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Busy bill format for Supervision

good afternoon everyone and thanks for joining us for a tax practitioner board webinar my name is julie shaw and i'll be hosting today's session now we've created this webinar to connect directly with you we value your opinion and today's an opportunity for you to raise any questions you have directly with us following the webinar today we will provide you with a copy of today's presentation and some useful hyperlinks and we'll send these to you via the email address that you used to register for today's session you can also access them by visiting our webinars resources hub on our website at tpb.gov dot a u forward slash webinar dash hub i'd also like to remind you that today's webinar will count towards your continuing professional education and you can claim one hour for attending however just note that we do not issue attendance certificates now let's look at what we'll cover today in today's webinar we'll help you understand the sufficient number requirement under the tax agent services act 2009 or taser for short we'll also look at relevant considerations to determine if adequate supervision and control exist in your practice now this will include where you might have remote supervision arrangements in place and also if you provide supervision for one or more related or unrelated entities we've included some scenarios and case studies in the presentation and they'll help you better understand the context of the sufficient number and supervisory arrangement requirements and then finally to finish up today we'll answer some of the common questions we do receive during the webinar so make sure you submit those questions to us by the chat box today so before we begin today's presentation i'd just like to conduct a quick poll um so that we can just get a feel for who's in the audience with us and in what capacity you're joining us uh today so the poll will just pop up on your screen in a moment and all we want you to do is provide an answer to the question and the question is what type of tax practitioner are you and we have three options for you the first one is supervising tax agent the second is tax practitioner under supervision and the other option we have is other so just launch that for you now and i'll give you a moment to put your responses through okay looks like we've got a few responses coming through there okay thank you everyone for putting through your responses there um we will just uh stop that poll and the results that we've got so far are 59 percent of people are supervising tax agents eight percent of you are tax practitioners under supervision and about 38 of you are under the other category okay so now i'd like to welcome our board member craig stevens who will be presenting today's webinar we also have madeleine starvos on the line and she'll be helping out answering some of the questions that come up in the chat box madeleine is one of our policy advisors so she'll be quite capable of responding to any questions you've got coming through today so thank you craig for joining us today i'll hand over to you now to begin the presentation terrific thank you julie thanks very much good afternoon everyone and thank you for joining us as dual indicated we will be discussing factors you should consider to ensure there is a sufficient number of registered individuals to provide adequate supervision and control in your practice you may be aware that we recently finalized our public consultation on the draft information sheet on this topic and are currently considering all the feedback we've received before finalizing the guidance this should be complete in the coming months so keep going on the e news and social media channels for updates and i should say thank you to all those who provided feedback to us on that draft policy today we'll be providing information that will help you understand our approach regarding this important aspect of managing the tax practice having a sufficient number of registered individuals to provide services to a competent standard and to oversee the supervisory arrangements in your practice are mandatory requirements under the tessa these requirements have become particularly important in this pandemic environment with many people working from home as i'm sure many of you are also with the continued advancements in technology remote working arrangements are increasingly becoming the norm including in our tax practitioners businesses so today's webinar will focus on helping you to ensure you're meeting your obligations and have adequate supervision and control in your practice so let's begin firstly i'll have a look at the legislative basis for the sufficient number requirement and the requirement to have adequate supervisory arrangements in your practice so there's a requirement under the tax agent services act of 2009 or tessa which we use for short we'll use through this presentation that all companies and partnerships meet the sufficient number requirement when registering or renewing the registration this requires companies and partnerships to have a sufficient number of registered individual tax practitioners to provide tax agent bas or tax financial advice services to a competent standard and to carry out supervisory arrangements when we say a company or partnership must have a sufficient number of registered individuals to provide services and supervision this means in the case of registration as a tax agent these individuals must be registered tax agents in the case of registration as a bas agent these individuals can include registered bas agents or tax agents and in the case of registration as a tax financial advisor also take into account the relevant requirements of the courts act the registered individuals can include registered tax financial advisors or tax agents so relevant requirements of the corporations act state that a financial services licensee must have adequate resources including financial technological and human available to provide the financial services covered by the license and to carry out supervisory arrangements and they must maintain the competence to provide those services as well as ensuring that its representatives are adequately trained and are competent to provide those financial services additional registered tax agents bas agents and tax financial advisors must ensure the services provided on their behalf are provided competently this includes ensuring that there are a sufficient number of individuals within the practice to carry out supervisory arrangements so sufficient number requirement the purpose of including the sufficient number requirement in the tessa is to ensure a partnership or company practice has sufficient organisational qualifications and experience to provide tax agent bas or tax financial advice services competently i must emphasize here that the sufficient number requirement not just on registration or renewal it's an ongoing registration requirement this means if your company or partnership practice ceases to have a sufficient number of registered individuals the entity will not be eligible to remain registered so you must ensure there is always an adequate number of registered individual tax practitioners in your entity you also have an obligation to notify us when your company or partnership ceases to meet this requirement the tester requires that any changes affecting registration must be notified within 30 days of you becoming aware or when you ought to have become aware of that change excuse me we'll discuss some factors to help you determine if you have sufficient number or a sufficient number of registered individual tax practitioners in your practice shortly before we do let's look at the legislative basis for supervisory arrangements the supervisory arrangements are relevant in the context of the code of professional conduct or code use code for short the civil penalty provisions in the tessa and when considering relevant experience looking at these individually the code of professional conduct so the code sets out the professional and ethical standards required of tax practitioners including the obligations you have to your clients the tpb and in relation to your own conduct in the code 7 a registered tax practitioner must ensure that the tax agent services they provide or that are provided on their behalf are provided competently now when i refer to tax agent services in this context i'm collectively referring to tax bas and tax financial advice services so in the codon 7 you are ultimately accountable for tax agent services provided on your behalf and you need to ensure that those services are provided competently in order to comply with this code obligation you must ensure that adequate supervision and control arrangements are in place services are provided to a competent standard and appropriately appropriate disclosures to clients is provided now in the context of the civil penalty provisions in the tessa having adequate supervision and control arrangements in place is important and relevant for registered tax and bas agents who sign declarations in tax documents or other statements in relation to a tax plan the civil penalty provisions basically prohibit registered tax and bas agents from signing declarations or other statements that have been prepared by an individual who is not either a registered tax aide tax or bas agent or who is not working under the supervision and control of a registered tax or bas agent that supervision comes in there then for relevant experience in the context of relevant insurance supervision and control is relevant and important for individuals who are seeking to register with the tpv as a tax practitioner for the first time the tax agent services regulations of 2009 require that individuals wanting to register with a tbb meet the relevant experience requirements one way individuals can demonstrate that they have the required relevant experience if by working under the supervision and control of a registered tax agent best agent or tax financial advisor for a certain period of time depending on the type of registration they are seeking therefore appropriate supervision and control by a registered tax practitioner is an important part of them gaining that relevant experience right so now that i've given you the legislative background for these requirements let's discuss them in some detail to see how this applies to your practice starting with the the sufficient number requirement when we talk about sufficient number the obvious question the question that arises is how many registered individuals should a company or partnership entity have and it would be easy if there was a set formula to work this out unfortunately there's no such thing as each tax practitioner's circumstances are different and unique to satisfy this requirement though there must be at least one registered individual nominated to provide tax agent services on behalf of the unity and to provide supervision and control within the practice nominated registered individuals individuals for your entity can include individual partners directors employees contractors and staff provided under a service trust arrangement for a partnership or company tax financial advisor in addition to the individuals i've just mentioned the nominated supervisors can also include financial services licensees representatives such as authorised representatives responsible managers compliance officers the line managers so determining the sufficient number i mentioned earlier there must be at least one registered individual for your entity to meet the sufficient number requirement but this does not mean that if you have one registered individual you would automatically meet our requirements as the appropriate number will depend on the circumstances of your individual practice or company so you need to consider a range of factors to determine if your practice has a sufficient number of registered individuals now this is not an exhaustive list but you could consider the following you have adequate financial technological and human resources to provide the tax agent services and provide supervision is the registered individual competent and adequately trained to provide effective supervision and control what is the size and range of services provided within your business this may include considerations such as your business turnover number of clients nature and sophistication of your client base and the number of relevant staff how complex the services you'll be you're providing and supervising how many qualified and experienced staff do you have and how often do they undertake training and development activities what supervisory arrangements do you have in place including quality assurance and control practices and escalation procedures what are your risk management processes and does your entity have a condition imposed on its registration by us so when you nominate a registered individual for your practice make sure you assess their capacity to undertake supervision on behalf of the unity while also providing a competent service to their own client base if they have one and take within that taking into consideration all the factors we've just outlined it is up to you to assess how many registered individuals your practice needs to provide competent services and adequate supervision and you must be able to demonstrate that you satisfy that sufficient number requirement when we request you to do so in addition when appointing registered individuals to provide supervisory services for your practice you must obtain their prior informed written consent now this is an important change in our requirements and will be included in our finalised guidance which will be published shortly on our website now you may think what does prior informed written consent mean it means that you must ensure the nominated individual has considered all the relevant information before agreeing to take on the supervisory role including the nature of the supervisory arrangements in place and the supervision and control to be undertaken the nominated individual must give a written signed statement to you to provide their consent this will ensure that the individual is aware of their appointment as a responsible supervisor and understands the requirements of the role the only exception where the prior informed written consent will not be required is in situations where you have existing documentation that sets out the nature of supervisory arrangements and supervision and control to be undertaken and the nominated individual is aware of and understands the obligations set out in the documentation right so now let me explain the sufficient number requirements a bit more for tax financial advisors through a couple of a couple of scenarios as we recognize they have different business models when compared to tax and best agents businesses this is partly due to the licensing requirements under the corporations act the scenario one australian financial services licensee or afs licensee for short operates under an authorised representative model only that is they have corporate authorised representatives and or individual authorised representatives only and no employee or other representatives all the authorised representatives provide tax financial advice services for a fee and are registered with the tpb so in this scenario the afs licensee will meet the sufficient number of requirements as all their authorised representatives providing tax financial advice services are currently registered with the tpv so the individual authorised representatives and or the registered and individuals of the corporate authorized representatives will form the sufficient number and help meet this requirement there for the afs licensee the afs licensee should not have to register more individuals to assist in meeting the sufficient number of requirements in this case scenario 2 an afs licensee operates under a business model that includes both employee representatives and authorised reps it may be either individual and or corporate authorized reps these authorised representatives provide tax financial advice services for affiliate award and the employee representatives all provide tax financial advice services on behalf of the afs licensee so in this scenario if all the authorised representatives are registered with the cpv that none of the employee representatives are registered and the afe s licensee will not meet the sufficient number requirement because there is no registered individuals within the licensee structure itself so to meet the sufficient number requirement the licensee will have to register individuals from within their structure licensee will need to determine how many individuals should be registered from within their structure to meet this requirement taking into consideration the factors we discussed earlier the licensee can choose to register individuals such as the partners directors employees or employee representatives contractors compliance officers etc of the licensee however these individuals must be competent and capable of providing effective supervision the fact that the authorised representatives are registered with the tpb in this instance is not a relative relevant consideration to determine how many individuals will form the licensees sufficient number right so let's now discuss how to determine if you have adequate supervisory arrangements in your practice the term adequate supervisory arrangements may broadly be considered as arrangements aimed at directing overseeing and checking the services provided on behalf of the company the partnership initiative to ensure those services are provided competently to determine if your practice has sufficient supervisory arrangements we will assess what measures you have taken to provide effective supervision and control for relevant activities ing to your circumstances now we've taken guidance from previous administrative appeals tribunal cases that were decided under the income tax assessment act of 1936 to determine some of this or to provide this guidance these cases established a number of principles on what constitutes a sufficient degree of supervision and control these principles were established in the context of the requirement that an agent have some relevant employment experience before being registered the prohibition of registered tax agents from allowing unregistered entities to prepare statements for a taxpayer required or permitted under a tax floor and conducting business on behalf of the registered agent the above principles are equally applicable to the tassa as we've seen earlier want to spoke about how supervisory arrangements under the tasa are important in the context of relevant experience and civil penalties so what should you consider to determine if there are adequate supervisory arrangements in your practice the level of depth and then the depth and oversight undertaken over the tax agent bas or tax financial advice services being provided in your practice is an important initial consideration really checking a document to see if it seems reasonable is not sufficient it must be substantial supervision this means there must be ample or considerable amount of involvement and not simply checking from time to time while you do not have to necessarily monitor or oversee all work or client interviews done by your staff there must be adequate supervision or oversight provided of course it would this would vary ing to the skills and experience of the staff and the complexity of the services being provided supervision and control must be exercised on the relevant activity completed for a taxpayer that is required or permitted by a tax law such as completing an income tax return or an activity statement must include periodic and spot checks of material prepared by staff importantly you don't have to necessarily have an employer or employee relationship with the person reforming the services to provide adequate supervision [Music] so any additional considerations further you can consider adopting a range of other measures to ensure there is adequate supervision and control before you sign a declaration or statement in a tax document in relation to a tax payer it has been prepared by someone not working under the supervision and control of a registered tax practitioner make sure you check the accuracy of the declaration or statement you assign ensure the staff have adequate level of education and understanding of the relevant tax laws to execute the tasks they are responsible for initial and ongoing training to your staff have documented procedures and processes in place so staff can raise any issues with their supervisor that are beyond their knowledge or if there's been any specific issues or concerns raised by your clients implement quality assurance and quality control mechanisms and conduct regular quality reviews of work undertaken by staff and undertake spot checks for the source documents and questions asked by staff to justify any income and deductions declared so one mechanism that we highly recommend you adopt to ensure you have adequate supervisory supervisory arrangement is to develop a plan setting out the supervisory arrangements the plan should be set out i'll just move that that's move that um forward one if we could thank you so supervisory plan the plan should set out the processes and procedures for supervision covering the considerations we just discussed it should help the nominated supervising tax practitioners to clearly understand what their responsibilities are and that of the staff under the plan and having such a plan should help you establish the supervisory processes for your practice and help you to comply with your obligations under the code it also enables you to have evidence of what you've done if it's ever queried by the tpb now we move on to remote supervisory arrangements let's look at some of the relevant considerations on this topic will matter i'm sure many of you are now used to working and interacting with colleagues remotely thanks to the pandemic environment we're in we're living in at the moment and also due to the technological advancements that have allowed remote working to become so commonplace when we refer to remote supervisory arrangements we are referring arrangements where the supervisor and the staff they supervise in their entity are in different locations we're also referring to situations where the supervisor and the supervised staff are employed by different entities so how do you ensure you have adequate supervisory arrangements when operating under these remote arrangements while it will depend on your particular circumstances the following considerations can be useful what's the frequency of contact and methods of communication between the supervisor and staff is the supervisor available to be contacted by staff at all times can staff access training and research resources while working remotely is there workflow management in place particularly where the supervision and control is being provided by a different entity how will documents be reviewed and feedback provided to the staff do you have systems that will allow reviews to be undertaken remotely is the registered tax practitioner supervising one or several entities so as mentioned earlier again strongly recommend you develop a supervisory plan for remote working arrangements to ensure you have effective supervisory arrangements in place which are well documented and able to ensure you comply with the code we will be satisfied there is adequate remote supervisory arrangement where there is a structured arrangement in place including documented procedures and processes specifically for remote working arrangements where the remote server advisory arrangement is clearly set out in that supervisory plan where there are regular training and check-ins with staff and regular review of documents prepared by staff and where there is clear communication of expectations on how work will be completed and reviewed in a timely manner so holding multiple supervisory roles we acknowledged earlier that a registered registered tax patient may be a nominated supervisor for one or more related or unrelated entities in this situation all the considerations we discussed earlier are relevant in determining if adequate supervisory arrangements are in place in addition you need to also consider the size of each entity for which the individual is the nominated supervisor it can include factors such as the turnover of the business the number of clients a number of relevant staff the market segment of the client base of each entity is important the type and complexity of tax agent bas or tax financial advice services being provided or supervised and other professional duties or responsibilities of the nominated supervisor so in relation to this one i strongly re encourage you to review our guidance once it is finalized and published on our website which will include the scenario in relation to this to help put it into some context context for you so penalties and sanctions consequences for failing to comply if a company a partnership tax practitioner does not have a sufficient number of registered individuals or supervisory arrangements in its practice can breach the tessa so if you find that a tax practitioner has failed to comply with the taser and in this case the code item code 7 item specifically we may impose one or more administrative sanctions or seek a court imposed civil penalty sanctions can include written and formal cautions one or more orders that may require the tax practitioner to do certain things such as completing a course of education or training we might specify limiting the services you may provide appointing additional registered individuals in the practice to provide the supervision and control providing services only under the supervision of another tax tax practitioner it also includes suspension of registration or termination of registration and prohibiting the entity from reapplying for registration for a period of up to five years the severity of that sanction obviously depends on the nature and extent of the breach and the individual circumstances of each case where sanctions are imposed the practitioner the practitioners have a right of review with the administrative appeals tribune that tribunal obviously provides an independent review and may publish its decisions we are also able to apply to the federal court which can pose a penalty for each breach and the maximum penalties can be up to 52 500 for individuals for each breach and for corporates up to 262 500 for each branch so finally i'd like to move on to a case study in relation to having no supervising agent so these these cases involve matters where a lack of sufficient number of registered individuals and adequate supervisory arrangements were brought before the board conduct committee the bcc first case we're going to discuss involves a company tax agent that lodged 96 returns and statements when it did not have any supervising registered tax agent individuals the company declared in his 2019 annual declaration to the tpv that its director was the registered individual providing services on behalf of the company however the director was no longer registered as he had failed to renew his registration the company failed to respond to our enquiries and there was no evidence that another supervising agent had been appointed by the company the company therefore failed to meet the registration requirement of having a sufficient number of individuals to carry out supervisory arrangements and ensure tax agent services were provided competent as part of the review has also found that the company did not comply with its personal tax obligations by filing the lodge's 2018 and 2019 income tax returns when june failing to lodge its annual gst returns for 2017 and 2019 years were in due and failing to pay its tax debts on time the bcc determined that the company breached the code by failing to respond to our inquiries knowingly making a false claim in its annual declaration in relation to the supervising agent and failing to comply with tax laws in its personal affairs on the basis of these findings the bcc terminated the company's registration as a tax agent you see the implications there of not meeting the requirements the next case study in this case the company tax agent had two registered individual tax agents nominated nominated to provide supervision it was found that the company failed to provide competent services and adequate supervision to nearly 3 000 clients in its client base audits by the ato showed the company agent had claimed work-related expense deductions for 13 clients in their 2018 tax returns without appropriate substantiation tax agent also had failed to ensure a business activity statement lodged for a client contained accurate information and the required substantiation before launching it with the atm the agent was found to have failed to apply tax force correctly in making the work-related expense claims and also in claiming rental property deductions the bcc disseminated the outcome of the ato audit showed that the company lacked appropriate supervisory arrangements to ensure competent services were provided to its clients taking into account the nature of the breaches and the mitigating circumstances provided the bcc imposed a written caution on the company an order that the company nominate an additional supervising registered individual tax agent the company and in order that the company's two supervising tax agents complete a course in practice management so that brings us to the end of the formal part of it to finish our webinar today i'll hand over madeline to share some of the questions that have been coming through during the session during the session natalie great thank you okay got quite a few questions here for you and um the first question is during covert 19 i've changed my business structure by increasing the number of employees i have do i need to provide details of their supervising agents yes so assuming a sufficient number requirements um needs have changed so because of the increasing number of employees the the existing number may now not be sufficient then you um need and so you need more registered tax practitioners to supervise employees yes you need to notify us um notifications necessarily need to be submitted in writing within 30 days of you knowing that you need to increase your sufficient number and i think they can be completed uh on a contact form on our website at uh .tpb.gov.edu and i think there's a spot there to select change your registration details great thanks craig the next two questions relate to the supervisory plan that you spoke about earlier in the webinar the first question is what should a supervisory plan include or cover okay a supervisor plan well it has to set out the processes and procedures you have in place to ensure that the tax agent bas agent or tax financial advice services provided are of a competent standard and that there is adequate supervision and control in place so what should include it may cover things such as uh the steps to be taken or processes that are in place to ensure the accuracy of information prepared by an individual in relation to the declaration or statement to be signed by the tax practitioner they include the ongoing training or initial training ongoing training to be provided to staff that are being supervised how staff and what circumstances staff should raise issues with their supervisors that are beyond their knowledge or experience how frequently there are audits of work undertaken or reviews of work undertaken by staff to ensure the level or the standard of work being prepared so those and the review procedures that were utilized and and i think i mentioned spot checks and source documents so when and how frequently they should be undertaken excellent really good advice there um next question is will having a supervisory plan mean that i have adequate supervision and control arrangements in place as i said on the way through we strongly recommend having a supervisory plan in place as it assists you in establishing and getting a clear understanding of the responsibilities of the supervisors and the staff to ensure that there is adequate supervision and control so i strongly recommend that however having that by itself does not necessarily demonstrate that there is adequate supervision and control it's it's a case-by-case basis we would look at the uh the plan in place look at how that works within the practice uh to determine that it is appropriate but having it is certainly a good step in providing us with evidence that you have arrangements in place that meet that requirement excellent um the next question is if a tax practitioner misses a mistake made by an employee who is not a registered tax practitioner will the supervising tax practitioner be penalized for that mistake so in this case the registered tax practitioner is the responsible party so at all times they are responsible for errors made or mistakes made by an employee so that's why the supervision and control we talk about is so important we don't the cpv doesn't require a tax practitioner to check every return we talk about periodic spot checks we talk about the other supervision that you have in place so the having the important thing is to have the appropriate processes in place first so it's one one error wouldn't necessarily get you penalized if you can demonstrate that you have a price appropriate processors in place that's that's that's the important part of it but you do need to understand that the tax practitioner is responsible is the responsible party at the end great thanks for that do clients have the right to expect that any tax advice provided by tax agents practice is prepared by or signed off by a registered tax agent as we've discussed the the registered tax practitioner is the responsible person for the services provider there's no standard process to use when determining adequate supervisory arrangements as it depends on the particular practice or business and they vary from entity to empty so what clients should expect is that there's adequate supervision and control in place being overseen by the by the tax practitioner rather than the tax practitioner has undertaken every step of the process great thanks craig um the next question relates to sufficient supervision and the question is if a tax agent works part-time but still checks the work of a tax practitioner working under them on the days that they're in the office in your view would that constitute sufficient supervision being exercised uh you you would need to consider this on a case-by-case basis and and review the plans and processes in place there are some factors that would indicate that it may be they may be fine the supervision and control needs so it's about supervision control it's not just about physical inspection supervision so we need to consider the processes in place to ensure that they're robust enough that a part-time physical presence or physical supervision is fine so it could be fine but it would depend on the processes and is a case-by-case decision thanks for that um and the final question i have here is in relation to offshore arrangements how do registered tax practitioners having who have work completed for them offshore meet the tpb sufficient supervision requirements yeah it's a topical question so to determine if appropriate supervision has been exercised or if there are appropriate supervisory arrangements in place again we'll require an assessment of the measures taken by the tax practitioner to supervise and control the relevant activities based around their their practice it's still we've still got to go back to the factors we've spoken about today um and have a plan in place on on how they are supervised i believe we published a practice note on this on outsourcing and offshoring which covers the factors that you would need to consider within entering into those arrangements so maybe we can share a link to that um after the webinar today which might assist great thanks craig you're right tom we have um published a practice note in relation to um outsourcing and offshoring of tax services and um i'll shortly um share that in the uh the chat box but i i think julie will also send that around following the webinar um that's all for the questions so i'll hand back to julie to talk about how the practitioners online can stay in touch with us thanks julie thank you so much maddie yeah just to finish up today i'd like to share some information on how everyone can stay in touch so if you'd like more information and to keep up to date with the tpb obviously we've got our website available to you which is full of helpful and useful information and you can find the website at tpb.gov dot a u um you can also follow us on linkedin facebook and twitter we're constantly putting updates on social media platforms there so that's another great way for you to keep up to date we also have a newsletter that goes out each month which is called tpb news you can subscribe to that as well so that you'll be kept up to date each month with all the tv happenings and that subscription page is on our website at tpb.gov dot a u forward slash newsroom um another great way that you can stay in touch with us is to subscribe to our youtube channel and if you do that you will receive notifications when we post any new content so any new videos you'll you'll get an email from us to say yep we've done something new um so we do actually record all of our webinars and we have a comprehensive library of webinars available for you to view at your leisure and they're all on our youtube channel as well and the good news about that is that you can still claim your cpe or cpd for viewing these videos so that's good to know um so just to finish up i would like to thank craig for providing all that useful information to us all today it was great to hear from you craig and thank you to madeleine as well for answering the questions through the chat box that was really helpful too maddie thank you so much for that and also just to everyone for um joining today thank you to chia for coming along and we do hope that you found the webinar beneficial we do think that the webinars are a great way for everyone to keep today and as we have said a couple of times today it does count towards your continuing professional education but also please do remember that we don't issue attendance certificate for people attending the webinars but we will email you just notifying that you have attended today so you can use that as a confirmation of your attendance so if you are interested in attending more of our webinars just again go to our website and you can register for some upcoming events but we've got lists there the um the web address for that is tpb.gov dot a u forward slash webinars and then the last thing today before we do finish i'd like to launch an exit survey and we would really appreciate it if you could take the time to complete it it's very quick it only takes a moment and your feedback is really useful to us because it does help us improve on the webinars and also lets us know of any topic that might be of interest to you so yeah please take the time to do that it will just pop up in your browser once you leave the webinar today so once again thank you for joining us today and we do hope that you stay safe and um we know this is a very challenging time for everyone so we do appreciate that you've taken the time to join us today so thanks again and enjoy the rest of your day stay safe