D. Gerald Searfoss, DBA, CPA

13704 E. Bellessa Lane

Spokane, WA 99206

January 5, 2009

Ms. Lisa Axisa

National Association of State Boards Of Accountancy

I am a retired partner from Deloitte & Touche, having served as the National Director of

Accounting Standards for the firm, and I am a Professor Emeritus of Accounting from the

University of Utah. Over the years I have served on the NASBA Education Committee

and served on and chaired numerous AICPA committees, subcommittees and task forces,

including serving on and chairing the Financial Accounting and Reporting Subcommittee,

which reviews and approves all CPA examination questions regarding financial

accounting, and serving on the CPA Examination Content Committee. Most recently, I

was a member of the AICPA Practice Analysis Oversight Group that spearheaded the

study of the current skills and knowledge practitioners and others believe are necessary to

My experience with the preparation of the examination and the practice analysis both

support the conclusion that the amount and complexity of knowledge and the requisite

skills to practice and serve the public interest is growing rapidly, not declining. The CPA

examination is a mechanism to judge competency to practice, thus the content of the

examination should reflect that growth in knowledge and complexity and the diverse set

of skills to serve the public interest. If the results of the practice analysis are incorporated,

as they should be, in developing the future content and approach of the examination, the

increase in expected knowledge and topical complexity will be reflected accordingly in

the exam. If the examination does not accomplish that, than shame on us!

As you know, the publ

ic accounting profession is under the highest level of scrutiny in its

history. There is a level of expectation that is extremely high, and rightfully so. We have

told the public that we hold ourselves to the highest level of professionalism and integrity,

and we tout the CPA examination as a tool to demonstrate a high level of competence

upon passing the exam. Given both NASBA’s and the AICPA’s significant roles in the

preparation and administration of the CPA examination, it appears that the conclusions in

this report will be viewed as a leading group in the profession speaking out of both sides

of its mouth, sending contradictory messages. It will be implied that the examination is

not the tool that we claim it is.

limited exposure that one can achieve in only a 120 hour undergraduate degree versus

150 hours of higher education is inappropriate. It undersells this profession and seems to

establish low expectations of those who desire to be certified. Accounting education

should prepare students and future CPAs to practice in the public interest, possessing the

necessary level of knowledge and skills, and the exam should be designed to test those

accordingly.

I continue to believe that 150 hours of higher education should be necessary to qualify for

taking the exam and to practice after appropriate experience.

D. Gerald Searfoss

D. GERALD SEARFOSS, DBA, CPA

Address:

13704 E. Bellessa Lane

Spokane, WA 99206

Telephone: Home 509-290-6302

Cell 801-550-9788

• Bachelor of Science - Economics

• Certified Public Accountant – Utah

Positions Held

• 2007-Present Emeritus Professor of Accounting (retired)

• 1994-2007 Professor of Accounting (tenured), University of Utah

• 1983-1994 Partner, Deloitte & Touche (retired) (See details of my

• 1982-83 Visiting Professor, Deloitte & Touche

• 1980-82 Professor of Accounting (tenured), University of Utah

I was responsible for the development of Deloitte & Touche positions and comment

letters regarding proposed FASB and AICPA guidance on accounting issues, an

presentation of the firm’s views at related public hearings of the FASB. In addition, I had

the responsibility for providing training and consultation to partners, staff and clients on

accounting for pensions, postretirement benefits, current values, and employee stock

ownership plans. I also had responsibility for the development of publications that

provided internal guidance on auditing and accounting issues. Examples of clients that I

consulted with on accounting issues include Boeing, Chrysler, General Motors, Loews,

Prudential, RJR-Nabisco, Rockwell, and UPS.

Responsible for the relationships with academia and the development and implementation

of firm efforts to impact accounting and business education.

Secretary and Treasurer of the Deloitte & Touche Foundation - 1991 - 1994

Responsible for the administration of the Foundation including budgets, program

development and implementation and the matching gift program. The Foundation is

• Member, Editorial Board, Accounting Horizons, 1994-97

• Member, Editorial Board, Issues in Accounting Education, 1995-98

• Vice President, Financial Accounting and Reporting Section, 1993-94

• Member, 1992-93 Administrative Support Committee of the Administrators of

• Member, AAA Financial Accounting Standards Committee, 1990-93

• Member, AAA Financial Reporting Issues Conference Committee, 1990-92

• Vice President of the Association, 1988-90

• Member, AAA Standing Committee on Publications, 1986-89

• Member, AAA Committee on Relations Between Academics and Practitioners, 1988

POSITIONS / MEMBERSHIPS IN PROFESSIONAL ORGANIZATIONS

American Institute of Certified Public Accountants

• Member, CPA Examinations Practice Analysis Oversight Group, 2006-present

• Member, CPA Examination Content Committee, 2005 - 2007

• Chair and Member, Financial Accounting and Reporting Subcommittee, 2003- 2007

• Member, Financial Accounting and Reporting Simulations Task Force, 2003-2006

• Member, Accounting Standards Executive Committee (AcSEC), 1986-1989

• Chaired, AcSEC Task Force on Amortization of Discounts on Certain Acquired

• Member, AcSEC Task Force on Accounting for Quasi - Reorganizations

• Member, AcSEC Task Force on Discounting Applications

Financial Accounting Standards Board

• Member, Interest Methods Task Force

• Member, Working Group on Voluntary Disclosures in the Oil & Gas and Chemical

POSITIONS / MEMBERSHIPS IN PROFESSIONAL ORGANIZATIONS

• Member, Education Committee, 2000 – present

Utah Association of CPAs

• Chair, Annual Educators Conference Committee, 2002-03

• Chair, Strategic Planning Committee, 1996-98

• Past Member, National Advisory Forum

Federation of Schools of Accountancy

• Member, Federation of Schools Of Accountancy, Curriculum Content Committee,

• Member, Committee on Transitioning For Change, 1991-93, 1996

AWARDS

• 2003 University of Utah, David Eccles School of Business, Masters Programs

• 2002 University of Utah, David Eccles School of Business, Distinguished Faculty

• 1995 University of Utah, Beta Alpha Psi Outstanding Teaching Award

• 1989 Indiana University, Beta Alpha Psi Outstanding Alumnus Award Recipient

An Investigation of the Attributes of Top Industry Audit Specialists, Behavioral Research

Shanteau)

Employers' Accounting for Employee Stock Ownership Plans, Journal of Accountancy,

February 1993, (With Dionne D. McNamee)

(With Judith Fellner Weiss)

"The Handbook of Accounting And Auditing, Second Edition". Warren, Gorham &

Lamont, 1989. (With Robert S. Kay)

"The Big Unfunded Liability: Postretirement Healthcare Benefits", Journal of

and Russell Coff)

"Intermediate Accounting", Second Edition (With Paul B.W. Miller and Kenneth Smith).

PUBLICATIONS

- continued

"Uncovering Corporate Irregularities: Are We Closing the Expectation Gap?", Journal of

"Corporate Irregularities: Bankers' Expectations and the New Audit Standards", The

Journal of Commercial Bank Lending, (Vol. 59, No. 11, July 1977). (With David Baron,

Douglas Johnson, and Charles Smith)

"Some Behavioral Aspects of Budgeting for Control: An Empirical Study", Accounting,

Organizations and Society (Vol. 1, No. 4, 1976)

"Perceived Participation in the Budget Process and Motivation to Achieve the Budget",

Academy of Management Journal, December, 1973 (With Robert M. Monczka)

"Academic and Practitioner Reactions Regarding the Relevance of Accounting Research",

Harvard University.

Accounting Conference. 1989, The University of Alabama.

"Accounting Standard Setting: Follies, Fables and Reality", 1986 Accounting Executive

in Residence Program, School of Accounting, San Diego State University.

Management: An Invitational Conference, Graduate School of Management, University

"Accounting Research: A Need for Emphasis on Relevance", 1984 Annual Accounting

Convocation, University of Alabama.

Barry E. Cushing and Reed Randall), 1979 University of Chicago Annual Conference on

Education Process", Thirteenth Annual Western Regional Meeting of the American

SELECTED PRESENTATIONS

- Continued

"Fraud and Adverse Management Behavior: Three Perspectives on the Detection and

Annual Western Regional Meeting of the American Accounting Association.

PROFESSIONAL MEETINGS

"The Financial Reporting Impact of Postretirement Benefits", National Association of

Corporate Directors, Boston Chapter, 1992.

"Financial Reporting Issues Related to Post retirement Benefits", RJR/Nabisco Financial

Reporting Group, 1990.

"Current Financial Reporting Developments", 1986 Annual Technical Update, Financial

on Public Personnel Administration.

"Current Accounting Issues", 1984 Annual Meeting, North Carolina Association of CPAs.

"The Organizational and Motivational Issues in Managing a Corporate Accounting

"Methods for Estimating Current Costs", Financial Accounting Standards Board

• Past member, Editorial Board, Accounting Horizons. A journal of the American