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Proposed Ballot 2007-08 Comments

Jurisdiction/Company Position Comments
Alabama Opposed Oppose as written. The ability to waive either, but not both of the registrant record keeping requirements is already included in the Audit Procedures Manual. It is currently the base jurisdiction’s responsibility to require the registrant to adhere to the requirements. Furthermore, it is currently the Peer Review Committee’s responsibility to ensure that the base jurisdiction is complying with the Audit Procedures Manual provisions.
Washington Opposed Do not support this ballot. Jurisdiction should strive to treat each registrant equally. Suggest eliminating a jurisdiction’s ability to waive a requirement.
ATA Opposed Literally, from what’s here a waiver of one of the requirements or the other must be in writing, but a waiver of both of the requirements need not be. What would reasonable cause be in this connection? What does “that fleet” refer to? What is meant by the registrant’s “accounting system”? When would such a system be deemed to be still “in effect”? If, as the introduction to this proposal says, sometimes a state’s policy puts the state’s auditor in “a compromising position,” isn’t that the state’s business and something that the auditor, a state employee, has to live with (or not)? Strongly opposed.
Oregon Opposed Do not support. This imposes another administrative burden on the jurisdictions and another element subject to a peer review.
Total supporting: 0
Total opposed: 4
Total undecided: 0