While I appreciate the need to increase the licensing fees and the application fees, the proposal calls for a 133% increase to be effective this year. As a public entity, our FY budget for 2019 - 2020 will end 06/30/2020 and the FY budget for 2020 - 2021 is well on its way to being completed. The impact on my office will be an additional $4,500 for the licensing renewals alone. We have managed to struggle with our limited training budgets by finding creative and budget conscious options secondary to the cost of attending conferences to ensure that our licensees are able to comply with the continuing education requirements. Some counties don't even have training funds available. Coming up with the proposed increase will present a burden for the counties that we will need to bare for the future, but coming up with the proposed increase with this short notice in the current fiscal budget is a burden that the counties will need to struggle with immediately.
Thank you for your consideration.

Peter Q. Santini, Pima County Public Fiduciary License #20199

I agree and understand that fees associated with initial licensure and renewals may need to be increased. However, an effective date further in the future is necessary to allow public offices, such as mine, to work it into a future budget. I believe the proposed increase is unreasonably large. I am worried it may affect the ability of our office to retain the number of licensed individuals we currently have or adversely affect other vital parts of our budget, such as training.
I will have expectations of AOC staff as these increases become effective. I would expect the exam, which is grossly outdated to be updated and the processing time of initial licensure and renewals to be expedited.
Thank you for your time.

Crystal K. Rose Cillitto
Pima County Public Fiduciary Supervisor
License #20793

The biggest issue this proposed change presents is the combination of the amount the fees are being raised and the immediate application of the proposed rules. Long term most larger entities will be able to recover but smaller business and public fiduciaries will immediately struggle adjusting to this so that they can maintain a licensed staff appropriate for their case load. Ultimately theses changes will discourage new licensed fiduciaries and new fiduciary businesses from becoming established at least in immediate terms.

-Pablo Valencia, License #20858

The issue here is most public fiduciary offices work on a strict budget and the budget is needed to pay for license renewals as well as other expenditures. In my office, we have more than 18 licensed fiduciaries. This increase does not allow all of us to attend AFA and NGA conferences so we can obtain our CEUs. This increase is going to happen regardless of input but I hope the funds collected goes to updating the overly outdated Fiduciary Exam.
- Darren Joe, Lic. No. 20792

While I appreciate the need to increase fees the suddenness and the amount of the increase is an extreme burden on the public fiduciaries. Public fiduciary offices are budget driven and our budget which is tax payer funded is virtually exhausted.

In the event the fee increase is approved I would request some consideration be given to public fiduciaries being exempted from the increased fees until 2022.

The recent notification by the Certification and Licensing Division regarding its proposed increase to fiduciary fees has the potential to cause significant hardship to our public fiduciaries. As a result of operating on a fiscal year, the county’s budget for expenses incurred through June 2020 was finalized in 2019. For my department this change would create an unanticipated expense of more than $8000. The proposed increase is staggering and difficult to absorb without planning.

I appreciate the potential need for a future increase given the rising costs and lack of previous increases. However, such a significant increase on short notice leaves little opportunity for licensees and departments to prepare and absorb the adjustments. Understandably, other licensed professions seem to have higher renewals. Though that may be the case, some of those professions also provide on-going training, resources and other services to its members. As an example attorney dues provide for monthly articles, on-going webinars (albeit not all free), and resources such as a hotline for attorney inquiries.

If the situation permits, it may be helpful to allow the profession to engage in a dialogue regarding increases and resources. If fee discussions could be tabled momentarily, fiduciaries could pay the amount anticipated for this year’s dues and engage in a dialogue with our licensing division regarding alternatives such as incremental increases, increased training or collaboration with our licensing division included in the fees, or at a minimum time to plan and budget for increases. It seems likely the licensees of our profession would welcome the opportunity engage in an effort to keep costs low, while ensuring our licensing board has the resources needed to conduct its affairs as well.

Thank you for the opportunity to comment.
Sincerely,
Maricopa County Public Fiduciary Lina G. Garcia #20911