proposed amendments to FRS 101 to maintain consistency with company law. Comments are due by April 30, 2015.
  4.  Exposure Draft: FRED 59 Draft Amendments to FRS 102 – Small Entities and Other Minor Amendments – issued February 19, 2015, proposes “the presentation and disclosure requirements applicable to small entities based on the new small companies regime within company law, whilst the recognition and measurement requirements of FRS 102 will also apply.” Also, proposed amendments to FRS 102 to maintain consistency with company law. Comments are due by April 30, 2015.
  5.  Exposure Draft: FRED 58: Draft FRS 105 - The Financial Reporting Standard applicable to the Micro-entities Regime – issued February 19, 2015, proposes “a single financial reporting standard that applies to the preparation of individual financial statements of companies that qualify as micro-entities and choose to apply the Micro-entities Regime. It aims to provide micro-entities with succinct financial reporting requirements and includes requirements for the most common and relevant transactions. If transactions are not addressed by this draft FRS either directly or by cross-reference to FRS 102, a micro-entity is not required to refer to FRS 102 in selecting its accounting policies. Comments are due by April 30, 2015. 
 

Additional A&A News 

The following links provide a selection of current articles devoted to highlighting other A&A topics currently making news.

  1. SEC Lacks Accounting Controls It Seeks in Others, GAO Says
  2. FASB Plans Next Phase of Big Accounting Changes
  3. Shrinking audit and KPMG SME offering means practice revolution for UK
  4. IFAC Assembles Global Coalition to Spur Better Public Sector Financial Reporting
  5. Global Audit Regulators Agree on Information Exchange
  6. IASB votes to propose delaying effective date of revenue standards

Audit & Accounting Alert is a publication of Integra International intended to highlight emerging issues in the profession. The goal is to give Integra members an awareness of developments impacting the practice of Audit & Accounting, enabling them to stay on the forefront of industry trends.

Editor Gerald E. Herter  •  HMWC CPAs & Business Advisors, 17501 E. 17th Street, Suite 100, Tustin, CA 92780-7924
 •  Tel: 1 714 505-9000  •  Fax: 1 714 505-9200  •  Email: [email protected]