An Overview of CPA
Firm Mobility
Gary McIntosh
AICPA Co-Chair, Uniform Accountancy Act Committee
September 9, 2014
American Institute of CPAs ®
Mobility: A Short History
Prior to the Profession’s Individual CPA Campaign,
CPAs often had to hold multiple reciprocal state
licenses
Bureaucratic Compliance Nightmare
Inconsistent Standards Across the States
American Institute of CPAs ®
Mobility: A Short History
Approximately a decade ago, profession leaders
joined together to try to resolve the problem
Idea launched to treat a CPA license like a driver’s
license – portable across state lines
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Mobility
Basic concept
• No notice
• No fee
• No escape (strong protections)
American Institute of CPAs ®
Mobility
Additionally, a CPA license, like a driver’s license,
must be predicated on substantial equivalency
• A CPA = a CPA = a CPA
• 150 hours of education, CPA Exam passed, 1 year of
experience
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Uniform Accountancy Act
Individual CPA Mobility Language was inserted into
the Uniform Accountancy Act (UAA) in 2006
• UAA is the profession’s model state act
• Written jointly by AICPA and NASBA
• States then model their accountancy statutes off of the UAA
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Mobility
The original plan allowed full individual and CPA
firm mobility
• Concerns arose, however, about how the new concept would
work in practice
• Untested
• Particular interest in being cautious about the attest function
Final 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 resolved
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The Campaign Begins
A True Partnership of the Entire Profession
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State CPA Societies
State Boards of Accountancy
AICPA
NASBA
CPA Firms and individual CPAs
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Today the Individual CPA Campaign is
nearing its end…
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Mobility
Only 3 Jurisdictions Remain
• Hawaii (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)
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Mobility
Additionally, AICPA and NASBA have established
resources for CPA Firms and Individual CPAs
• CPAMobility.org
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An Incredible Success Story
Statutes modernized to reflect actual way CPAs
practice around the country
No complaints about enforcement by state BOAs
Bureaucratic red tape and fees that don’t serve
public interest eliminated
Envy of other professions
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Mobility
Nonetheless, some minor implementation issues
remain
Some states still have a few state-specific
provisions (ex. casinos, ag audits)
Massachusetts and Georgia have “quid pro quo”
provisions
American Institute of CPAs ®
Firm Mobility
Profession now revisiting CPA Firm Mobility for
attest
Completion of a promise made in 2006
Timely after successful history with individual
mobility
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Uniform Accountancy Act Initiative on CPA
Firm Mobility for Attest
Multi-year project
Exposure draft with 90 day comment period
Approximately 3 dozen comment letters received
Language approved Spring 2014 by AICPA and
NASBA
States being asked to look at the new language
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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 firms
American Institute of CPAs ®
Firm Mobility: Public Protections
To be eligible, must comply with peer review and
CPA ownership requirements of mobility state
If not in compliance, then must seek to register as
an ‘out-of-state’ firm
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Firm Mobility
14 states already have CPA firm mobility and it
appears to be working well
States like OH and VA have had firm mobility for
over a decade
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Firm Mobility
This new language will not be a concerted
campaign.
Commitment not to push like with individual CPA
mobility
Reasons:
• Individual CPA mobility is too new in some states
• Other pressing state issues needing to take precedent
• Boards and societies need to review the concept, discuss with
stakeholders and members, consider if appropriate
American Institute of CPAs ®
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 past
• Need to educate, discuss, and develop a comfort level among
our partners
American Institute of CPAs ®
Firm Mobility
Lessons from the UAA Comment Period on the CPA
Firm Mobility Language
• State Societies and CPA Firms all broadly supportive
• State BOAs mixed, some strongly supportive, others opposed or
had questions or concerns
• States BOAs with CPA firm mobility already in place often
proved to be the most supportive of other states joining them
American Institute of CPAs ®
Firm Mobility
Common Concerns That Needed to be Examined
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Understanding 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 Fees
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Questions?
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