SSB 3135 (LSB 5185XC (4) 86)

SENATE FILE _____

BY  (PROPOSED COMMITTEE ON STATE GOVERNMENT BILL BY CHAIRPERSON DANIELSON)

A BILL FOR

An Act requiring the professional licensure of tax consultants and tax preparers, and making penalties applicable. 
BE IT ENACTED BY THE GENERAL ASSEMBLY OF THE STATE OF IOWA:

    Section 1.  Section 542.3, subsection 11, Code 2016, is amended to read as follows:
   11.  “License” means a certificate issued under section 542.6 or 542.19, a permit issued under section 542.7, or a license issued under section 542.8 or 542.33; or a certificate, permit, or license issued under corresponding prior law.
    Sec. 2.  Section 542.3, Code 2016, is amended by adding the following new subsections:
   NEW SUBSECTION.  13A.  “Licensed tax consultant” means a person who is licensed under this chapter to prepare, advise, or assist in the preparation of income tax returns for another and for valuable consideration.
   NEW SUBSECTION.  13B.  “Licensed tax preparer” means a person who is licensed under this chapter to prepare, advise, or assist in the preparation of income tax returns for another and for valuable consideration while under the supervision of a licensed tax consultant, attorney at law, certified public accountant, licensed public accounting firm, or certified public accounting firm.
    Sec. 3.  Section 542.4, subsection 9, paragraphs d, g, h, j, k, and r, Code 2016, are amended to read as follows:
   d.  Rules specifying the educational and experience qualifications required for the issuance of a license under section sections 542.8 and 542.33 and the continuing professional education required for renewal of a license under section sections 542.8 and 542.39.
   g.  Rules relating to actions discreditable to the practice as a certified public accountant, or licensed public accountant, licensed tax consultant, or licensed tax preparer.
   h.  Rules relating to professional confidences between a certified public accountant, or licensed public accountant, licensed tax consultant, or licensed tax preparer and a client.
   j.  Rules governing the failure to disclose a material fact known to the certified public accountant, or licensed public accountant, licensed tax consultant, or licensed tax preparer.
   k.  Rules relating to a material misstatement known to the certified public accountant, or licensed public accountant, licensed tax consultant, or licensed tax preparer.
   r.  Rules on substantial equivalency under section sections 542.19 and 542.35.
    Sec. 4.  Section 542.4, subsection 9, Code 2016, is amended by adding the following new paragraph:
   NEW PARAGRAPH.  0q.  Rules governing the manner and circumstances of use of the titles “licensed tax consultant” and “licensed tax preparer”.
    Sec. 5.  Section 542.14, subsections 1 and 2, Code 2016, are amended to read as follows:
   1.  If, as a result of an investigation under section 542.11 or otherwise, the board believes that a person or firm has engaged, or is about to engage, in an act or practice which constitutes or will constitute a violation of section 542.13, or 542.20, or 542.45, the board may make application to the district court for an order enjoining such act or practice. Upon a showing by the board that such person or firm has engaged, or is about to engage, in any such act or practice, an injunction, restraining order, or other order as may be appropriate shall be granted by the court.
   2.  In addition to a criminal penalty provided for in section 542.15, the board may issue an order to require compliance with section 542.13, or 542.20, or 542.45 or to revoke a practice privilege under section 542.20, and may impose a civil penalty not to exceed one thousand dollars for each offense upon a person who is not a licensee under this chapter and who engages in conduct prohibited by section 542.13, or 542.20, or 542.45. Each day of a continued violation constitutes a separate offense. The board may impose a penalty up to ten thousand dollars per violation against a firm that violates section 542.13, or 542.20, or 542.45.
    Sec. 6.  Section 542.15, subsection 1, Code 2016, is amended to read as follows:
   1.  A person who violates a provision of section 542.13 or 542.45 is guilty of a serious misdemeanor.
    Sec. 7.  NEW SECTION.  542.31  Licensed tax consultants and tax preparers —— exceptions.
   1.  A person shall not engage in the practice of preparing, advising, or assisting in the preparation of income tax returns for another and for valuable consideration in the state unless the person is a licensed tax consultant or a licensed tax preparer as provided in this chapter, except as permitted by subsection 2.
   2.  The provisions of sections 542.32 to 542.46, relating to the licensure of tax consultants and tax preparers, do not apply to the following individuals:
   a.  A full-time or part-time employee hired to fill a permanent position, who in connection with the duties as an employee has the incidental duty of preparing income tax returns for the business of the employer only.
   b.  An attorney at law rendering services in the performance of the duties of an attorney at law. 
   c.  While acting as such, a fiduciary, or the regular employees thereof, acting on behalf of the fiduciary estate, testator, trustor, or grantor, or the beneficiaries thereof. 
   d.  A certified public accountant issued a certificate issued under section 542.6, a licensed public accountant or licensed public accounting firm issued a license or permit under section 542.8, or a certified public accounting firm issued a permit under section 542.7. 
   e.  An employee of a certified public accountant, licensed public accountant, licensed public accounting firm, or certified public accounting firm described in paragraph “d”. 
   f.  A person employed by a local, state, or federal government agency but only in performance of official duties.
    Sec. 8.  NEW SECTION.  542.32  Supervision of tax preparer.
   A tax preparer licensed under this chapter may prepare, advise, or assist in the preparation of income tax returns for another only under the supervision of a licensed tax consultant or person described under section 542.31, subsection 2, paragraph “b” or “d”, and subject to such conditions and limitations as the board by rule may impose. 
    Sec. 9.  NEW SECTION.  542.33  Qualifications for licensure as a tax consultant and tax preparer.
   1.  An applicant for a license as a tax consultant or tax preparer must meet all of the following requirements:
   a.  Be eighteen years of age or older. 
   b.  Possess a high school diploma or have passed an equivalency examination. 
   c.  Present evidence satisfactory to the board that the applicant has successfully completed at least eighty hours in basic income tax law, theory, and practice at a school training session or educational institution approved by the board.
   d.  Possess a preparer tax identification number issued by the internal revenue service. 
   2.  In addition to the requirements of subsection 1, an applicant for licensure as a tax preparer must pass an examination to the satisfaction of the board. The examination shall be constructed in a manner that in the judgment of the board measures the applicant’s knowledge of federal and Iowa income tax law, theory, and practice.
   3.  In addition to the requirements of subsection 1, an applicant for licensure as a tax consultant must do all of the following:
   a.  Present evidence satisfactory to the board of active employment as a tax preparer or employment in this or another state in a capacity that is, in the judgment of the board, equivalent to that of a tax preparer or tax consultant, for not less than a cumulative total of one thousand one hundred hours during at least two of the last five years. 
   (1)  The board shall consider certification by a tax consultant or person described under section 542.31, subsection 2, paragraph “b” or “d”, that the applicant was employed as a tax preparer under supervision for the period indicated in the certificate to be satisfactory evidence of the applicant’s employment as a tax preparer for the period indicated.
   (2)  If an applicant has worked less than a cumulative total of one thousand one hundred hours in at least two of the last five years, the board may consider the number of hours employed, the number of years employed, the number of tax returns prepared, and whether the work involved contributed directly to the professional competence of the applicant in determining if a tax preparer or tax consultant has met the work experience requirement.
   b.  Pass to the satisfaction of the board an examination that is constructed in a manner that in the judgment of the board measures the applicant’s knowledge of federal and Iowa income tax law, theory, and practice. The examination for licensure as a tax consultant must be of a more complex nature and require higher standards of knowledge of income tax law, theory, and practice than the examination for licensure as a tax preparer. 
   4.  If, in the judgment of the board, an applicant has the combined education and experience to qualify for licensure as a tax consultant or tax preparer, but does not meet or cannot present evidence of strict compliance with the requirements of subsection 1, paragraph “c”, or subsection 3, paragraph “a”, the board may allow some of the applicant’s education or experience to substitute one for the other. However, this subsection does not allow a waiver of, or substitution for, any qualifications needed for licensure as a tax consultant or tax preparer other than those described in subsection 1, paragraph “c”, or subsection 3, paragraph “a”.
    Sec. 10.  NEW SECTION.  542.34  Application for licensure.
   A person seeking licensure as a tax consultant or tax provider shall apply in writing to the board. The board shall approve application forms for licensure. An application shall include or be accompanied by evidence, satisfactory to the board, that the applicant meets the qualifications prescribed in section 542.33. An application shall be accompanied by the examination fee established under this chapter.
    Sec. 11.  NEW SECTION.  542.35  Substantial equivalency, internal revenue service enrollment.
   1.  The board shall issue a license to an applicant as a tax consultant or tax preparer who does all of the following:
   a.  Presents evidence satisfactory to the board that the applicant is licensed as a tax consultant or tax preparer in a state that has requirements for licensure similar to the requirements for licensure in this state. 
   b.  Passes to the satisfaction of the board an examination covering federal and Iowa income tax law, theory, and practice, the provisions of this chapter, and the code of professional conduct prescribed by the board.
   2.  Notwithstanding section 542.33, subsections 1 and 3, but as otherwise provided in this chapter, the board shall license as a tax consultant a person who is, on the date of the application for licensure as a tax consultant, enrolled to practice before the internal revenue service pursuant to 31 C.F.R. pt. 10 if the person has passed to the satisfaction of the board an examination covering federal and Iowa income tax law, theory, and practice, the provisions of this chapter, and the code of professional conduct prescribed by the board. 
   3.  Except as provided in this section, an examination is not required for licensure.
   4.  A person seeking licensure under this section shall apply in writing to the board which application shall be accompanied by the applicable license fees established under this chapter.
    Sec. 12.  NEW SECTION.  542.36  Issuance of licenses.
   1.  The board shall issue a license as a tax consultant or a tax preparer to an applicant who does all of the following: 
   a.  Demonstrates to the satisfaction of the board fitness for licensure.
   b.  Pays to the board an initial license fee as established by the board.
   c.  Demonstrates to the board that the applicant has no disciplinary actions pending before the board.
   2.  A tax consultant or tax preparer shall display the license issued to the person in accordance with rules adopted by the board.
    Sec. 13.  NEW SECTION.  542.37  Registration of sole proprietorships, partnerships, corporations, or other legal entities for the preparation of tax returns. 
   1.  A sole proprietorship, partnership, corporation, or other legal entity, through individuals who are authorized within this state to render income tax preparation services, may engage in the preparation, advisement, or assistance of income tax returns for another and for valuable consideration and represent that the entity is so engaged if the entity does all of the following:
   a.  Registers annually with the board in the manner prescribed by the board.
   b.  Designates and reports in the manner prescribed by the board the authorized individual or individuals who are responsible for the tax return preparation activities and decisions of the entity.
   c.  Complies with the provisions of this chapter and the rules adopted by the board.
   2.  A sole proprietorship, partnership, corporation, or other legal entity shall not be relieved of responsibility for the conduct or acts of its agents, employees, or officers by reason of compliance with subsection 1, and a tax consultant shall not be relieved of responsibility for professional services performed by reason of employment by or relationship with such sole proprietorship, partnership, corporation, or other legal entity.
   3.  A sole proprietorship, partnership, corporation, or other legal entity shall not engage in tax return preparation activities under subsection 1 if any tax consultant, proprietor, partner, principal, officer, director, manager, or shareholder of the entity is any of the following:
   a.  A person whose license as a tax consultant or tax preparer under this chapter is permanently revoked.
   b.  A person to whom the board has refused to issue or renew a license on the basis of dishonest conduct or conduct involving tax preparation.
   c.  A person whose occupational license, permit, or registration has been revoked by another state regulatory agency or the internal revenue service for dishonest conduct or conduct involving tax preparation. 
   4.  For purposes of subsection 3, “shareholder” means any of the following: 
   a.  A person who owns more than ten percent in value of the outstanding stock of the corporation if the corporation is publicly traded, or traded on an established securities market.
   b.  A person who owns any value in outstanding stock of the corporation if the corporation is not publicly traded, or not traded on an established securities market.
    Sec. 14.  NEW SECTION.  542.38  Renewal of license, restoration of lapsed license.
   1.  A tax consultant or tax preparer seeking license renewal shall apply for annual license renewal to the board and pay the fee for license renewal on or before the date prescribed by the board. The application shall be accompanied by evidence satisfactory to the board that the person applying for license renewal has completed the continuing education requirements established under this chapter.
   2.  The board shall provide notice to the tax consultant or tax preparer that the annual renewal application and fee are due at least thirty days before the established annual renewal date. 
   3.  A license that is not renewed within fifteen days after the established annual renewal date shall lapse. 
   4.  The board shall restore a lapsed license upon payment to the board of all unpaid renewal fees and a fee for restoration of a lapsed license and upon proof of compliance with any applicable continuing education requirements.
    Sec. 15.  NEW SECTION.  542.39  Continuing education requirement.
   1.  Except as provided in subsection 2, a person licensed as a tax consultant or tax preparer shall submit evidence satisfactory to the board that the person has completed at least thirty hours of board-approved instruction or seminar in subjects related to income tax preparation for each year that the person is licensed. The tax consultant or tax preparer shall submit evidence satisfactory to the board of compliance with this subsection upon submission of the annual license renewal application. If the board does not receive satisfactory evidence that a tax consultant or tax preparer has completed the continuing education requirement, the board shall not renew the applicant’s license.
   2.  The board shall have the discretion to exempt a tax consultant or tax preparer from the continuing education requirement if the applicant provides evidence satisfactory to the board of an inability to comply because of unusual or extenuating circumstances.
    Sec. 16.  NEW SECTION.  542.40  Inactive status.
   1.  If a tax consultant or tax preparer ceases to engage in the preparation or in advising or assisting in the preparation of income tax returns, the tax consultant or tax preparer may apply to the board to be placed in inactive status. A license in inactive status may be renewed each year upon payment of the license fee established under this chapter. Proof of compliance with the continuing education requirement as provided in section 542.39 need not be presented to the board for the renewal of a license in inactive status. 
   2.  A license in inactive status may be reactivated upon payment of a reactivation fee, as established under this chapter, and upon proof of compliance with such continuing education requirements as may be adopted by the board by rule. 
   3.  The board may revoke or suspend a license in inactive status if conditions exist under which the board would have been authorized to revoke or suspend the license if it were active. 
   4.  A person whose license is inactive shall not act as a tax consultant or tax preparer.
    Sec. 17.  NEW SECTION.  542.41  Fees.
   The board, by rule, may establish and charge fees for the following:
   1.  The application for examination for a tax consultant license.
   2.  The application for examination for a tax preparer license.
   3.  The issuance or renewal of a tax consultant license.
   4.  The issuance or renewal of a tax preparer license.
   5.  The issuance or renewal of an inactive tax consultant license. 
   6.  The issuance or renewal of an inactive tax preparer license.
   7.  The reactivation of an inactive tax consultant or tax preparer license.
   8.  The restoration of a lapsed license. 
   9.  The issuance or replacement of a duplicate license. 
   10.  The registration or registration renewal for a sole proprietorship, partnership, corporation, or other legal entity.
   11.  The issuance or renewal of a tax consultant or tax preparer license combined with the registration for a sole proprietorship, partnership, corporation, or other legal entity. Eligibility for a combined license shall be determined by rules adopted by the board. 
    Sec. 18.  NEW SECTION.  542.42  Tax consultant records.
   1.  Except as provided in this section, a person licensed as a tax consultant shall keep records of all income tax returns prepared by the person, or in the preparation of which advice or assistance has been provided. The records of the returns shall be kept for a period of not less than four years after the date of the preparation, advice, or assistance. 
   2.  If a tax consultant is employed by another tax consultant, the records shall be kept by the employing tax consultant. 
   3.  If a tax consultant who has been designated as responsible for the tax return preparation activities and decisions of a partnership, corporation, or other legal entity ceases to be connected with the entity, the records shall be retained by the entity. 
    Sec. 19.  NEW SECTION.  542.43  Appointment of secretary of state as agent.
   Application for a license under section 542.34 by a person or entity not a resident of this state constitutes appointment of the secretary of state as the applicant’s agent upon whom process may be served in any action or proceeding against the applicant arising out of a transaction or operation connected with or incidental to services performed by the applicant while a licensee within this state. 
    Sec. 20.  NEW SECTION.  542.44  Continuing authority of board.
   The lapsing, suspension, or revocation of a license by operation of law, order of the board, decision of a court of law, or voluntary surrender by a licensee shall not deprive the board of jurisdiction to proceed with any investigation of or any action or disciplinary proceeding against the licensee, or to revise or render null and void an order suspending or revoking the license. 
    Sec. 21.  NEW SECTION.  542.45  Prohibited acts.
   Except as otherwise provided in this chapter, a person shall not do any of the following:
   1.  Prepare, advise, or assist in the preparation of income tax returns for another and for valuable consideration or represent that the person is so engaged if the person is not licensed as a tax consultant or tax preparer.
   2.  Assume or use the title or designation of “tax consultant” or “tax preparer” if the person is not licensed as a tax consultant or tax preparer.
   3.  Obtain or attempt to obtain a license as a tax consultant or a tax preparer by any fraudulent representation.
   4.  Represent that the person is licensed as a tax consultant or tax preparer if the person is not so licensed. 
   5.  Present or attempt to use the license of another person.
   6.  Attempt to use a suspended, lapsed, or revoked license.
   7.  Falsely impersonate a person licensed as a tax consultant or tax preparer.
   8.  Engage in dishonesty, fraud, or deception relating to the preparation of income tax returns. 
    Sec. 22.  NEW SECTION.  542.46  Grounds for disciplinary action.
   After notice and hearing, the board may revoke, suspend for a period of time not to exceed two years, or refuse to renew a license; reprimand, censure, or limit the scope of practice of any licensee; impose an administrative penalty not to exceed one thousand dollars per violation against an individual licensee or ten thousand dollars per violation against a registered legal entity; require remedial actions; or place a licensee on probation; all with or without terms, conditions, and in combinations of remedies, for any one or more of the following reasons: 
   1.  Violation of section 542.31, subsection 1, or section 542.32 or 542.45.
   2.  Failure to keep records pursuant to section 542.42.
   3.  Negligence or incompetence while working in the capacity as a tax consultant or tax preparer in another state or the federal government.
   4.  Conduct resulting in a conviction of a felony under the laws of any state or of the United States. 
   5.  Conviction of any crime, an essential element of which is dishonesty, fraud, or deception, under the laws of any state or the United States.
   6.  Conviction of any crime related to the tax laws of any state or the United States.
   7.  Failure to comply with the continuing education requirement under section 542.39, unless such requirements have been waived by the board.
   8.  Failure to pay any administrative penalty incurred within the time determined by the board. 
   9.  Cancellation, revocation, suspension, voluntary surrender, or refusal to renew the authority to practice as a certified public accountant, licensed public accountant, accounting practitioner, licensed tax consultant, or licensed tax preparer, by any other state or foreign authority for any cause other than the failure to pay appropriate fees.
EXPLANATION
The inclusion of this explanation does not constitute agreement with

the explanation’s substance by the members of the general assembly.
   PRACTICE ACT. This bill requires the Iowa accountancy examining board to license all persons who wish to practice as tax consultants or tax preparers. 
   DEFINITIONS. The bill defines a “tax consultant” to mean a person who is licensed to prepare, advise, or assist in the preparation of income tax returns for another and for valuable consideration. The bill defines a “tax preparer” as a person who is licensed to prepare, advise, or assist in the preparation of income tax returns for another and for valuable consideration under the supervision of a tax consultant or other authorized person.
   AMENDMENTS. The bill amends several paragraphs in Code section 542.4(9), as well as adds a new paragraph, to provide the Iowa accountancy examining board with authority to regulate the tax consultant and tax preparer professions. The bill also amends Code sections 542.14 and 542.15 to subject tax consultant and tax preparer licensees to the same penalties as the other public accounting professions regulated in Code chapter 542.
   PRACTICE REQUIREMENT AND EXEMPTIONS. The bill prohibits a person from engaging in the practice of income tax return preparation for another and for valuable consideration unless the person is licensed as a tax consultant or tax preparer. The bill exempts the following persons from the bill’s licensing requirements: employees who prepare income tax returns only for the business of the employer, attorneys, fiduciaries acting on behalf of an estate, other individuals or firms licensed under Code chapter 542, employees of other individuals or firms licensed under Code chapter 542, and government employees.
   SUPERVISION OF TAX PREPARERS. The bill requires tax preparers to work under the supervision of licensed tax consultants or other authorized individuals. 
   QUALIFICATIONS FOR LICENSURE. The bill requires an applicant for a tax consultant or tax preparer license to be at least 18 years of age, possess a high school diploma, complete at least 80 hours of relevant training or education, possess an internal revenue service preparer tax identification number, and pass an examination. An applicant for a tax consultant license must also demonstrate employment in a relevant profession for no less than 1,100 total hours during at least two of the last five years. The board may consider other relevant factors if an applicant has less than 1,100 total hours. The board may also substitute an applicant’s education and work experience if the applicant does not meet these exact requirements. 
   APPLICATION. The bill requires an applicant for licensure to apply in writing to the board. The applicant must include evidence that the applicant meets the qualifications for licensure, as well as the examination fee. 
   SUBSTANTIAL EQUIVALENCY. The bill requires the board to issue a license to an applicant who is licensed as a tax consultant or tax preparer in another state with similar licensure qualifications and passes an examination. The bill also requires the board to issue a license to an applicant who is enrolled to practice before the internal revenue service pursuant to 31 C.F.R. pt. 10 and passes an examination. 
   ISSUANCE OF LICENSES. The bill requires the board to issue a license to an applicant who demonstrates fitness for licensure, pays the initial license fee, and has no pending disciplinary actions before the board. 
   REGISTRATION OF LEGAL ENTITIES PREPARING TAX RETURNS. The bill requires a sole proprietorship, partnership, corporation, or other legal entity engaged in the practice of income tax return preparation to register annually with the board. Such a legal entity must also report the individuals responsible for the tax preparation activities to the board. The legal entity is prohibited from engaging in income tax return preparation activities if any employee, officer, or shareholder of the legal entity has had their license as a tax consultant or tax preparer revoked, or has been refused a license or renewal because of dishonest conduct or conduct involving tax preparation in this state, another state, or by the internal revenue service. 
   RENEWAL AND RESTORATION OF LAPSED LICENSE. The bill requires a licensee to apply for annual license renewal, with proof of compliance with the continuing education requirement. The board shall provide notice of the renewal requirement to the licensee at least 30 days in advance. A license lapses if it is not renewed within 15 days of the annual renewal date. The board shall restore a lapsed license after payment of all fees and proof of compliance with the continuing education requirement.
   CONTINUING EDUCATION REQUIREMENT. The bill requires a licensee to complete 30 hours of continuing education annually but provides for waiver of the requirement because of unusual or extenuating circumstances. 
   LICENSES IN INACTIVE STATUS. The bill permits a license to apply to be placed in inactive status if the licensee ceases to engage in the profession, which may be reactivated upon payment of a fee and proof of compliance with the continuing education requirement. The board may revoke or suspend a license in inactive status.
   FEES. The bill authorizes the board to establish fees for examinations, the issuance, renewal, reactivation, restoration, and replacement of a license, the registration of legal entities, and the issuance or renewal of a license combined with the registration of a legal entity.
   RECORDKEEPING. The bill requires tax consultants to keep a record of each income tax return prepared or worked on by the licensee for at least four years after the preparation.
   SECRETARY OF STATE AS AGENT. The bill requires the secretary of state to be appointed as the agent for a nonresident license applicant for any action arising out of the applicant’s services while licensed in the state. 
   CONTINUING AUTHORITY OF BOARD. The bill provides the board with continuing authority to regulate a licensee whose license has lapsed or is suspended, revoked, or surrendered. 
   PROHIBITIONS. The bill prohibits a person from doing the following: engaging in the preparation of income tax returns without a license, using the title of “tax consultant” or “tax preparer” without a license, obtaining or attempting to obtain a license by any fraudulent misrepresentation, representing that the person is licensed if the person is not, using or attempting to use the license of another person, attempting to use a suspended, lapsed, or revoked license, falsely impersonating a licensed person, and engaging in dishonesty, fraud, or deception in the preparation of income tax returns. A violation is a serious misdemeanor. A serious misdemeanor is punishable by confinement for no more than one year and a fine of at least $315 but not more than $1,875.
   GROUNDS FOR DISCIPLINARY ACTION. The bill authorizes the board to take disciplinary action for the following reasons: violating Code section 542.32, 542.39, 542.42, or 542.45; negligence or incompetence as a tax consultant or tax preparer in another state; being convicted of a felony, a crime with the element of dishonesty, fraud, or deception, or a crime related to tax law; failure to pay an administrative penalty; or losing a license issued by another state or foreign authority for any reason besides failing to pay fees. The board may take the following disciplinary actions after notice and hearing: revoke, suspend for up to two years, or refuse to renew a license, reprimand, censure, place on probation, or limit the scope of practice of a licensee, take remedial action, and impose an administrative penalty of up to $1,000 per violation against an individual licensee or up to $10,000 per violation against a registered legal entity.