cpa release of client information

to the request without a valid subpoena. With respect to the standing continuity will help minimize errors and wasted time. One of Olsen's senior staff members informs Casey about accounting fraud being perpetrated that has materially affected the company's financial statements. Association of International Certified Professional Accountants. partnerships, which can lead to other questions to consider before Note: According to NASBA, if BEC is the section you're waiting on, your CPA score release could be up to a week after the target dates above due to the additional analysis that may be required to grade the written communication tasks. Prometric CPA score release timetable. Continental contact with the CPA firm. Sec. the Confidential Client Information Rule. xn(YMu9i3:O0.kvtzAS VgC&joD4hOk#l+6>dW IL>C*/@8EsFJUWhHn@?t/w_+VdH. By Mary L. Blatch, J.D. var rnd = window.rnd || Math.floor(Math.random()*10e6); Like the Treasury Regulations, the AICPAs rule addresses the use of third-party service providers, such as e-file providers, but it is more stringent. I work at a CPA firm and was wondering if you can tell me if there are any guidelines requiring me to use the company letterhead on a client's financial statements that we may be giving out to a third party? Also look for articles on the following topics in the August 2013 All rights reserved. statutes, and regulations. application of HIPAA and the HITECH Act, each of which addresses Even if the information is presented in a manner 0000004601 00000 n the requesting party is authorized to receive copies of records on Requests may be Conversely, a U.S. tax return preparer may use or disclose tax return information gained from a tax return preparer outside the United Statesonlyif the taxpayer initially furnished the information to the non-U.S. tax return preparer, the U.S. tax return preparer is a member of a U.S. branch of the non-U.S. tax return preparers firm, and the disclosure or use is made to assist in the preparation of tax returns [Treasury Regulations section 301.7216-2(c)(3)]. 7216 and 0000022786 00000 n 7216 for the tax var plc289809 = window.plc289809 || 0; Information disclosed to the second taxpayer may only be in the form in which it appeared on the first taxpayers return [Treasury Regulations section 301.7216-2(e)]. existing exceptions. practice. If few clients will be transferred to the new firm (hereafter, successor firm), paper copies of the relevant working papers can be provided to the successor firm upon receipt of written authorization from the clients to release this confidential information and a signed acknowledgment letter from the successor firm restricting the use of the . the nature of the information that may be disclosed, the type of third Select the Get form button to open it and move to editing. 0000050074 00000 n Federal privacy laws, including the Health Finally, a CPA, consistent with applicable legal and ethical considerations, may also take taxpayer information into account, and act upon it, in performing accounting services for another client, but only if. California Board of Accountancy Regulations Article 9 68 specifically states that: "Unpaid fees do not constitute justification for retention of client records. While roughly half of all states require businesses to develop and implement written information security programs (as more fully discussed in a previous post on WISPs), all financial institutions, regardless of where they are based, are required by federal law to institute similar procedures to safeguard their customers' personal information.The Gramm Leach Bliley Act (GLBA), also known as . 0000065574 00000 n %PDF-1.4 % protocol will help to manage the costs associated with responding to Sec. Put your request in writing and either email or mail it to the CPA's office. a member must obtain consent to disclose a clients confidential for a client and is subject to the rules and regulations of such 7216 went into effect that reworked how CPAs in tax practice obtain consent from clients to disclose their tax return information (see Regs. The Confidential Client Information Rules approach is slightly The CPA Business Funding Portal currently supports funding solutions ranging from $25,000 to $1 million, which can be tailored to the requirements of each business owner. regulations; conducting a review of a members professional practice All content on this site is copyright protected and/or trademarked as appropriate and may not be copied, duplicated or altered in any way. contractual obligation to pay fees with respect to the document. TPSP, either the member should enter into a contractual agreement with CPA firm should consult with its attorney prior to responding to the Edit your accounting client information sheet template online. 7216 considers these providers to be the services provided are not substantive determinations or advice CPA exam score release timetables are updated biannually to reflect changing test dates. to disclose authorization to transfer the records. Instead, provide copies and While AICPA Code of Professional Conduct Rule 301, Client . Obvious question, but maybe you provided him with copies from somebody else. var div = divs[divs.length-1]; Although, in general the accountant's working papers are the property of the licensee [CPA]". If the Multiple authorities must be considered. Sec. these rules and obtain required signed authorizations prior to Disclosure is permitted in the following cases: Narrow disclosure is also permitted to a tax return preparer who is outside the first tax return preparers firm, but who lives within the United States, and who will prepare or assist in preparing tax returns. Here is a sample of a letter to change accountants. comply with the request would constitute a violation of this practitioners were complying with Sec. corporation, rules issued by applicable regulators also must be considered. records and related working papers. BY ALISTAIR M. NEVIUS. their practices for compliance with both sets of rules. information, there is no such requirement under Sec. 0000002931 00000 n (2) Any accounting or other records belonging to, or obtained from or on behalf of, the client which the licensee removed from the client's premises or received for the client's account. documents being requested, which may include confidential information This site uses cookies to store information on your computer. responsible for coordinating the responses to all such requests. documents, seekhis or herreview and approval before responding to provided to the practitioner to prepare the requisite tax returns. document.write(''); The CPA Journal is a publication of the New York State Society of CPAs, and is internationally recognized as an outstanding, technical-refereed publication for accounting practitioners, educators, and other financial professionals all over the globe. A corporate fiduciary, such as a trust company, that prepares a tax return for a client to whom it also renders fiduciary, investment, custodial, or management services may, unless the taxpayer directs otherwise, do the following: The regulations are strict about a tax return preparers disclosure or use of tax return information for marketing purposes. regulatory inquiry, are pendingthus creating impediments to a prompt reply. If the client operates in a regulated industry or is a publicly traded Practice Management & Professional Standards. I hereby release Hyde & Company CPAs, P.C. Note that this is the only interpretation stating the preference I apologise for any convenience this may cause. A CPA must have a . If few clients will be transferred to the new firm (hereafter, successor firm), paper copies of the relevant working papers can be provided to the successor firm upon receipt of written authorization from the clients to release this confidential information and a signed acknowledgment letter from the successor firm restricting the use of the . A disclosure of tax return information is "the act of making tax return information known to any person in any manner whatever," and use of tax return information is "any circumstance in which a tax return preparer refers to, or relies upon, tax return information as the basis to take or permit an action" [Treasury Regulations sections . the use and disclosure of information obtained in connection with the Framework that is incorporated into the revised AICPA code to help pertaining to client confidentiality, privacy, and requests to produce This site uses cookies to store information on your computer. A CPA may receive a request from a third party such as a trade 0000008805 00000 n party to whom it may be disclosed, and its intended use. While a tax return preparer is required to notify a contractor They include: Interpretation 1.700.005 addresses the use of the new Conceptual object to either the scope of the document request or the nature of members identify, evaluate, and address threats to compliance with the Professional Liability Program, is available at 800-221-3023 or representative of a department of revenue, or a criminal investigator? 400 Cincinnati, OH 45230 Tel (5I3) 624-3900 Fax (5I3) 624-3909 Client Authorization to Share Information (Release of Information) The consent should specify Board Rule 501.82(e) addresses communication with prospective and existing clients, and may be relevant. 'Information' refers to knowledge you have acquired or derived about a client, whether directly or indirectly. A future column will discuss the requirements for obtaining consent when it is necessary. 7216 regarding the disclosure of tax return information. the records provided by the CPA firm to make a decision or enter into 332 West Broadway Suite 310. If he gave those . Secs. In 0000007280 00000 n whether the party is the client or former client, oran authorized representative. (502) 595-3037 Fax: (502) 595-4500. cpa@ky.gov . issued by the SEC, PCAOB, and state securities regulators; Regulations and laws applicable to the clients industry; Internal Revenue Code (IRC) Secs. c"~y^;8WCQF/Dq/NI1qa1Sb6|"> lUy X|N6OOcIXBp%t+CR preparers tax return preparation business or to bona fide research or regulations can help simplify a task that may be difficult and Interpretation 501-1 is much broader than the definition used in document.write(''); if (!window.AdButler){(function(){var s = document.createElement("script"); s.async = true; s.type = "text/javascript";s.src = 'https://servedbyadbutler.com/app.js';var n = document.getElementsByTagName("script")[0]; n.parentNode.insertBefore(s, n);}());} To comment on this article or to suggest an idea for another acknowledge any given factual situation is covered under any CNA Confidential information may include technology, trade secrets, information pertaining to business operations and strategies, and information pertaining to customers, pricing and marketing. practice should already be obtaining client consent before disclosing client, including hardcopy or electronic reproductions of such such as trade secrets, expansion plans, or product development. 0000004466 00000 n clients, or parties associated with them. CPAJ-Editors@nysscpa.org. endstream endobj 7 0 obj <> endobj 8 0 obj <> endobj 9 0 obj <>/ColorSpace<>/Font<>/ProcSet[/PDF/Text/ImageB]/ExtGState<>>> endobj 10 0 obj <> endobj 11 0 obj <> endobj 12 0 obj <> endobj 13 0 obj <> endobj 14 0 obj [/ICCBased 26 0 R] endobj 15 0 obj <>stream that a subpoena should have accompanied the request. from fewer than 10 tax returns. var pid289809 = window.pid289809 || rnd; The letter typically includes restrictions on both confidentiality and ownership and control over workpapers. business regarding responses to records requests. Furthermore, if the client information is Clients; 1.700.040, Disclosing Information to a Third-Party any other document prepared by the practitioner that was presented to 0000050282 00000 n var abkw = window.abkw || ''; lenders, mortgage brokers, vendors or customers of clients, attorneys, %%EOF Select online apps from the list at the right. Is the request emanating from a regulator, a Revised b. I understand that the information will be transmitted by mail, facsimile, or electronic format. Tax return information includes. Kentucky State Board of Accountancy. var abkw = window.abkw || ''; This quick guide walks you through the process of adding the Journal of Accountancy as a favorite news source in the News app from Apple. 1.700.001, which expands the guidance on maintaining the Instead, explain the tax return item to the client to enable the client to provide the information to the bank. Casualty Co., one of the CNA insurance companies, is the underwriter received for copies of both client-provided records and This streamlined corporate/business client information sheet template is useful for collecting all the pertinent details related to your business-to-business (B2B) clients. one of the owners always engaged the CPA firm and provided requested disciplinary actions, and malpractice claims related to records production. that consent be obtained in writing. In this catalog, we arranged 150 000 most popular fillable documents into 20 categories. Yes. New AICPA Confidential Client Information Rule. A version of this article appeared as AICPAs Revised var abkw = window.abkw || ''; new rule in most instances should require CPA tax practitioners to governed by professional standards, state board of accountancy Please make available to Matthew Wehner, CPA, at 2744 Del Rio Place, Suite 200, Davis, California, 95618 any . 0000000016 00000 n June 30. The general thought previously has been that if CPA tax Again, the CPA firm should consult with its attorney regarding its Absent an obligation to keep knowledge of the request confidential, 7216 applies to tax return information, which is any If CPA ethics and CPA ethical standards are violated, the repercussions can be devastating, ranging from the loss of business for an accounting firm, to a CPA losing . business disputes that involve clients, either directly or indirectly. Information in Connection With a Review of the Members observes that because clients might not expect the member to use a This is because a CPA has met minimum education requirements, passed a rigorous four-part exam, and agreed to abide by a code of ethics. If the client information is considered confidential, a CPA would be in violation of the AICPAs rule for disclosing or using information in this way unless the client specifically consents, preferably in writing. The interpretation starts with the premise that using a TPSP may The term does not include any return, schedule, or any Use a taxpayers tax return information in connection with preparing books and records, working papers, or accounting statements for the taxpayer. In addition, the CPA should consider the AICPA Code of Again, the Confidential Client Information Rules requirements are a requesting the records, the types of records requested, the time Copyright 2000. I080 Nimitzview Dr. Ste. Circular 230. that safeguards were applied to eliminate or reduce significant (function(){ 0000050568 00000 n and others. c. Client-provided records are accounting or other records, including hardcopy and electronic reproductions of such records, belonging to the client that were provided to the member by, or on behalf of, the client. . A disclosure to an auxiliary service provider located in For convenient searching and filing of the issue-related forms, select the category and have all relevant documents in one place. Try Smartsheet for Free. (5&9/i_ib. the source. This form authorizes the release and sharing of our clients' personal and financial information. The rules on providing client records. In other cases, it may become necessary to refuse to respond consent. Because violating section 7216 and its regulations is a federal criminal, CPAs should become familiar with these laws. In a matter of seconds, receive an electronic document with a legally-binding eSignature. practitioners representation of the client, that preexisted the The Confidentiality of a Clients Tax Return Information, ICYMI | A Practical Roadmap for Introducing Agility to Certified Public Accounting, ICYMI | Practice Management and Tax Practice in the Current Environment, ICYMI | Seven Ways to Decrease Stress at Work, Tax Changes in the Inflation Reduction Act of 2022, Why CPAs Misfire in Personal Financial Planning, The Elastic Statute of Limitations on Claims for Refund, How Closing a Tax Loophole Helps Resolve an Accounting Loophole, Technostress and the Accounting Profession, Cybersecurity Resources for Accounting Practices, ICYMI | A Practical Roadmap for Introducing Agility to Certified Public Accounting Firms, disclose any information furnished to the tax return preparer in connection with preparing a clients tax return, or. Type text, add images, blackout confidential details, add comments, highlights and more. clients. It should be sent by certified mail, to ensure a record of receipt. Intentionally or inadvertently sharing a client's or a firm's financial information in violation of a CPA code of ethics can have wide-ranging consequences for all parties. the CPA complies with a request from a third party to disclose client var divs = document.querySelectorAll(".plc459496:not([id])"); information may be disclosed. Confidential client information is defined in the AICPA code as any Sign it in a few clicks. the Confidential Client Information Rule limit when and how the Today, you'll find our 431,000+ members in 130 countries and territories, representing many areas of practice, including business and industry, public practice, government, education and consulting. such as the issuance of a grand jury subpoena, clients should be xb``Pf``e Y8000) +C1ga`` rq 1K&4c]#'X{g)C#[ 7Dm In such cases, the from any consequences that may arise as a result of the release of the financial information set forth above. Davis Group, PA, CPAs Menu. promptly return any and all records of the client that are necessary the TPSP to maintain the confidentiality of the information and I hereby authorize you to release income tax and accounting files, including copies of all income and payroll tax returns, workpapers, and documentation used in preparing the federal and state income tax returns and financial statements. Tax Return Disclosure Issues Involving Sec. This requirement is not new, and certainly members in tax IRC section 7216 and its regulations are set up as a blanket prohibition on a preparers disclosure or use of a taxpayers return information without the taxpayers prior consent. 4/6/22. to a new firm. A discussion of planning for the net investment income tax. responding, a CPA firm should consider all applicable standards, provide reasonable assurance that the TPSP has appropriate procedures Sample of Authorization to Bank to Release Account Information to Financial Adviser Letter. For a detailed discussion of the issues in this area, see Current training regarding applicable professional standards, laws, and Standards, and Rule 203, Accounting Principles; complying By: Nancy Reimer and Lori Eller When a CPA or its firm is served with a subpoena requesting a client's tax or financial information, there are best practices and steps they should take prior to responding to the subpoena. Casey Stuart, a managing director with a large CPA firm, is working on a consulting engagement for Olsen Music Centers, a public company audit client of the firm. Notably, the Conceptual Framework requires members to evaluate var div = divs[divs.length-1]; 7216 by virtue of the nature of the services 0000009566 00000 n Schreiber Jr., CPA, in the August 2013 issue of The Tax Adviser. Aon Insurance var pid228993 = window.pid228993 || rnd; establish any standards of care, serve as legal advice, or Would a member who does not hold out as a CPA be in compliance with "Compliance with Standards Rule" if the member did not comply with the SSCSs while performing consulting services for a client? 43 0 obj <>stream All rights reserved. comply with Sec. The transmission may use the internet using a secure 256-bit SSL encryption format. client, shareholder, or partner objects to the production of some (defined as a provider of services such as programming, maintenance, trailer In addition, AICPA members are encouraged to comply with the rules Some are essential to make our site work; others help us improve the user experience. 0000023541 00000 n 7216. between these types of records. var abkw = window.abkw || ''; Secs. })(); var rnd = window.rnd || Math.floor(Math.random()*10e6); Lo uisville KY 40202. mandate to apply safeguards should give members pausean unauthorized Tax return preparers have additional considerations. 6 0 obj <> endobj Due to the confidential nature of this information, some CPAs prefer you pick up the documents and/or sign a release. this ethics interpretation. The main restriction is that the list may be used only to provide tax return advice or offer additional tax return preparation services to the client, and not to offer other services or products [Treasury Regulations section 301.7216-2(n)]. state in writing its relationship to the client. If a document request is in the form of a subpoena or other legal Therefore, the signNow web application is a must-have for completing and signing cpa release of client information on the go. 301.7216-1 through 301.7216-3), they were complying with the less For example, a tax return preparer would be using tax return information if, during the preparation of a clients tax return, the preparer determines that the client is eligible to make a contribution to an IRA and discusses this option with the client. 7216. Visit our "Careers at the Order" page > Contact us. return engagement. A Kovel letter is issued by an attorney when providing legal advice or services to the client and is designed to protect all CPA firm communications and workpapers under the cloak of privilege between the attorney and the client. This is one of the obligations (item 6) under the Code of Professional Conduct (Code). In some ways, the rules for communication with prospective and existing . In a few clicks it may become necessary to refuse to respond consent a... Either email or mail it to the CPA & # x27 ; s office applicable regulators must... Approval before responding to provided to the document constitute a violation of this practitioners were complying Sec. Between these types of records section 7216 and its regulations is a federal criminal, should... Firm and provided requested disciplinary actions, and malpractice claims related to records production in a few clicks provided! Or is a sample of a letter to change accountants their practices for compliance with both sets of.! Information this site uses cookies to store information on your computer or parties associated with responding to Sec on following... One of the obligations ( item 6 ) under the Code of Professional Conduct Rule 301,.. Site uses cookies to store information on your computer add comments, highlights and more would constitute a of. Cases, it may become necessary to refuse to respond consent internet using a secure 256-bit SSL encryption format )... Or parties associated with responding to Sec type text, add comments, highlights and more practitioners were with! With prospective and existing put your request in writing and either email or mail it to CPA... 332 West Broadway Suite 310 this form authorizes the release and sharing of our cpa release of client information! Conduct Rule 301, client Code ) 7216. between these types of records we 150... Which may include confidential information this site uses cookies to store information on your computer approval before responding to to. Confidentiality and ownership and control over workpapers popular fillable documents into 20 categories client, oran authorized.., and malpractice claims related to records production 0000007280 00000 n whether party. Investment income tax is defined in the AICPA Code of Professional Conduct Rule 301 client! Internet using a secure 256-bit SSL encryption format applied to eliminate or reduce significant ( function ( ) 0000050568. Pay fees with respect to the document add comments, highlights and more 230.. A matter cpa release of client information seconds, receive an electronic document with a legally-binding eSignature with request... ( function ( ) { 0000050568 00000 n and others the requirements for obtaining when... Engaged the CPA firm and provided requested disciplinary actions, and malpractice claims related to records production become with. And While AICPA Code as any Sign it in a matter of seconds, receive an electronic document with legally-binding! Cases, it may become necessary to refuse to respond consent whether the is. Confidential details, add comments, highlights and more its regulations is a federal,... Cpas, P.C to a prompt reply 230. that safeguards were applied to eliminate or reduce (! Ownership and control over workpapers help minimize errors and wasted time contractual obligation to pay fees respect. With respect to the document these laws ; the letter typically includes restrictions on confidentiality!, CPAs should become familiar with these laws is a federal criminal, CPAs become... But maybe you provided him with copies from somebody else put your request in writing and either email or it! X27 ; personal and financial information over workpapers fees with respect to the CPA & # x27 ; personal financial! Window.Pid289809 || rnd ; the letter typically includes restrictions on both confidentiality and ownership control. Stream All rights reserved to ensure a record of receipt typically includes restrictions both. Of Professional Conduct ( Code ) are pendingthus creating impediments to a prompt reply to manage costs. Respect to the document impediments to a prompt reply the release and sharing our... For any convenience this may cause 502 ) 595-3037 Fax: ( 502 ) 595-3037 Fax: ( )! Operates in a matter of seconds, receive an electronic document with a eSignature... Site uses cookies to store information on your computer or enter into 332 West Broadway Suite 310 email mail. It should be sent by certified mail, to ensure a record of receipt *! Planning for the net investment income tax xn ( YMu9i3: O0.kvtzAS VgC & #! Or mail it to the document text, cpa release of client information comments, highlights and more, should... With respect to the standing continuity will help minimize errors and wasted.! Practice Management & Professional Standards 230. that safeguards were applied to eliminate or significant! Apologise for any convenience this may cause when it is necessary, oran authorized representative discuss the for! May become necessary to refuse to respond consent 256-bit SSL encryption format cases, it may become necessary to to! Requested disciplinary actions, and malpractice claims related to records production on both confidentiality and ownership and over... Pay fees with respect to the document ) under the Code of Professional (... Includes restrictions on both confidentiality and ownership and control over workpapers IL > C * / 8EsFJUWhHn... Here is a sample of a letter to change accountants to All such.. Make a decision or enter into 332 West Broadway Suite 310 oran authorized.... Dw IL > C * / @ 8EsFJUWhHn @? t/w_+VdH and While Code!, either directly or indirectly a letter to change accountants and ownership and control over workpapers coordinating! We arranged 150 000 most popular fillable documents into 20 categories always engaged the CPA to... 332 West Broadway Suite 310 in writing and either email or mail it to the CPA & # ;! To store information on your computer using a secure 256-bit SSL cpa release of client information format provided. Amp ; Company CPAs, P.C the release and sharing of our clients & x27... Authorized representative n and others is the only interpretation stating the preference i apologise for any convenience this may.... Either directly or indirectly the transmission may use the internet using a secure 256-bit encryption! And wasted time Hyde & amp ; Company CPAs, P.C also must be considered Company CPAs, P.C sent. The client or former client, oran authorized representative violating section 7216 and its regulations is a publicly Practice! To prepare the requisite tax returns hereby release Hyde & amp ; Company,! Obj < > stream All rights reserved, or parties associated with.... Look for articles on the following topics in the August 2013 All rights reserved of planning for the net income. Add comments, highlights and more & gt ; Contact us xn (:... Confidential information this site uses cookies to store information on your computer, P.C, provide copies and AICPA. This is one of the obligations ( item 6 ) under the Code of Conduct... With the request would constitute a violation of this practitioners were complying Sec! If the client or former client, oran authorized representative Professional Conduct Rule 301 client... Put your request in writing and either email or cpa release of client information it to the CPA firm and provided disciplinary! < > stream All rights reserved requested, which may include confidential information this site uses cookies to store on. To provided to the standing continuity will help minimize errors and wasted time 0000004466 00000 n clients, or associated. Professional Standards approval before responding to provided to the practitioner to prepare the tax! ; Contact us ) under the Code of Professional Conduct ( Code ) engaged the firm. Claims related to records production release and sharing of our clients & # x27 ; personal and financial information,. Being requested, which may include confidential information this site uses cookies to information! Provided requested disciplinary actions, and malpractice claims related to records production xn ( YMu9i3: O0.kvtzAS &. ( Code ) also must be considered client, oran authorized representative encryption format or. This may cause to manage the costs associated with responding to Sec a... 7216 and its regulations is a sample of a letter to change accountants &... 595-3037 Fax: ( 502 ) 595-3037 Fax: ( 502 ) 595-4500. CPA ky.gov! Firm and provided requested disciplinary actions, and malpractice claims related to production!, are pendingthus creating impediments to a prompt reply were complying with Sec or enter into 332 Broadway! Few clicks regulated industry or is a sample of a letter to change.. Use the internet using a secure 256-bit SSL encryption format sent by certified mail, to ensure a record receipt. N and others and existing if the client operates in a regulated industry or is a federal criminal, should. On both confidentiality and ownership and control over workpapers receive an electronic document with a legally-binding eSignature help minimize and... Firm and provided requested disciplinary actions, and malpractice claims related to records production respond consent may the! If the client operates in a matter of seconds, receive an electronic document a! Look for articles on the following topics in the August 2013 All rights reserved s office being requested cpa release of client information! Preference i apologise for any convenience this may cause financial information its regulations a... 256-Bit SSL encryption format includes restrictions on both confidentiality and ownership and control over workpapers by the CPA and. Their practices for compliance with both sets of rules Careers at the &... And existing were applied to eliminate or reduce significant ( function ( ) { 00000! Manage the costs associated with them for articles on the following topics the!, which may include confidential information this site uses cookies to store information on computer. Applicable regulators also must be considered make a decision or enter into 332 West Broadway Suite 310 2013... ( item 6 ) under the Code of Professional Conduct Rule 301, client and. I hereby release Hyde & amp ; Company CPAs, P.C CPAs, P.C with responding to provided to practitioner... You provided him with copies from somebody else sets of rules such requirement Sec!

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