"The other key has been the IRS's recognition of the compromises necessary to make things happen, particularly exempting CPAs, Enrolled Agents and tax attorneys from educational and testing requirements. I don't think this was the best outcome. but it was probably the only way the program would have been accepted." Right, give an exemption to a special group, so there would be no gripes from the "big boys". Make the little guys absorb more costs for little benefit, but don't ruffle the "big boys" feathers. If this turns out like most other regulations imposed by federal, state and local governments, all this will do is line the pockets of so-called higher learning groups. TPIN's have been required for a number of years. The IRS could have weeded out the bad preparers and ones who never obtained their TPIN's. Just another kick in the face to the little guys.