If "tax preparers" haven't previously taken SOME form of CPE, then shame on them! With the new "limited" representation rules under the RTRP certification, just create "category 4" (along with CPA's, EA's & Attorney's) and proceed as originally planned. Let "Mom & Pop" continue to call themselves "tax preparers" when they're not busy running their "Convenience Store" and let their "ignorant clients" (who are trying to save a dollar), suffer the consequences!