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The Consumer Financial Protection Bureau And the Tax Representation  IndustryImpending enforcement from the Consumer Financial Protection Board could potentially devastate tax representation firms;  the real victims of these regulatory changes are the people that the Regulators are trying to protect the most – Taxpayers!

Any legitimate tax representative can attest there are countless cases in any given week where a Tax Payer has been wronged by IRS or state audit or collection departments.  The tax agencies are law unto themselves:  sometimes their actions are motivated by malice…other times by government incompetence.

I like to think that illegal levies or seizures occur due to simple oversights.  Even if this is so, we regularly have fight tooth and nail to overturn these governmental errors and to insure that our clients can continue to have a roof over their head and feed their children.

There is no other instance where, when charged by the government with some form of wrong doing…whether civil or criminal…that a US citizen is denied the right to representation.  In fact, due process of law is an idea so fundamental to the heart of our nation that our Founders consecrated it in the Fifth Amendment of the Constitution and in the Bill of Rights – right along with our other fundamental rights, like speech, religion, and privacy.

We have had some bad players in the tax representation industry;  we are, however, highly regulated.  The behavior of a few bad apples is not reflective of the vast majority of competent

providers of tax representation services in the country.  Yet a violation of a citizen’s right to due process is exactly what could happen if the Consumer Financial Protection Bureau goes forward with the proposed enforcement of the Dodd-Frank Act against the tax representation industry.

The title of this regulatory agency Consumer Financial Protection Board is a misnomer;  it should more aptly be named the Government Protection Board.  It is protecting the interests of the Government and not the consumer – a flagrant conflict of interest. The Government is using an over-reaching regulatory agency to eliminate or render impotent the Taxpayer’s right to representation.

Dana M. Ronald

Tax Crisis Institute

June 1, 2012