Gary McIntosh AICPA CoChair Uniform Accountancy Act Committee September 9 2014 Mobility A Short History Prior to the Professions Individual CPA Campaign CPAs often had to hold multiple reciprocal state licenses ID: 702088
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Slide1
An Overview of CPA Firm Mobility
Gary McIntoshAICPA Co-Chair, Uniform Accountancy Act Committee
September 9, 2014Slide2
Mobility: A Short History
Prior to the Profession’s Individual CPA Campaign, CPAs often had to hold multiple reciprocal state licensesBureaucratic Compliance NightmareInconsistent Standards Across the StatesSlide3
Mobility: A Short History
Approximately a decade ago, profession leaders joined together to try to resolve the problemIdea launched to treat a CPA license like a driver’s license – portable across state linesSlide4
Mobility
Basic concept No notice No fee No escape (strong protections)Slide5
Mobility
Additionally, a CPA license, like a driver’s license, must be predicated on substantial equivalencyA CPA = a CPA = a CPA150 hours of education, CPA Exam passed, 1 year of experienceSlide6
Uniform Accountancy Act
Individual CPA Mobility Language was inserted into the Uniform Accountancy Act (UAA) in 2006UAA is the profession’s model state actWritten jointly by AICPA and NASBAStates then model their accountancy statutes off of the UAASlide7
Mobility
The original plan allowed full individual and CPA firm mobilityConcerns arose, however, about how the new concept would work in practiceUntestedParticular interest in being cautious about the attest functionFinal proposal changed to allow individual CPA mobility and CPA firm mobility for non-attest services
Attest services would still require the registration of a CPA firm in any state where attest services are offered, however the firms’
CPAs
could operate without reciprocal
licenses
Additional concerns at the time about peer review, use of firm names, and CPA ownership standards – mostly now resolvedSlide8
The Campaign Begins
A True Partnership of the Entire ProfessionState CPA SocietiesState Boards of AccountancyAICPANASBACPA Firms and individual CPAsSlide9
Today the Individual CPA Campaign is nearing its end…Slide10Slide11
Mobility
Only 3 Jurisdictions RemainHawaii (Discussions occurring regarding a 2015 push)Guam (legislation expected in Summer/Fall 2014)Commonwealth of the Northern Mariana Islands (legislation expected
in Summer/Fall 2014)Slide12
Mobility
Additionally, AICPA and NASBA have established resources for CPA Firms and Individual CPAsCPAMobility.orgSlide13Slide14
An Incredible Success Story
Statutes modernized to reflect actual way CPAs practice around the countryNo complaints about enforcement by state BOAsBureaucratic red tape and fees that don’t serve public interest eliminatedEnvy of other professionsSlide15
Mobility
Nonetheless, some minor implementation issues remainSome states still have a few state-specific provisions (ex. casinos, ag audits)Massachusetts and Georgia have “quid pro quo” provisionsSlide16
Firm Mobility
Profession now revisiting CPA Firm Mobility for attestCompletion of a promise made in 2006Timely after successful history with individual mobilitySlide17
Uniform Accountancy Act Initiative on CPA Firm Mobility for Attest
Multi-year projectExposure draft with 90 day comment periodApproximately 3 dozen comment letters received Language approved Spring 2014 by AICPA and NASBAStates being asked to look at the new languageSlide18
Firm Mobility Model for Attest Services
Same as individual mobility“no notice, no fee, no escape” Already in place for non-attest services
States
will
gain additional explicit authority
to go after unregistered firmsSlide19
Firm Mobility: Public Protections
To be eligible, must comply with peer review and CPA ownership requirements of mobility stateIf not in compliance, then must seek to register as an ‘out-of-state’ firmSlide20
Firm Mobility
14 states already have CPA firm mobility and it appears to be working wellStates like OH and VA have had firm mobility for over a decadeSlide21
Firm Mobility
This new language will not be a concerted campaign.Commitment not to push like with individual CPA mobilityReasons:Individual CPA mobility is too new in some statesOther pressing state issues needing to take precedentBoards and societies need to review the concept, discuss with stakeholders and members, consider if appropriateSlide22
Firm Mobility
What are the biggest obstacles and concerns in regard to CPA Firm Mobility?Same common concerns we heard in regard to individual mobility in the pastNeed to educate, discuss, and develop a comfort level among our partnersSlide23
Firm Mobility
Lessons from the UAA Comment Period on the CPA Firm Mobility Language State Societies and CPA Firms all broadly supportiveState BOAs mixed, some strongly supportive, others opposed or had questions or concernsStates BOAs with CPA firm mobility already in place often proved to be the most supportive of other states joining themSlide24
Firm Mobility
Common Concerns That Needed to be ExaminedUnderstanding the peer review protections Potential Insufficient Information without registration/notification Questions about enforcement
Inconsistency between states (e.g. compilations)
Concerns
about insufficient information or study of the issue.
Potential
Loss of Revenue from Out-of-state Registration FeesSlide25
Questions?