Cognition, Cloud Accounting engine, for Mobile platform developers.

We are witnessing an explosion, of new generation Mobile Platform "Apps", targeted towards business; in particular the sole trader (tradies, consultants ect) and small business owner or operator, and their staff.


Most of these Apps have very simple, and also very good user interfaces, in many cases better than the transitional software developers like ourselves. Additionally they move with the times, it does not take 4 years to get a basic function like an estimate, in many cases new stuff happens weekly or monthly at the longest. The typical Mobile developer looks at business functions with a new insight, they are not "cut down" versions of existing desktop accounting software.


Today you can get a Mobile App to do almost anything.

But any analysis of this market, shows in almost every case (Freshbooks is an example) these Apps lack even the most basic accounting functionality and none of the ones we reviewed had even the basic double entry accounting or complied with any of the accounting standards or registrations. We typically got responses like, "we don't need any accounting standards, as we target non-accountants", but this is no excuse to not comply with reporting and compliance standards. Removing complexity, for a target market is a grand goal, but one still needs the basics. In fact Freshbooks was the catalysis for Cognition, as we needed a engine to allow accountants to perform back office, Activity Statements, and perform basis accounting functions, bank loan reporting, bank feeds, tax returns ect. In many ways Freshbooks was our first Cognition "App" but the integration was done at the back end database, not the front end App developer. This approach has many draw backs, synchronization being the lest of these. We concluded that to be successful, the integration must be done at the developer App level.


Even non Mobile accounting solutions, like the market leader Xero maintain a set of +/- transactions, rather than the traditional double entry, which one can see within their journal API.

When it comes to functions like BAS, online ATO returns, bank feeds, AAS25 reporting and compliance with accounting standards, the typical "App" is found to be sadly deficient..

Compliance and reporting is the "Hard" bit and takes a lot of time and money to get right..



The new bread of App Developer
The rapid growth within the Apps market, has been driven by "Free" or very low cost applications, which are very easy to use, most cost less than $20.. This means that any paid App needs significant volume to make money..

If an App developer, makes use of an traditional accounting solution say Xero as their engine, they hit the "Fee" brick wall, where the excessive fees, limits the "volume" and in most cases will stall the App take up, free trials do not help. Also these traditional solutions, compete directly with the Apps market developer, this leaves very little market for the agile Mobile developer, and their customers.

We see that there is a fee threshold or about $100 per year, for this market.

Additionally the interfaces for the likes of Xero are way too complex, and not suited to the typical "light weight" application developer.

Volume underpins the success of any mobile platform "App"..

The Future Accountant
Many say the future for accountants is bleak, the increasing pressure from Adviser channels and the cost of new AFSL compliance, makes it all toooo hard. Many who are reaching retirement, see it as time to move on..

We, actually see a rosy future for the new generation accountant especially for those servicing, sole trader, trade persons, consultant, or road warrior small business, offering a local personalized service to their clients.

Most of this markets clients do not really care about BAS/IAS, tax returns, they "need " to focus on their day to day business, the last thing on their "to do list" is producing complaint reporting for Banks or Investors or the ATO.

While the new generation of Apps, can keep track of payments and cash flows, most of the Apps market users are time poor, and more than happy to "in-source" professional advice and specialist services.


The "in-sourced", virtual CFO, the future of accounting..

Also working with accountants over the years, many are latent "developers".. in that they realise the only way to differentiate themselves in the market is to offer unique and personalized services to their clients. If all practices use Xero where is the differentiation, from a clients perspective.

As there are currently over a Million Android Apps, in the market today, so there is no shortage of App developers in the market.
The new generation of Accountants get this differentiation,and have the "savvy" to understand the market changes.

With the release of Cognition, a practice can now offer a totally unique and personalized service to clients via any Mobile Platform..

Accountants simply re-selling Web Site services like Xero, Reckon, MYOB are the "old world"...
The future is unique practice services, delivered directly to your clients, you own and control your destiny.
Bottom line you can provide superior and in almost all cases, a more cost effective solution to your clients.

In marketing world this is called the "sticky client"...



Cognition "The Cloud Accounting Engine"

Enter the Australian first, and only, dedicated cloud accounting engine for Independent Software Developers.
Unlike all other cloud accounting services, Reckon, MYOB, Xero, Sage quicken ect.
Cognition has no user interface, it is exclusively a "engine" for App developers, to provide the Enterprise Accounting back end to their own "Apps".

Developer
Features:

• Free to all Sole Traders
• Fixed fee of $50 per year, or $5 per month which includes payroll..
• Only developers can use engine, as no end client interface, so fee cannot be under cut.
• Zero account setup fee, above fixed fee can be bundled "in App" all services are white labeled.
• All access via, secure, light weight REST API, using JSON message sets.
• API is free, to all registered Australian App developers.
• No Cognition "App" or web service to compete with.
• Secure, Enterprise double entry accounting engine, been in use since 2000, long before the likes of Xero even existed.
• ATO registered, for BAS/IAS with integrated SBR gateway
• Secure cloud based Auskeys
• Unlimited translations per entity,
• Unlimited customers, suppliers per entity
• Limited to 20 staff (SME market), and fair usage.
• The API usage is also unlimited, Xero has 1000 transactions, and rate limited.
• The API has paging, which limits the max set to 100 entries per page.
• Optional support for SMSF Apps, via our SMSF365 service engine.

Functions

• Invoicing, Estimates
• Expenses, Receipts
• Projects, Tasks
• Time Entry
• Payments
• Items
• Staff
• Contractors, Suppliers, Prospects
• Payroll
• Tax

Accountant Only
Features:

• SBR for activity statements, via AWO
• Tax returns, via AWO
• Optional Payroll Processing via AWO
• Traditional accounting system, journals ect, with AAS25 reporting for SME's
• Registered with the ATO.
• Payroll Bureau with AWO
• Same accounting engine in use since 2000, used in Web Ledger, Web Office and SMSF365 services.
• Deliver in-sourced, professional accounting services

Cognition: Cloud accounting engine, partners with Australian App developers and Accountant services to deliver the future today.



Availability

• Trials Q3 2014, available to all Australian App developers, and Accountants
• Commercial availability Q4 2014.

Disclaimer The contents of this site should not be understood to be accounting, taxation or investment advice but rather as general product related educational information that may or may not meet your specific requirements.

Bitcoin "Private Money"

With a rush of  people fleeing the various effects of Fiat currencies, especially from China, Greece and Cyprus, digital currencies such as Bitcoin have become part of the financial landscape, with ~ USD$8,000,000,000 in capitalisation today.

The above statement, may sound like, I am a supporter of BitCoin, far from it, I see a number of issues with BitCoin, a hard supply cap, the significant first mover advantage, and liquidity at the Fiat currency interfaces, are but a few, but the discussion around BitCoin and its treatment as a currency or property, needs to be both rational, and have some basic is reality.

The Bitcoin with a hard supply cap, has a built-in deflation, while most western countries including Australia require an underlying inflation rate. The purpose of inflation is to drive people to invest their money into something productive, it also pays of national debt. Deflationary currency undermines productivity, and essentially provides a disincentive to be productive, as all new value created drives down the value of existing property. But I digress..

So back to Oz, the ATO has been grappling with the question of whether to classify Bitcoin as money or property for years, just like the rest of the world.

Bitcoin is effectively pseudonymous and potentially anonymous.  But, it’s important to understand the difference between “anonymous” and “tax fraud.”  Knowingly or intentionally refusing to report or pay taxes on income earned is by definition – tax fraud.  Whether you’re likely to be caught is an entirely other argument.  Mixing the two is a mistake that we shouldn’t make.

The furphy about tax evasion and Bitcoin is just that, tax evasion occurs today inside all of the Fiat currencies worldwide without exception.

Many people believe that if the ATO “doesn’t know who owns the BitCoin” and if their wealth is “entirely in BitCoin,” then the ATO can’t touch them, on the assumption that the ATO does not know who owns a BitCoin. The problem with this argument is that it is short-sighted and factually incorrect. But it is a fact that inside the BitCoin domain there is little or no transitional knowledge, beyond a peer-to-peer exchange.
As an example, John Doe owns a million BitCoins, and spends AUD buying houses, cars ect..The ATO has all of John's AUD transactions from Johns Fiat bank account, and calls and asks where did this money come from?  John can’t explain where the money is coming from and is slapped with a tax bill. The ATO does not need to identify the transactions inside of BitCoin, does not need to know a single BitCoin holder address to affect its tax collection obligations.

Hence in practice, the only way "States" like Australia, have control over Bitcoin flows,and any associated Tax treatment, is to treat BitCoin as Unit of Account, similar to how the ATO treats foreign exchange currencies, and use the banking system (AUD Fiat Currency) to track it once it "leaves" the Bitcoin world.

One can simply forget about the techo waffle of treating BitCoin as property, and tracking Bitcoin addresses (a joke), this is a reaction to Bitcoin being a non Fiat currency, and the need for "States" to have treaties around the control of "Currencies" nothing to do with the reality of BitCoin transactions.

Probably the most thought though classification of Bitcoin comes from Germany, who treats it as unit of account or "Private Money".

"On 19 August 2013, the German Finance Ministry announced that Bitcoin is now essentially a "Unit of account" and can be used for the purpose of tax and trading in the country. It is not classified as a foreign currency or e–money but stands as "private money" which can be used in "multilateral
clearing circles". Then they lost it, with capital gains and sales tax.

The Solution, must be simple..
FX Transactions
Bitcoin trading has FXGains ect.

Non FX Financial Transactions
Financial transactions have Capital Gains using Bitcoin FXrates same as any currency, as Bitcoin is a non Fiat currency, there is no currency tax, just normal taxes within the actual financial transaction which use Bitcoin as the foreign currency.
Bitcoin is always a foreign currency for all parties.

Where to Tax
For this to work, taxes are applied to all transactions which pass outside of the Bitcoin world (currency), i.e at the point of entry into any entities domiciled Fiat currency. All "States" have the ability to track all such transactions today, so also nothing new required.

This matches the existing cash economy today.

There are no taxes inside Bitcoin (same as no GST on bank transactions ect), this is constant as there is no taxes with "Cash" transactions today.

Bitcoin is just a non fiat currency, all the same currency rules should apply, simple.

The classification of Bitcoin as "Private Money" gets around a lot the treaty issues and matches more closely with the real world..

Australia either plays in the big pond, or becomes irrelevant as a significant number of Chinese, Russians (Cyprus) and Greeks have already voted with their feet and left the Fiat currencies.



Approach
Keep it simple, require minimal changes, i.e reuse as much as possible of existing legislation and infrastructure, and address issues as they evolve..



1. Bitcoin's deflation problem
2. A unit of account is a standard monetary unit of measurement of value/cost of goods, services, or assets. It is one of three well-known functions of money.^[1] It lends meaning to profits, losses, liability, or assets.


Disclaimer The contents of this site should not be understood to be accounting, taxation or investment advice but rather as general product related educational information that may or may not meet your specific requirements.

Cloud Accounting, it's not all roses..

There has been a recent rush, to Cloud based Accounting, and also Cloud based Practice Management solutions, but what is the downside issues to consider..

As one of the pioneers in Cloud based solutions from back in 1999, there are a few things a Practice partner should consider..

The advantages are spruiked in numerous places, hence in this posting, we will look at some of the potential disadvantages and how these may be addressed.


The Accounting Practice
A Practice needs to be able provide evidence to authorities to justify our accounts and tax claims - possibly years after the fact, satisfy legal requirements to keep records, answer owners questions, satisfy ethical requirements of documentation.


1. Back Up and Restore

The accountant who maintains accounts that (legally) belong to someone else, and now all the data is outside of the control of both the accountant and the client.

a) In the old days, one simply saved a copy of the client accounts in MYOB or whatever, as at the date the end of year or BAS was prepared. One could simply load back the saved file into the accounting program and all was available.

b) In most cloud based systems, there is very little archive or even back up capabilities, and even less ability to restore any of these files to a specific client account.

c) When the client stops paying for the service, what use is a proprietary exported file, that cannot be accessed, anyway?

2. Service Disruptions

All computer systems have a uptime which is not 100%.

a) What is the maximum loss of data (time period)  in the case of an service disruption?

b) What is the maintenance schedule.
The ATO recently closed down its entire SBR for over 4 days to do a "update"?
While no-one has any control over the ATO, one should ensure that ones accounting system, and data, is able to be used when one "needs" to..

3. Disaster recovery
When clouds have issues, they tend to affect all of their users.
One could consider the Megaupload case as an extreme example, but can one be sure..
"MYOB General Manager Julian Smith says the data sovereignty issues in this case fall into a “grey area” of US law."  The issue is foreign and even our governments will give priority to their own considerations, the users as in this case are "collateral damage"..
a) "Hurricane Katrina created a number of challenges for Gulf Coast businesses, chief among them being data protection. While many companies utilized remote data backup services - or had the foresight to ensure that their backups were completely safe – others were left with submerged computers and no backups".
b) In the last Brisbane floods, several organisations who has stored paper records, and computer backup tapes, in their basements found them destroyed.

4. Service Level Agreements
These Cloud services support your business, so you need to know exactly what you are paying for, and if it is approperate for your operational requirements.
a) Check out if there is an SLA at all?
b) If there is a SLA look to see if they actually pay penalties, when they breach their SLA; always a good litmus test

5. Security.
Saw a recent positing, on one of the major Accounting providers, basically stating that they use SSL, so clients don't need to care about their data or any security! Also this specific positing started with "Our Security Experts" and then left these as anonymous.
a) Any security professional knows security is never equal to "encryption" or in fact any single security mechanism. There is a basic premise around "security in depth".
b) the recent Heartbleed SSL bug, is but one example of how silly,and potentially liable these types of statements are.


The Solution
Ok, so we get the picture, so what can we do about it.
1. Backup and Restore
As one cannot own the accounting software one need to have a non-proprietary format which can be stored under the Practice or Client control. It is preferable that this file can be given to the ATO, if required without change, the second best is  the ability to use industry standard products like Excell or any Spreadsheet to provide the required evidence.

Within all VillageMall solutions including Practice Manager,  we make use of the international
OECD SAF-T archive formats.

2. The minimum acceptable level, should be the ability to recover, in a stable state, for at least the previous night, some providers will do this on an hours basis.. The "stable state" is particularly important as most cloud based systems are multi-tenanted databases, i.e a single database is service all clients.

3. Disaster Recovery
With the availablity of several enterprise Australian based data centers, and the new APP 8 privacy act requirements, there is simply no reason to take on the risks associated with storing client and practice data outside of Australian jurisdictions. In the case when data needs to be stored outside of Australia to meet geographical independence, then this data should be 100% encrypted in transit and at rest.


Cloud services have lots of upside, so keep smelling the roses, as you find them...

Disclaimer The contents of this site should not be understood to be accounting, taxation or investment advice but rather as general product related educational information that may or may not meet your specific requirements.

The $1.7 Billion "Flush", of Tax and Superannuation members dollars..

Like one of the silent "majority" of tax payers, it is with some despair, that one watches tax money being flushed down the drain.

A few facts to start with, which politicians seem to miss:

• politics is not the best way to pick market, or technology winners or losers
• political interference, be it well intentioned, almost always distorts markets, and can actually destroy existing market participants (pink bats, solar energy)
• government departments with unlimited tax payer funding, should not compete with commercial entities on an non-commercial basis. A level playing field must actually be level.
• if a specific technology needs to be "mandated" to get anyone to use it, should sound alarm bells.

The programs in question are the Standard Business Reporting (SBR), and more recently Superstream.

These government run program names, are always interesting, SBR is anything but "standards" based, and superstream is only "super" in its ability to spend tax payers and superannuation members money.

The first look

This particular SBR program is quite strange, some obvious aspects:

• run by treasury, actually a front for the ATO, obviously some internal political issue?
• no review or accountability on any aspect of the project to-date
• after many years, and millions of $$$ already spent, almost zero adoption by any commercial organisations
• unknown millions wasted by commercial organisations, when promised returns are never realised.
• after many years, still cannot process a basic "Individual Tax Return"
• recently closed down for 4 days for "updates".. this is simply not commercially viable.
• use of ATO propriety technologies, that have never been deployed anywhere in the world, for this type of application, the sole country with limited usage, is Denmark, and they could not get any commercial take up
• technologies that any competent technologist, would advise again using, as simply not fit for purpose.

Yet it continues... and in fact this year..
To overcome the almost zero adoption of the program, the current government has decided to mandate usage, rather than doing a traditional review of the BC, this is after an expenditure in excess of $400 Million to date.

If it looks like a dodo, acts like a dodo, it is likely to actually be extinct.
Bit like John Cleese's "parrot" it is only on the perch because it is nailed there, it is actually deceased.

Superstream is a good example, of something gone amiss.
"The main purpose of SuperStream is to ensure employer contributions are paid in a consistent, timely and efficient manner to a member’s account."

Today, and for the last 15 years to my knowledge, employers of all sizes have been paying and reporting member payments to superannuation funds via their payroll system, and BECS for almost zero additional cost. All banks are capable of passing member data though to funds, via their existing bank data feeds.
The Problem to be solved as identified above, simply does not exist...

For anyone involved in rollovers of members superannuation funds, knows it is the Superannuation fund "hoops"  that is always the issue, not the transfer technologies.

Technologies are never good at solving "people" or "business process" issues.
Hence to suggest that something which is not broken, requires $1.2 Billion to be spent, could only exist inside a tax payer funded, government department, perhaps looking at building a "Yes Minister" empire?


So what went wrong?

• why is treasury doing commercial software development?
• why is there zero accountability for any deliverables under the program?
• why is a basic Individual Tax Returns not supported after many years?
• why is a working ELS system being trashed? rather than replacing the antiquated ATO proprietary bits with commercial technologies?.
• why are their zero client deliverables, all are internal?
• why does the system need to be closed down completely, for up to 4 days at a time, just to "update"
• why is there no review of the past $400+ million expenditure?
• when was the original BC reviewed?
• why is no common sense or normal business accountability being applied to this program?
• why would anyone invest an additional $1.2 Billion to achieve a saving of less than a cup of coffee?
• why is there a mandatory levy, to pay for the program which no-one wants (other than those with a financial gain from the program) that can be done today, using existing commercial infrastructure, for almost zero additional cost.

This program is technically flawed, would not make it past the "initial" gating process in any commercial organisation, yet has spent in excess of ~$400M (no-one has an actual figure, even treasury) to date, with zero return or quantified savings over existing systems. Plus has had a  "negative affect" on Australian Developers (the ATO paying millions to overseas companies is not developing jobs for Australians, just like we funded 100+ of factories in china to make pink bats, and sent local Australian companies broke), and is planning to spend $1.2 Billion to solve a problem that does not exist..

The technical issues are very straight forward, the politics seems confused at best..

Bottom line, after almost 10 years (2005), not a single cent has been quantified as actual savings, which is a direct result of SBR, and yet without any review another $1.2 Billion is planned to be wasted..

If the current Government was actually interested in reducing waste, they would start by looking inside the Treasurers own department..

Litmus Test
1. Google Standard Business Report or SBR, and look for any independent support, i.e not from a government department?
2. Look for any expenditure reporting and qualified savings for this program?
3. Look for any factual basis for the "potential" savings of $800 Million anywhere?
4. Look for a comparison of SBR with the existing ELS and other existing electronic programs?
5. Look for any accountable "person", political or otherwise.

This is a "Yes Minister" program, worthy of its own episode.


-- Links and additional information.
1. Extract of email to Joe Hockey, April 2015.
To: Joe Hockey
Treasurer
CC: Chris.Bowen, Wayne Swan, Emily Devine (SBR)

Dear Joe  Hockey,

Within your department there is an planned expenditure which is seriously flawed in both design and implementation, this program is a legacy from the previous Government, but has the potential to exceed the likes of the "Pink Bats" and  "School Sheds" programs.
 ...
I don't get involved in politics, I am part of the silent majority..
       But wasting $1.7 Billion to get a  return of less than a cup of coffee, is just too much to sit by and let happen.
...
Australian Software developers are one of the few areas that Australia does better than anyone else in the world today, and most likely into the future, it has the potential to replace the old world jobs rapidly disappearing in Australian..
But all of this is in jeopardy, in the same manner as poor government decisions destroyed the "home instillation", zero jobs today,and it looks like the same with the Solar Industry.."
-- end snip

2. The objective of the SBR Program in Australia is to reduce the cost of reporting for business by A$800 million over six years at a cost of A$320 million over the same period.^[5]

In October 2005 the Australian government commissioned the "Task force on Reducing Regulatory Burdens on Business," known as the Banks Review. Recommendation 6.3 called for the development and adoption of a business reporting standard, which became "Standard Business Reporting."

The SBR strategic plan was approved with a Commonwealth commitment of $243 million over four years.
On 3 July 2008 COAG endorsed Standard Business Reporting as one of nine additions to the regulation reform agenda (COAG Communique, 2008).

The business case developed by the Australian Treasury estimates that the average costs of implementing SBR by businesses will be $403 per business.

3. The costs associated with the implementation of the Super Stream measures will be collected as part of the superannuation industry levies.
The levies will recover the full cost of the implementation of SuperStream reforms and will be imposed as a temporary levy on APRA-regulated superannuation funds from 2012-13 to 2017-18 inclusive.
The amount of levy payable is subjected to the Minister’s determination.
The costs associated with the implementation of the SuperStream reforms are $121.5 million in 2012-13, $111.1 million in 2013-14, $83.1 million in 2014-15, $69.3 million in 2015-16, $41.2 million in 2016-17 and $40.9 million in 2017-18.

4. No SuperStream silver bullet: Bravura

5. Funds deeply unprepared for SuperStream

6. Using Tax File Numbers as the primary superannuation identifier

7. SuperStream working group· Tax File Numbers and account consolidation

8. The Tax File Number Scheme:  A Case Study of Political Assurances and Function Creep

Disclaimer The contents of this site should not be understood to be accounting, taxation or investment advice but rather as general product related educational information that may or may not meet your specific requirements.

The New breed of Accountants

The new breed of accountants

There’s a new breed of younger practitioners coming through that understand technology, and see the benefits, but a lot of it will be driven by the clients too.
We see these practices, picking up clients at the moment, from their current accountant, who doesn’t know Xero, doesn’t understand it and doesn’t want to understand it.

The client says: ‘I want to use Xero, it suits my business. 
But..if I have to print out my reports to give it to you, I don’t see the benefit'.
I need you to help me with the compliance stuff like BAS, Company Tax returns, and provide me timely advice on my business.'

They demand an Accountant who 'gets it'..

The Technology Revolution..

Cloud Technology is revolutionising how accountants work. The major driver of this change is elastic cloud computing, and storage; which is enabling not only companies, but their accountants with better and faster access to business intelligence that they can then use to advise clients. Cloud computing allows a company or a practice to access applications from an offsite cloud provider via the internet, rather than from company-owned and maintained hardware and software.
This provides 'software as a service', which in turn allows businesses to pick and choose best of breed software, bringing together online accounting, inventory, business intelligence, CRM, payroll, Jobs, Client billing, online Tax form processing, and many other packages.

Cloud computing has driven a proliferation of high quality software packages, available on a monthly or yearly subscription basis. This is particularly beneficial for businesses in the SME sector. Previously, the world class functionality available with some of this software was too expensive to be economic for SME’s, whereas today, the entry cost is very low, a typical accounting practice solution is currently sub $2000 per year, for a complete practice solution.

With the introduction of online accounting software, such as Xero,Quickbooks Online, SMSF365 and Simple Fund 360, ect..; accountants can now access client information on-line in real-time. This has made the accounts preparation process more timely and efficient, as well as opening up access to more up-to-date and detailed business information.

The benefits of having your financial statements prepared sooner are numerous. Whether it is managing cash flows, meeting banking covenants, understanding how a business has truly traded, or assisting with forecast preparations.

Less time taken preparing accounts also leaves an accountant with time to spend more time on understanding  the client business and providing insightful advice, enter the age of the Virtual CFO, for even small SME's. Access to the information online also means that this advice is based on real-time information. On-line access has the added benefit of encouraging greater collaboration between businesses and their advisors which in turn leads to better governance. It is well documented that good governance is crucial to the SME sector. So while there is still a need for great people on your board, that are willing to challenge and bring their experience to bear, technology is playing an increasingly important role in assisting more effective governance. 

But...

When we look at the typical suburban Accounting Practice, which are SME's, they are mostly "back in the dark ages". The concept of "eating ones own cooking" is a truism..

Many accounting practices, don't use online accounting services for their own practice client billing. In the rare case, when they do, this system is not linked or integrated with the Practice Management, or even their SMSF Administration system, so each exists as independent islands.. never to communicate or share data.

And yes each of these separate applications has their own fees..

The fact ... a typical suburban accounting practice, has many of the same drivers as their client companies.

The New Practice
The changes to the accounting landscape, by the arrival of cloud technology, cannot be underestimated. Cloud accounting, championed by a wide range of technology providers, does away with the old business model, and has the capability to make a range of existing accounting services obsolete, especially the low value services..
This change, is normal, and no different to the demise of the typist, travel agent, or corner shop in recent years.

The economics
With a Cloud based solution, the practice is purchasing the utilisation of a fully hosted and managed Practice Management service, via an online service provider. There is no software updates, no power outages, and no initial capital expenditure, and it’s all paid by a single yearly fee.

We have found the usual decision point for change, comes when a practice receives the quote for the "upgrade of existing servers", or the partner looks at the "current fees" being paid to older desktop Practice Management Software, which typically have not been updated in years.

A modern Cloud based Practice Management solution, can be as little as $2000 per year for up to 25 employees... this is probably less than the cost of electricity, to run the existing servers.

The costs
At the same time, the focus on costs is creating more outsourcing of work to locations around the world.
We are seeing a lot of  practices off-shoring work, especially SMSF related activities, to places like the Philippines, Malaysia, India. These countries are creating centres of excellence, with highly qualified staff and pushing the mundane work into even lower cost jurisdictions.

Over the last couple of years we have seen more of the higher value activity, such as SMSF compliance, also being pushed into those low cost jurisdictions. Previously it was processing work like invoicing, data entry, very much back office functions and data gathering, but we’re now seeing more value add, more strategic work, work that needs a better knowledge of accounting or tax rules.

We see this as an interim stage, the true Cloud Practice replaces routine work with automation, and concentrates its staff on high value add, activities like virtual CFO's ect..

The recent privacy laws on 'cross-border disclosure of personal information' while they do not prohibit outsourcing to overseas countries, simply make it a more onerous task, for any Australian Practice; as the Practice is now responsible for the client data if it is "disclosed" overseas.
See Does your data still call Australia Home

The Agile Practice
Because it is accessed online, the software is Mac or PC, mobile phone, tablets of almost any type compatible, well almost all.

There’s unlimited data storage, as the practice information is not held on the internal network. As a result, the business is not constrained to the storage, or memory on its desktop computer; as data is securely held in the cloud. And most importantly, it can be securely accessed from anywhere. This provides convenience and enhanced business agility. The only thing the firm, or any of its employees need is an internet connection, anywhere, anytime.

This approach gives a practice, the flexibility to adapt very quickly to the changing needs of an organisation, or the accounting market in general. We see a future that for some client companies,  it allows the Practice to better embed themselves into the client organisation, this is our vision of the next generation "in-sourced" accounting practice.

The level of compliance work, as a proportion of a practice business will reduce. What is holding many Australian firms back from the cloud are fears of security, with sensitive data moving out of a company’s local premise into "the cloud".  Many worry, with good reason, that the information might be accessed by un-authorised individuals. An example, is practices using insecure, USA located, free services to transfer client files...
This, in turn, creates great concern over practice governance, risk and controls.
Many of the more recent providers, are starting to ensure only authorised individuals can access data in the cloud, but many of these are located outside of Australia; Xero accounting and their WFM, is an obvious example. This is a bit like allowing anyone to logon to your internal system today, one needs to be sure your provider has a lot of Cloud operational experience, most of these providers did not even exist a few years ago. VillageMall has been providing Cloud based services since 1999..

To address these concerns, the leading software cloud providers, offer a practice" the option" of a cost effective 'Private Cloud' solution, where the practice retains ownership and control of the Cloud Practice, in a manner similar to their existing on-site services.

Today, there is simply no reason, that Client or Practice data, should leave the legal jurisdiction of Australia.

There is no compelling reason, that a Cloud solution, should require a fundamental change to your existing on-site compliance environment today, you simply don't need the hassles..

The barriers
One of the biggest hurdles to moving a Practice to the Cloud has been ATO tax form support, most cloud based practice solutions have been short of delivery in this area, it is "always next year".
But in 2014, this barrier has been removed by the Industry leading solution providers.

The old world Desktop Software Lockin
One would hope that a practice would move towards being "completely paperless", so that the many associated efficiencies can be realised, and also move to a subscription-based service offering.

Within the next few years, all practices will be able to jettison the license fees for there "old world" (read way to expensive...) software; they’re locked in at the moment. It’s all about timing the escape from the locking contracts, and additionally offers a practice the ability to move from one software support product to another more nimbly.

Compliance
There is a wide range of privacy,and compliance issues being faced by a practice.
At a minimum the following should be addressed by all Practice Management Solutions:

• Integrated, secure (100% Encrypted, and located in Australia) Records Management System.
• Registered against Taxation Ruling TR 2005/9 requirements
• Storage designed to meet Australian Privacy principle APP 8 (March 2014)
• Corporations Act in s286(1)
• X509 Signed Digital Timestamp, to meet legal filing date, and integrity requirements
• Implements an out-of-box "Standard Business Classification Scheme"

The Future practice
The key to the new cloud practice is the "automation" of  low value process intensive tasks..
At VillageMall, within our Practice Manager, we are getting close to a total automation of Activity Statements, via our unique Cloud SBR Tax modules.

The actual process..
1. Setup the client record with ABN and check Activity Statement
2. On the first week of each month, our Automation robot, will use the Practice Device Auskey, to pre-fill  the Client Activity Statement, from all of the clients enabled above, and the ATO has generated a AS for this period.
3. The automation robot will also create a Practice Job, using the Practice specific job template, and mark it as active, plus set the due date to match the data extracted from the ATO Activity Statement.
4. The Job is assigned to a staff member (manual bit)
5. Staff member reviews the ATO pre-filled form, and fills the form from the linked client Xero accounting package, yes just a single click (the high value bit)
6. Subject to authorisation, the Activity Statement can be submitted directly to the ATO in real-time.
7. Job is closed and Client invoice generated from job details, directly inside Practice Xero account.

It done..

Note, that Staff do not need to leave the Practice Manager application, everything comes to the staff member as they need it. Also they do not need access to the Practice Xero accounting system at all.


The Future is here Today..

See  Practice Manager for details.

Disclaimer The contents of this site should not be understood to be accounting, taxation or investment advice but rather as general product related educational information that may or may not meet your specific requirements.

The Accountants Practice, will it go the same way as Car manufacturing in 2017...

Australian Car manufacturing will disappear in 2017.
Typists are no more, online travel bookings are the norm, teller banking is going, or priced out of the mainstream..

Where will the typical, local accounting practice, be in 2017, or even next year?

Its seems like a life time ago, way back in 2005, that we released our Web Office fully integrated solution for Australian SME's.

At the same time net suite was just starting out, but very few would pay several $1k per year, and $10k, to $20k to setup a "total solution", which did not even do Australian payroll, sales force aimed at the least setup, with a small part of the net suite offering.

So here we are in 2014 almost 10 years latter, very few if any Practices have a best practice solution, most have a set of disjoint applications, on various platforms.

A few things we have learned over this period, about Accounting Practices..

• Most offer a range of client accounting services the most common being
  a) Company setup, BAS/IAS services
  b) Company Tax returns
  c) Tax Agent services, and advice.
  d) SMSF year end accounting, audit and tax returns.
• Of the over 480,000 funds almost 80% are held in Accounting Practices typically 20 to 50 funds.
• SMSF's make up only 20 to 40% of a typical Accounting practice client base.
• Most SMSF's do other business with their accountant.
• The majority of existing SMSF's were setup by an accountant.

The Specialist SMSF Admin Myth..

SMSF's are  still, a "cottage" industry, there are No economies of scale, few if any SMSF admin specialist firms make money, and they individually manage a very small proportion of the total SMSF funds..

One can count the number of MSSF admin firms with greater then 1,000 fund on ones hands.

AMP after consolidation of several admin firms is reported to have some 11,000 funds.

Why is this so?

Specialist SMSF admins miss the point, that an SMSF is just a part of the relationship they have with their local accountant.

While the Industry tries its best, to make SMSF's very "complex" and wave the ATO compliance "red flag", the reality for the majority of SMSF's are that they are very simple.

The typical fund, has a set of Managed Funds, some Australian Equity shares, Fixed Interest and perhaps some property or unlisted investments, which don't churn, the other significant group are fully in pension mode, also simple; with a a range of funds in between these.

So the problem is actually fairly straight forward, after all this is a "SELF" managed super fund business.

What about  Back Office Outsourcing?

There has been a steady growth in overseas suppliers of back office providers, but the largest of these has less than 15,000 funds..

I believe the future of BPO's is to "in-source" directly into an local Accountant Practice

What about Accounting Practice groups?
These tend to be  a set of  independent Practices, with little or no common systems, mainly though the lack of scale able system solutions in this space.

The SMSF Admin Software Myth..

The reality of any "non monopoly" market, is that there is a tendency to converge service offerings and price.

While there is a lot of hype at the moment between a few players, about how their solution is "far" better than anyone else..

The reality, is that all offer mostly the same solutions, the differences are very minor and tend towards personal preferences, rather than technical capabilities.

Debates about what is a cloud, and comparing very technical aspects like remote access to browsers access in a modern day environment is rather useless from an Accounting Practice perspective, it simply does not matter.

From an SMSF accounting software perspective, SMSF365, Class Super and BGL360 all are very similar, and to be honest almost impossible to make a case for one over the other at this basic level, all will meet the typical accounting requirements. Also Software prices are now tending to the norm of ~ $100 per fund per year as almost all software providers off a online service.

So what about the future of Accounting Practice Management?

Non SMSF accounting has become a commodity, Xero is an example of this.

But as SMSF's make up only a small percentage of a typical practice, the issue is not about SMSF accounting software, but rather about how it integrates in to the "Accounting Practice"..

Many practices have gone from the high cost specialist services, to the current set of "bolt" on applications.

The last thing a practice needs is yet another SMSF Software "island".. it all gets tooo hard..

The SMSF side of the business must integrate into the "business".

The typical Practice does not have a "big" problem to solve, a typical practice is quite small so the "fees" for a "Practice Management" solution should be "fit for purpose"..

Document Management?

Physical paper documents are like the dodo bird, they disappeared years ago..

All service providers supply electronic documents these days, Banks Telco's ect, it will cost you extra, to get paper. It has become socially unacceptable, bit like smoking, to store and distribute paper,and other than small set of very specific cases paper is not legally required.

Having said this, I did get a call the other day to say his SMSF Admin firm, had just sent him a "box" of color printed Fund documents; his comment was even the Invoice was printed in color!
The bit he really liked (sic) was pulling the documents apart and scanning the pages to a PDF file, for his own use, yes there was zero electronic documents. And yes trees are still being cut down in 2014.
It is archaic practices like these that killed off the Car industry.

Document management, at the practice level is almost non existent, at best it is a set of "folders" on a local server, at worst it is stored within public services located in the USA, i.e "dropbox" etc and yes, the client data is stored unprotected in these foreign data centers.
In almost all cases there is zero encryption applied, and a Practice often stores "sensitive" data for their clients. At a  minimum all stored documents "should be encrypted at rest" as even "local servers" are now connected to the internet. Once again simply best practice.

It will be interesting to see the effect of new Privacy Laws which come into practice in March 2014 regarding APP8 cross boarder controls over client data, and how some of the Accounting Practices will meet this requirement. APP8 also applies to use of foreign based Back Office service suppliers. Several cloud based service providers use very low cost "Rackspace" hosted in Texas in the USA

Enter SMSF365 Practice Manager
Give that we already have our own Web Office solutions, we decided to provide a complete Accounting Practice solution as part of our "SMSF365 Accounting Practice" service, and to provide it for no additional fee.

As most Accounting Practices are using Xero for many aspects of their practice, we decided to integrate SMSF365 with Xero workflow max, to allow a practice to get an immediate gain, and preserve their investment, mostly time and effort, and not require yet another "new" set of practice software.

This allow allows a fully integrated solution from day one, plus get immediate productivity gains.
An while we believe SMSF365 is the best cloud based SMSF software available, it simply does not matter, for the typically 20 to 50 SMSF funds within a typical Accounting Practice, and while we would love to have a single account with 100,000 funds this is simply not the reality of the Australian SMSF market.

As the only SMF sofware to support ATO SBR SMSF tax returns we are uniquely positioned with the addition of Xero integration to support a integrated Accounting Practice Solution.

The Next Step
Given that the practice now has a cost effective and simple to use solution, what next?
Xero accounting has quite reasonable fees, but Xero workflowmax is quite expensive..

Hence our strategy:

• Allow integration with existing Xero WFM clients, to preserve their investment.
• Integrate directly with Xero Accoutning: Inventory items, Invoice, and payments.
• Offer a simple version of WFM, using our Web Office feature set, included in the SMS365 base fee
• Extend our ATO SBR offerings to support non SMSF sevriecs, like company, BAS/IAS tax returns
• Develop a set of stanardised Job templates to suite SMSF Admin, and Financial Planning aspects of a Accounting practice..

See details at
http://www.villagemall.com.au/content/WebSuperFund/Service/smsf.htm

Conclusion
Unlike, Australian based Car manufacturing, there is a bright future for the Modern suburb based, Accounting Practice, providing a range of "trusted" services to their clients.
But like all industry segments, there is always a need to ensure world best practice, in every thing we do..

Disclaimer The contents of this site should not be understood to be accounting, taxation or investment advice but rather as general product related educational information that may or may not meet your specific requirements.

SMSF Administrators Going going... Gone..

The 2013 year end, saw an extraordinary level of take-over activity in the Self Managed Super Fund (SMSF) administration space. The sector has long been regarded as a ‘cottage industry’ due to its high level of fragmentation, the majority are managed via accounting practices with less than 20 funds. This situation has persisted despite remarkably strong growth in fund numbers over the last decade. With even the largest of SMSF administration firms holding less than two per cent of the overall market, the potential for consolidation has become an increasingly hot topic, and many have begun to believe that a consolidation is overdue.

AMP’s Paul Sainsbury released a statement saying, “This is an exciting and attractive sector and it makes sense for AMP to look for growth opportunities in this market.” yet there has been underwhelming traction from AMP over the last few years. It is not apparent that AMP has achieved, via consolidation of existing SMSF admin firms,more total Fund numbers than specialist online firms like esuperfund. The 10,000 barrier seems to remain, even with outsourcing to foreign domiciled BPO's.

So far, Australia’s other major financial institutions have chosen to wait and see how AMP’s foray into the sector progresses before announcing their own intentions. Recently ANZ sold its own foray into this market (superconcepts[1]). This leaves a hand full of  independent SMSF admin firms with typically less than 1500 funds, there is simply no economies of scale with this small number of funds, when compared to a typical Industry or Retail Superannuation provider.

 However, there are various factors that suggest consolidation may become a major trend in the SMSF industry in the coming years. One of the biggest of these factors is the shift towards "in-sourcing", as apposed to the more traditional "outsourcing" used by many large corporates' world wide.

The majority of small to medium accounting businesses (these groups make up the lion-share of firms administering SMSFs) provide a wide range of accounting services and often only look after a small number of self managed funds. As a result, these firms frequently have trouble finding and retaining staff with the specialised skills required to administer an SMSF. In addition, their processes tend to be highly manual and inefficient causing unnecessary errors and delays.

While the recent trend has been for "AFSL Advisors", this push is not coming from trustees themselves, who traditionally use their accountant for much more than just SMSF's, in fact the majority of Australia's SMSF's have more linkage and ongoing synergy with their accountant then with any other professional group.

National Development Manager at SMSF Advice Limited presented part of an Investment Trends survey to the SMSF Professionals Association of Australia (SPAA) in June 2012 which indicated that 22 per cent of accountants planned to outsource their SMSF work if the licensing legislation was implemented as proposed.

Yet the problem with outsourcing, is one of relationship control,and transparency, this is especially important with the changes to the Privacy Act (APP8) cross border controls.

The fact still remains that accountants are one of the very few "Trusted" professional, their holistic relationship to their clients is their "bread and butter".

People go though the pain of an SMSF for "control" over their superannuation, all the other issues are secondary.. the whole concept of outsourcing is foreign to this prime objective.

We see the future of  SMSFs as one of in-sourcing to the SMSF trustee, this is effectively what accountants have been doing for many years, the Trustee obtains professional services from their accountant as required.

But we see this as expanding to include a wide range of professional service providers, advisors, lawyers, auditors, actuaries ect..

The key is control is retained by the trustee, not outsource to some faceless back office in a foreign country..

From a technology point of view, the move towards consolidation and especially in-sourcing begs such questions as; ”What sort of platform solutions will the large-scale SMSF  administration firms of the future require?”, and ”Will they actually have any control over these platforms?”.

Within the Retail and Industry Superannuation world, the platforms are provided by the "custodians", the superannuation providers, simply utilise these services, and in many cases, from multiple Custodians. Much like investment managers have a panel of brokers.

In 2014, we released a DIY version of our enterprise SMSF365 service, this was designed specifically for this next generation "in-sourced" world, focused around the Trustee.

Our enterprise SMSF365 Accounting Practice is still the focus point, but now Trustees can in-source just like large Superannuation providers do with custodians today, but for any "professional service" provider..

So back to the Accounting/SMSF admin practice...

As a firm grows, its portfolio of funds often becomes more diverse in terms of the investment types that have to be catered for. One of the key advantages of a self managed fund is the ability for members to invest in almost any asset type they choose – hence large administrators will require a solution that allows them to easily manage complex investment instruments such as futures and options, across global markets as well as assets that are held in foreign currencies. If an efficient solution for managing these complex investment types is not properly implemented, they can easily create a roadblock in the administration process and lead to a significant decline in efficiency.

Over the years we found it strange that all current software solutions, require accountants to perform external calculations within spreadsheets, and then journal the results into their accounting software, which universally has no concept of multiple currencies, let alone any of the FX translation rules. This process is very expensive, as one accountant recently stated, it cost us over $1200 to just process some 300 trades, the client does not understand how time consuming this is. Back in 2008 we developed Broker Portfolio Services, which is a back office solution, to perform all these tasks; in 2012 we fully integrated BPS into our enterprise SMSF365 service, spreadsheets are now a thing of the past..

In addition to a powerful investment management system, online communication between the accountant and an increasingly "mobile client" is an essential tool, vital to maintaining efficiency and ensuring fund compliance.

An administrator will often be presented with transactions which cannot be properly processed without further information from the client. Deferring the processing of these transactions to the end of the year not only reduces efficiency, but can also result in inadvertent breaches of contribution caps, pension draw down limits, and even lead to a breach of the terms of the Superannuation Industry Supervision Act.

Comprehensive online reporting and fully automated processing of trade related transactions combined with fully complaint (7/10 year retention) document management has the potential to drastically reduce processing delays and provide members with more timely information, allowing them to avoid any inadvertent breaches.
Ongoing growth in the self managed super fund sector seems assured as more and more Australians look to take control of their retirement savings.

What about outsourced SMSF Administration firms?
The reality is, that the typical accounting practice, is not going to grow from  20 to 10,000 funds anytime soon. We have a similar vision for accounting practices, as we have for Trustees, we see an in-sourced future for specialist SMSF Administration firms, operating in much the same was as custodians do today.
The difference is the platform is universal, owned by the Trustee, and not limited to a specific firm.

This matches our mantra of "Technology plus Knowledge" equals competitive advantage.

In-sourcing potentially provides a ‘best of both worlds’ solution for an industry based heavily on personal relationships between suburban accountants and their clients. In-sourcing ensures the relationship between the accountant and their client is retained, while allowing the administration work to be done professionally by a team of specialists. By limiting themselves purely to providing SMSF administration services, an in-sourcing firm can more easily streamline their operations and apply their focus to developing the most effective processes for delivering timely lodgement and reporting, the same applies with audit,actuary and investment advice. Outsourcing is going...going, the future is in-sourcing within existing trusted relationships, with full transparency,and control in the hands of the Trustee.

What about Trustee education?
In theory there is no difference, in practice, this area is slowly maturing as specialit sites spring up and new education specialists enter the SMSF market, it seems strange that we can get online education for our children, but not for SMSF trustees.

What about Financial Advisers?
While the trustees of some SMSFs also seek professional financial planning advice, the majority of SMSFs have no formal relationship with a financial planner. The in-sourcing model not only provides a platform for advisers (we don't change any fees for Adviser access accounts), it also supports the "Know your Client requirement of their AFSL, and additionally a fee for service model.

The potential impact of SMSFs on industry funds?
Industry funds have consistently been losing their ‘large account balance’ members to SMSFs in recent years and this trend looks likely to continue.
The resulting reduction in average member balances increases pressure on fees as the industry funds are forced to spread their members’ costs over a proportionately smaller pool of money. Industry funds are increasingly finding themselves forced to develop more flexible solutions for their members in an attempt to retain them and slow the loss of funds to SMSFs. The model outlined here allows industry funds to offer an integrated SMSF solution, within a traditional Enterprise space. Technology will be an integral enabler in this shift and will inevitably lead to further consolidation in the industry fund market. One of the main issues with retail and industry superannuation is their "legacy" infrastructure and non compatible Custodian  platforms, change will happen slowly, if at all.

Do we eat our own cooking?
Yes, we offer a Virtual Private Cloud, this is an in-sourced version of our SMSF365 service, which an wholesale entity can 100% own and control.

What about pricing?
Pricing tends to be very chaotic, some have volume based pricing, some have base process then heaps of add on, bit like buying a $50 low cost airfare then paying $100 to put your bags on.
With cloud based elastic computing there are no real economies of scale, the fees grow proportional to resources used, which equates to the number of funds processed. Hence all fees should be known and fixed, this allows deterministic pricing for all in the chain. For SMSF365 there is a single $80 per fund per tax return year.. Simple...

The development of a new and more powerful generation of SMSF software platform, focused on the needs of Trustees, and yet tailored to the needs of growing accounting practices and back office administrators, will allow the industry to provide a more professional, comprehensive and timely service to members, at a lower cost.

This technology driven shift will open up the benefits of self managed funds to a much larger proportion of Australians, driving increased member engagement across the industry and allowing more people to take personal control of their retirement savings.

With over $2.6 Billion leaving the Superannuation industry for SMSF's last year alone, the time is right for a Trustee and their Accounting Practice to lead change to the SMSF world.

This is the way forward for SMSFs.


References
[1] Financial Observer 31 Oct 2013;  http://www.financialobserver.com.au/articles/anz-sells-super-concepts


Disclaimer The contents of this site should not be understood to be accounting, taxation or investment advice but rather as general product related educational information that may or may not meet your specific requirements.

"Honey I shrunk the Kids"... Moment.

It's the 1st Jan 2014, a new year...

something's just creep up on you, no "big bang" just gradual change..

All my bank accounts are now on-line, I never go to a bank any more. don't even know who my bank manager is ?

But one of the most surprising  realisations is that all my Family Documents, and online accounts details are "every where"..

What if I had an accident or died, how would my family gat access to all those important family documents and access details..

Now my first though was my Wife will have everything, but we plan on travelling a lot more together in the future, so what about the kids ect, and where do we put all of the "Important Stuff".

A quick check shows we have stuff all over the place, and some stuff is only known to me..
Last year we moved most of our  infrastructure online, so stuff is now on my mobile, my work computer, in data centres, and the cloud..
every picture I take, is stored on my "Google drive" linked to my mobile phone..


So Where Does One securely Keep Important Family Documents?
While there are lots of online storage, none really come close to providing the secure means of allowing access to "trusted" people who is not yourself..

All rely on an account and access password details, once you give it away, then it is no longer secure.. and keeping track of these ever growing account details is an issue in itself..

The latter I solved with a secure password storage program we developed, based upon need, many years ago, when I founded a security company "Spyrus Australia" .. and still use today..

I use it because I know how it was developed, and it utilises some of the high assurance cryptographic technologies we developed for the Military, Governments and fortune 50 companies across the globe..


A Solution?

Let’s borrow an ancient yet incredibly useful idea: if it’s really important to get your facts right about something, be sure to have at least two or three witnesses. This is especially true concerning matters of life and death but it also comes up when protecting really valuable things.
By the 20th century, this “two-man rule” was implemented in hardware to protect nuclear missiles from being launched by a lone rogue person without proper authorization. The main vault at Fort Knox is locked by multiple combinations such that no single person is entrusted with all of them. On the Internet, the master key for protecting the new secure domain name system (DNSSEC) is split between among 7 people from 6 different countries such that at least 5 people are needed to reconstruct it in the event of an Internet catastrophe.
If this idea is good enough for protecting nuclear weapons, the Fort Knox vault, and one of the most critical security aspects on the Internet, it’s probably good enough for your Family Documents.

The Technologies..
One of the technologies we developed to protect the "Root" key in our Certification technologies was  a split key technique, which distributed parts to many individuals ( these were on secure smart cards), and the process of combining these parts back together.

One of the problems with very secure encryption, is that is it secure, and cannot be circumvented even by the people who developed it. Hence once your data is encrypted, one of the real issues is how to prevent  the loss of access to your data, the issue we needed to solve for the Root private key used in a global certification infrastructure.


The Family Document Service, is born..
We have developed a secure solution, which addresses the issues above, and provides secure storage, with a split key access scheme.

We plan to released in the first quarter 2014.

Complete piece of mind, for those Family Documents, from only $20 per account per year.

See http://my.familydocuments.biz for details..




Disclaimer The contents of this site should not be understood to be accounting, taxation or investment advice but rather as general product related educational information that may or may not meet your specific requirements.