Maryland AG Opinion on BOI Reporting

[Lee B]

Copied from today's AICPA Town Hall:

"Earlier this month, Maryland Attorney General (AG) issued an opinion on whether assistance by a CPA with BOIR would constitute the unauthorized practice of law (UPL). Determined that it’s fact specific and provides guidelines

• What is NOT UPL:

• Raising awareness

• Guiding clients through FinCEN’s FAQs/Compliance Guide

• Filling out the BOIR based on client information

• Answering client questions where the question and answer “do not call for legal knowledge or skills”

• CPA “generally should not answer a BOIR-related question for a client where there is uncertainty as to the answer and resolving that uncertainty would require legal knowledge, skill, and judgement”

[Gail in Virginia]

19 hours ago, Lee B said:

"would require legal knowledge, skill, and judgement”

Well, that's all sorted then.

[Medlin Software, Dennis]

Skill and judgment take real skill and judgement to determine. Along with some good old fashioned (now un)common sense.