Already I have read comments and opinions on the recently released proposed rules for Accounting of Disclosures (AoD) to include on how problematic, burdensome, etc. it will be for covered entities to generate and provide these AoDs to requestors. I haven’t come across too much from the covered entity community that has been very supportive of these rules.
When you combine these proposed rules with the general statement from the covered entity community that the number of requests for AoDs is a very small number, it seems that these proposed rules may need to be recalibrated to reflect the reality on the scale of AoD requests and therefore, the context in which these rules exist.
My word of advice….if you have feedback, concerns, support, or observations on these proposed rules (good or bad)…make use of the comment period. You just may make the difference in what ultimately appears in the final rule.
Frank Ruelas