CPA Firm Mobility


CPA firm mobility allows CPA firms to provide all services (including attest services) across state lines without having to register in each state in which they offer those services. This is an extension of the popular individual mobility initiative that allows individual CPAs to provide services in 52 states and jurisdictions without having to obtain a reciprocal license. 

Just as with individual mobility, firms operate under a “no notice, no fee, no escape” law. While out-of-state firms would not need to provide notice to a state board of accountancy to provide attest services, nor need to register as an out-of-state firm, they would be subject to that board’s rules, regulations, and requirements – including those related to firm ownership and peer review. In this way, CPA firm mobility ensures strong regulatory protections for the public, while eliminating unnecessary compliance costs and fees.

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Full CPA Firm Mobility for Attest Services

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In May 2014, the AICPA and NASBA released the seventh edition of their model state act, the Uniform Accountancy Act, which would allow CPA firms to perform attest services and issue reports in states in which they do not have a physical presence without having to register the firm or paying new fees. In exchange for this privilege, CPA firms would be required to meet the peer review requirements and non-CPA ownership requirements of the state in which they were offering services.

This is an extension of the individual CPA mobility initiative, which has been embraced throughout almost the entire country. Under states’ individual CPA mobility laws, CPAs operating within CPA firms can provide “non-attest” services in states in which they do not have a physical presence, and the provision of these services does not require the firms to register in the new state. (“Non-attest” services include items such as tax advice, financial planning, and consulting services.) CPA firm mobility extends this privilege to attest services (such as audits), while ensuring that the public has the exact same protections as they do under individual mobility. In fact, under CPA firm mobility, state boards of accountancy retain the same authority to investigate, fine, or even revoke a practice privilege as they do under individual mobility laws.

Several states have already moved forward with this concept as part of their earlier debate about passing individual CPA mobility. Fourteen states – almost one-third of the country – do not require eligible out-of-state firms to register or pay fees when providing attest services, and their state boards of accountancy are not reporting any problems in their ability to regulate the profession. 

Fundamentally, CPA firm mobility for attest services is about creating a modern and effective regulatory regime for the accounting profession in the decades to come. It is about creating a level playing field across the states, ensuring public protection without unnecessary paperwork, and recognizing the ways in which CPAs and CPA firms operate in today’s business environment.