Common Concerns During the Comment Period Debbie Lambert Uniform Accountancy Act Committee September 9 2014 Overview Approximately 3 dozen comment letters received State Boards State CPA Societies ID: 485836
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CPA Firm Mobility Common Concerns During the Comment Period
Debbie LambertUniform Accountancy Act Committee
September 9, 2014Slide2
Overview
Approximately 3 dozen comment letters receivedState Boards
State
CPA Societies
CPA FirmsSlide3
Broad range of somewhat complex issues
Letter from UAA Co-chairs dated May 20, 2014 summarized issues and how the UAA Committee
addressed
them Slide4
5 Common Themes
Potential insufficient information without registration/notificationQuestions about
enforcement
Inconsistency between states (e.g. compilations
)
Concerns about insufficient information or study of the
issue
Understanding the peer review protectionsSlide5
Potential insufficient information without registration/notification
Concern of some State Boards“Would they have sufficient information to regulate out-of-state firms if there is no registration/notification requirement
?”
No knowledge until a complaint is logged
Consistent with individual CPA mobilityEven with firm registration, complaints drive investigations of potential
wrongdoing
Similar concerns when individual mobility was introduced
Subsequently issues have not emergedSlide6
Potential insufficient information without registration/notification
NASBA’s Accountancy Licensee Database (ALD)Alerts Boards to the
disciplinary
history of
CPAs
This database could
potentially be
expanded
to
include information
regarding firm discipline
No state that has firm mobility commented that they had insufficient info to fulfill their responsibilities and several wrote in support of the change to the UAA Slide7
Questions about enforcement
Two pronged concern:Question of enforcement powers over an out-of-state firm that comes into jurisdictionWhat if the out-of-state firm’s home Board of Accountancy might not have the same support and oversight
capacity
Currently in place:
UAA
Section 23(a)(3): A Board can take any action against an out-of-state firm that it can take against its own licensees, short of revoking the
out-of-state
firm’s
license
A Board can bar a firm from practicing within their
jurisdiction with or without CPA firm mobilitySlide8
Questions about enforcement
Enforcement powers will not be harmed by passage of
CPA firm mobility
NASBA
has offered to
assist
Boards with
resources
when constraints
impact
their ability to enforce mobility laws and
regulationsSlide9
Inconsistency between states Issue raised by Texas Board and Texas Society: Under Texas definition of attest compilations must be performed by a CPA
firmCompilations fall under the definition of attest in other states as well – but not under the UAA
UAA Sections 7(a)(2) and
Section
23(a)(3) address
the
issue
sufficiently
A mobility jurisdiction is able to enforce its
definition
of “attest” requirements for out-of-state firms just as it would for
in-state firmsSlide10
Inconsistency between states Will require unique tailoring of the UAA language to conform to the specific statutes in certain
jurisdictionsPotential expansion of
CPAmobility.orgSlide11
Concerns about insufficient information or study of the issue
Some commenters – insufficient information/study on the issue of firm mobilityHowever:
Several states have had
firm
mobility in place well
over
a decade and have
not
found barriers to
regulating
and protection the publicSlide12
Understanding the Peer Review Protections
(Covered in a separate presentation by AICPA Vice President, Jim Brackens)Slide13
CPA Mobility and Board Revenue Streams
(To be covered in a separate presentation by AICPA Senior Manager, Suzanne Jolicoeur)Slide14
Questions?