Managed Bookkeeping

Method: jurisdictional applicability review. IRS guidance distinguishes record-organizing bookkeeping from tax preparation, but does not establish general permission for our launch. State-specific accountancy, business registration and reporting conditions remain unverified because no state is selected. Excluding audit opinions, tax filing and custody narrows the review but does not prove lawfulness.

The supplied federal guidance is narrow, and applicable state requirements are unresolved.

Method: operating-design comparison. Our reconciliation, report delivery and support can occur entirely in client-owned online accounting accounts. The comparable states: "Every client’s books are maintained in their own QuickBooks Online account." This supports an online delivery mechanism, assuming clients provide records digitally and our service does not include physical document collection.

The proposed workflow and documented online platform align; actual launch procedures are not supplied.

Method: licensing applicability review. In its bookkeeping scenario, the IRS states: "No, she is not a tax return preparer, and is not required to have a PTIN." This supports a limited federal distinction if we only organize records and avoid substantive tax preparation; excluding filing alone would not suffice. No selected state or applicable accountancy licensing evidence establishes that our reporting role needs no special licence before the first client. External payment processing does not resolve that question.

Federal PTIN guidance does not settle state professional licensing or partner requirements.

Method: recurring-revenue mechanism comparison. The comparable documents monthly bookkeeping plans: "Plans are flat-rate, published, and start at $160 per month with no setup fees and no annual commitment." Our proposed prepaid monthly retainer charges for repeated reconciliation and monthly reporting, with transaction volume determining price. This is an applicable recurring service mechanism, not proof of acquired customers or retention. Our volume-based pricing is distinct from the comparable’s flat-rate pricing.

Monthly delivery and monthly charges are explicit in both the proposal and comparable offering.

Method: proposed money-flow and obligation review, with evidence supporting the bookkeeping delivery mechanism. Our customers prepay service fees through an external operator; we reconcile records rather than advance money, lend or guarantee customer debts. Assuming those stated boundaries remain in contracts and operations, our role does not make us a creditor or guarantor. The comparable’s broader AP/AR services are not attributed to us.

The proposed boundaries are explicit, but contracts and processor terms have not been supplied.

Method: obligation classification. The documented reconciliation and financial-reporting service supports our proposed service category. Our design sells bookkeeping work, not insurance or compensation for insured events, and expressly excludes insuring. Assuming contracts preserve that boundary, we do not accept insurance underwriting risk; ordinary responsibility for service errors is a separate issue.

The service scope is clear, while final contractual obligations remain unverified.

Method: proposed funds-flow review. Our design excludes holding client funds and routes service-fee settlement directly through an external operator. Accounting access is for reconciliation and reporting, not custody or payment execution. The comparable states: "CoCountant is added as a user with role-appropriate permissions." That supports a limited-access accounting workflow, not proof of its funds flow. The pass assumes our permissions and processor arrangement implement the stated non-custodial design.

Non-custody is explicit in our design, but processor arrangements and access controls are not verified.

Method: activity classification. The evidence documents monthly reconciliation and reporting as bookkeeping deliverables, matching our proposed customer job. Our product records transactions rather than executing trades, and the proposed role expressly excludes trading. This conclusion assumes no expansion into investment execution.

The proposed activity is clearly bookkeeping rather than trading.

Method: buyer and function classification. Our proposed buyers are small service businesses purchasing private reconciliation and monthly reports; the evidence documents the same commercial customer category. The design excludes performing a state service and does not base sales on government procurement. This pass assumes the stated private-business customer focus remains the baseline.

The specified buyer and deliverables are commercial, with no government function or procurement dependence in the design.

Method: comparable valuation evidence review. No supplied document establishes a valuation of at least $300 million for CoCountant or another comparable. The comparison’s Bench customer counts and acquisition narrative do not establish transaction value. Carlsquare’s generic valuation multiples cannot establish a comparable’s valuation without company-specific financial and transaction evidence. Missing a verified large comparable is not a failure of the model.

The supplied evidence contains no qualifying company-specific valuation.