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Equal Tech Solutions
Anonymized client engagement

How a 28-person CPA firm passed FTC Safeguards review and ended tax-season slowdowns

Accounting & CPA firm2025

28-person CPA firm · single office · Knoxville, TN

Result 01
Passed
FTC Safeguards review
Result 02
~60% faster
Tax-season app-launch speed
Result 03
0
Unplanned outages during peak season

The challenge

Where they started.

FTC §314.4 required a Written Information Security Plan and a named Qualified Individual — they had neither. RDS server choking during tax season meant 30–60 second app launches in CCH Axcess for staff. Seasonal preparers from prior years still had VPN access nobody had revoked.

Specific pain points

  • FTC Safeguards Rule effective date passed; no WISP or IR plan documented
  • Tax-season RDS performance degraded 30–60s app launches in CCH Axcess
  • Seasonal preparer accounts from past years still active with VPN access
  • Client tax docs transiting through email attachments and personal Dropbox accounts
  • MFA on partner accounts only; rest of the firm was username + password

The approach

What we did.

WISP and IR plan delivered first to clear regulatory urgency, then tax-software workloads were re-platformed for elastic scaling. Identity hardening was sequenced to land before January 31 so the firm hit tax season with a clean baseline.

What we delivered

  • Written Information Security Plan + Incident Response plan (FTC §314.4 / IRS Pub 4557 aligned)
  • Named Qualified Individual (vCISO arrangement) for ongoing oversight
  • Windows 365 environment for CCH Axcess, sized for tax-season peak
  • TaxDome client portal replacing email attachment workflows
  • Phishing-resistant MFA enforced firm-wide via Authenticator number-match
  • Seasonal preparer accounts now provisioned with hard-coded April 16 expiration
  • Quarterly identity audit cadence with documented offboarding workflow

The outcomes

What changed.

First tax season after the engagement ran without a single performance complaint. Safeguards review passed first time. April 17 onboarding fire drill — perennially the worst day of their year — simply didn't happen.

  • Passed first attempt
    FTC Safeguards Rule review
  • 45s → 18s
    CCH Axcess average launch time
  • 0
    Unplanned tax-season outages
  • 100% workforce
    MFA coverage
  • Auto-expires April 16
    Seasonal account offboarding
Tax season used to be when our IT broke. Now it's when our IT shows up and saves us. The Safeguards binder was the bonus.
Managing Partner, mid-size CPA firm

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