The following questions and answers were compiled from questions frequently asked of Board staff. They are unofficial staff applications of Board laws. Please rely on the laws rather than the questions and answers for authoritative guidance. The accountancy law authority consists of the Public Accounting Act (RCW), Board Rules (WAC), and Board policy statements and rulings. To find the answer to your question, select from the topics listed below:

• General
• Attest Services
• CPA-Inactive Certificateholders - How to Apply for a License
• Complaints
• Continuing Professional Education (CPE)
• CPA Exam
  • Education
  • Application
  • Scheduling
  • Cost (including Guam Surcharge)
  • Extensions/Refunds
  • Scores
  • Miscellaneous (including Frequently Used Terms)
• Ethics
  • Compensation/Ethics
  • Solicitation
  • Successor in Interest
• Experience
• Firm Licensing
• Incidental Practice
• International Applicants
• License Requirements
  • Education
• Peer Review
• Practice of Public Accounting
• Reciprocity
• Renewal of CPA-Inactive Certificate/License
• Retirement
• Safe Harbor Report Language for Use by Non-CPAs
• Transfer of CPA Exam Grades
• Using the Title

General

What is the Board’s fax number?

(360) 664-9190

How do I verify if someone is a CPA or CPA-Inactive certificateholder?

See the Licensee Search function or call (360) 753-2585.

I’ve moved. How do I notify the Board?

Address changes must be submitted in writing within 30 days and include your signature. See:

• Change of Address Form
• WAC 4-25-550
• CPA Firm Change of Address Form

Does the Board accept credit cards for payment of fees?

No.  Fees must be paid with check or money order in US dollars drawn on a US bank.

How do I notify the Board that I changed my name?

Submit your written notification along with documentation (such as, a copy of the marriage certificate, divorce decree, or court order) to the Board.  Additionally, Board rule, WAC 4-25-661, requires that the name a CPA or a CPA-Inactive certificateholder uses with the CPA or CPA-Inactive title matches the name appearing on the CPA's license or CPA-Inactive certificateholder's certificate.  To change your name and obtain a new wall document or license, submit the Name Change Form with the required documentation and fee.

I hold a CPA license in Washington State and am applying for a CPA license in another state.  That state board requires that the Washington State Board completes an "Exchange of Information" form.  Does the Washington State Board charge a fee for this service?

No.  Please mail the form to:  PO Box 9131, Olympia, WA  98507-9131.  Board staff will complete and mail the form to the other state board within five working days.

May I obtain a listing of all CPAs licensed in Washington State?

The Board may not give, sell, or provide access to lists of individuals for commercial purposes.  However, Board rule (WAC 4-25-520) and the Public Records Act, RCW 42.56.070(9) provides that: " . . . lists of applicants for professional licenses and of professional licensees shall be made available to those professional associations or educational organizations recognized by their professional licensing or examination board."

Professional associations or educational organizations wishing to be recognized by the Washington State Board of Accountancy for purposes of obtaining a list of applicants and/or licensees/certificateholders may submit a request letter to:

Executive Director
Washington State Board of Accountancy
P O Box 9131
Olympia, WA  98507-9131.

The request letter should include:

• a description of your organization
• a statement as to why your organization is a professional association or educational organization as provided in RCW 42.56.070(9)
• a description of how your organization intends to use the list
• any other supporting documentation or information you believe to be relevant to the request

A sub-committee of the Board reviews requests for Board recognition.  Please allow the sub-committee approximately ten days to review a request.

Upon recognition as an educational organization or professional association, you may obtain a list of individual CPAs and CPA-Inactive certificateholders or CPA firms by submitting a List Request Form with the applicable fee.

Questions?  Please call (360) 664-9194 or e-mail webmaster@cpaboard.wa.gov

I represent a commercial organization, may I obtain a listing of CPA firms licensed in Washington State?

The Board may provide a list of CPA firms to organizations that are not recognized by the Board as a educational organization or professional association. However, these lists may not include individuals, that is, CPA firms that are sole proprietorships or partnerships composed of individuals. To obtain this list the organization must submit a written request in writing to:

Board of Accountancy
PO Box 43123
Olympia, WA 98504-3123

The request should include:

• A statement indicating an understanding that the list will not include sole proprietorships or partnerships composed of individuals
• The data requested such as firm name and address
• The format requested (ASCII, Word, or Excel)
• A $75 fee

May a non-licensee sign, on behalf of a firm, the firm’s name to an audit, review, or compilation report?

Yes, when directed to do so by the practitioner-in-charge (licensee) of the engagement.  You should review the AICPA’s Statement on Quality Control Standards #5 The Personnel Management Element of a Firm’s System of Quality Control - Competencies Required by a Practitioner-in-Charge of an Attest Engagement and AICPA U. S. Auditing Standards AU 508 Paragraph .08(i).

Can a non-licensee be the engagement or review partner on an audit, review or compilation engagement?

No.  The Board interprets WAC 4-25 and AICPA standards (referenced below) to mean an engagement partner or a review partner on an audit, review, or compilation engagement must be a CPA licensed to practice public accounting in one of the 54 US jurisdictions and possessing the necessary skills, knowledge and experience to meet the requirements of the specific engagement.  We recommend you review the following rules and standards:

• WAC 4-25-610 Which rules govern the conduct of CPAs? (See Due Care)
• WAC 4-25-630 What are the Requirements Concerning Competence
• WAC 4-25-631 With which rules, regulations and professional standards must a CPA comply? (This rule requires all CPAs, CPA firms and owners comply with the AICPA Statement on Quality Control Standards.)
• AICPA Professional Code of Conduct ET201 General Standards and ET201-1 Competence
• AICPA U.S. Auditing Standards AU 210 Training and Proficiency of the Independent Auditor
• AICPA U.S. Auditing Standards AU 311 Planning and Supervision including AU 9311
• AICPA Statement on Quality Control Standards #5 - The Personnel Management Element of a Firm’s System of Quality Control - Competencies Required by a Practitioner-in-Charge of an Attest Engagement. (This standard requires that the practitioner-in-charge have the competencies and skills to perform the services to be rendered.)

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CPA-Inactive Certificateholders - How to Apply for a License

As a CPA-Inactive certificateholder you must complete four CPE hours in ethics applicable to the practice of public accounting in Washington State prior to the end of your reporting period, December 31, 2006.

In order to apply for the license, you must also renew your CPA-Inactive certificate and pay the renewal fee.  To apply for a license, you may submit the Renewal Application and renewal fee along with one of the following applications:

• If you held a license in the past, you would submit the Application to Return To Previously Held Status As a Licensee.
• If you have not held a license in the past, you would submit the Certificateholder License Application. 

License Requirements - Education

I first took the CPA exam in May 1999 and wish to apply for a WA license.  I understand I must meet Washington's education requirements in force at that time.  What were the Board's education requirements then?

The education requirements (WAC 4-25-710) for applicants for a Washington state  CPA license who first took the CPA exam between May 1993 and May 2000, were a baccalaureate degree conferred by a college or university recognized by the board including at least:

1. Twenty-four semester hours or the equivalent, in accounting subjects including no more than ten semester hours of lower division elementary accounting courses; and
2. Twenty-four semester hours or the equivalent, in business administration subjects which shall include business law, finance, and economics.
3. A concentration in accounting for holders of graduate degrees for purposes of this rule shall consist of at least:
   1. Sixteen semester hours or the equivalent in graduate level accounting subjects. Undergraduate accounting courses may be substituted at two-thirds of the stated undergraduate credit; and
   2. Sixteen semester hours or the equivalent in graduate level business administration subjects which shall include business law, finance, and economics. Undergraduate business courses may be substituted at two-thirds of the stated undergraduate credit.

Note:  On January 25, 1996 and again on August 29, 1997, the Board ruled that a student who otherwise meets the accounting concentration requirements of WAC 4-25-710 (above) except for a course in business law, will have been exposed to sufficient business law subject matter to satisfy the business law requirement.

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Ethics

I am the successor CPA on an attest engagement and I have discovered evidence that the predecessor CPA violated one or more of the Board's rules as well as the AICPA Code of Conduct.  What is my obligation to this to the Board? (01/04)

There is no 'whistle blowing' requirement contained in the Public Accountancy Act or Board rules and you are therefore not required to report the violation to the Board.  However, the Public Company Accounting Oversight Board (PCAOB) and the Securities and Exchange Commission (SEC) have established new standards of conduct and obligations with respect to CPAs engaged in public audit and you are cautioned that, if your activities are regulated by the SEC or the PCAOB, that any violations of their rules regarding reporting obligations would be a basis for disciplinary conduct by the Board.  In addition, you should remain cognizant of the need of all CPAs to maintain and uphold the public's trust and the Board suggests you consider providing information regarding the potential violation to the Board.  It is important to note:

• The Board investigates anonymous complaints only when additional evidence of a violation of the Public Accountancy Act or Board rules has been submitted with the complaint
• Investigation files remained closed to public disclosure until the investigation has concluded
• Once the Board's investigation has concluded, the investigation files, including information provided by the complainant and the letter of complaint, are available for public disclosure
• Washington's public disclosure laws limit the Board's ability to redact the name of the complainant

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Incidental Practice

Our firm is licensed in several states, including Washington State. We have a CPA who is residing and licensed in Utah.  S/he will be performing attestation work for a client that is located in Washington State.  Do the rules and regulations require this CPA to be licensed in Washington State if the following situation applies?: 

• The CPA will be issuing a representation/engagement letter addressed to the client,
• All reports will be addressed and delivered to the client in Washington,
• The client does not have an office located in Utah,
• The CPA will not be physically entering the State of Washington to assist the client however the CPA will communicate with the client by way of e-mail, fax, and US mail,
• The attestation work that the CPA will be performing for the Washington client will be done in Utah and will be electronically sent or mailed to the client.

Since the Utah CPA works for your firm and your firm is licensed by the Washington State Board of Accountancy, the Utah CPA's practice in Washington may be considered "incidental."  If the Utah CPA's practice is "incidental" the Utah CPA may practice in Washington without either having to provide notification to the Washington Board or obtaining a Washington CPA license.  

The practice is deemed "incidental" if the Utah CPA: 

1. Spends 10% or less of his/her work hours (over a 12 month period) on activities conducted within the state of Washington, 
2. Does not maintain an office or workstation in the state of Washington, or
3. Does not advertise to provide his/her services within the state of Washington.

If the Utah CPA's practice meets the above test and is "incidental," the Utah CPA may practice in Washington without notifying the Washington Board or obtaining a Washington CPA license.

However, if the Utah CPA:

1. Spends more than 10% percent of his/her work hours (over a 12 month period) on activities conducted within the state of Washington,
2. Maintains an office or workstation in the state of Washington, or 
3. Advertises to provide his/her services within the state of Washington

Then the Utah CPA must either: 

1. Obtain a Washington state CPA license (which requires compliance with Washington's rules including the CPE requirements) or 
2. Notify the Washington Board of her/his intent to enter the state and receive confirmation from the Board (which requires compliance with Washington's rules but does give the CPA an exception to Washington's CPE requirements provided the CPA meets Utah's CPE requirements).

Finally, should the Utah CPA decide to move to Washington State, s/he will be required to obtain a Washington State CPA license in order to use the title CPA in Washington State.

See Board rule WAC 4-25-756 I am licensed in another state--How do I notify the board of my intent to enter the state in order to obtain practice privileges in the state of Washington? and WAC 4-25-410 Definitions - (14) Entering the State.

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License Requirements

What are the requirements for applying for a license?

Briefly, you must meet the following requirements:

• Education: A degree, 150 semester hours, and a concentration in accounting; 
• Examination: Pass all parts of the CPA exam;
• Experience: One year of qualifying experience;
• Ethics Exam: A score of 90% or better on the "Professional Ethics for CPAs" exam;
• Good character: Lack of a history of dishonest or felonious acts; and
• Submission of a complete form including payment of the fee.

Applications for licensure may be audited by the Board's Qualifications Committee and, as a result, these applications may take up to six weeks to process. 

When your fully completed application is approved, Board staff will mail an approval letter and a wall license to you and post your name and license number on the Licensee Search of the Board's web site. 

We suggest you monitor the Licensee Search section of the Board's website to obtain immediate notice of the approval of you license.

Is residency required to become licensed in Washington State?

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International Applicants

Will the Board accept my education from a school(s) which is outside the United States?

Education which was obtained from a school outside the United States must be submitted to an approved Foreign Degree Evaluation service for evaluation. (see International Education—Evaluation of Credentials.)

What can I do if I disagree with the evaluation from a Board approved evaluator?

The Board relies on the expertise of the approved evaluation services for all evaluations of foreign education. If you disagree with the results of an evaluation, you will need to contact the evaluation service directly to consider your complaint. The Board will not intervene in any disagreements and if a disagreement exists, will rely on the final evaluation from the approved evaluation service.

How can I become a member of the AICPA?

To apply for membership with the American Institute of CPAs (AICPA), contact the AICPA at:

AICPA
AICPA Member Service Center
220 Leigh Farm Road
Durham, NC 27707
1-888-777-7077
www.aicpa.org

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Transfer of CPA Exam Grades

I took and passed the CPA exam in another state under the paper and pencil version of the exam.  May I transfer my exam grades to Washington if I originally sat for the CPA exam for only two sections at a time rather than sitting for all unpassed parts? 

Yes.  Your exam grades may be transferred to Washington State as long as the grades are valid in the state where you took the exam.  

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Reciprocity

I am applying for a Washington State CPA license under the interstate reciprocity provisions of WAC 4-25-746.  Under this method, I can meet the experience requirement if I had five years of experience in the practice of public accountancy within the last ten years (or three years of experience in the practice of public accountancy within the last five years).  May I use the experience I obtained at a CPA firm in another state prior to becoming a licensed CPA?  (02/05)

No.  You may only use experience obtained as a licensed CPA in public practice to qualify under the 5-in-10 or 3-in-5 provision.

I have moved to Washington and hold a CPA license from another state.  I am currently working at a Washington CPA firm.  However, because I do not have a Washington state CPA license, I have not used the title "CPA."  I plan to apply for a Washington State CPA license under the reciprocity provisions of WAC 4-25-746.  May I use the title "CPA" in Washington before my Washington CPA license is issued?  (02/05)

Provided no sanctions or investigation by other jurisdictions are in process, and you have met the requirements for applying for licensure through interstate reciprocity, upon filing a complete application with the Board, you may use the CPA title in Washington State.  A complete application means you have completed and submitted the form titled "License Application Interstate Reciprocity", paid the application fee, and submitted all other required documentation with your application.

I moved to Washington and hold a CPA license from another state. I am currently working at a Washington CPA firm.  However, because I do not have a Washington state CPA license, I have not used the title "CPA."  I plan to apply for a Washington State CPA license under the reciprocity provisions of WAC 4-25-746.  May I use the experience I obtain at the Washington CPA firm to meet the requirements of interstate reciprocity? (02/05)

Under the interstate reciprocity provisions, an individual may either meet the Board's current experience requirements or demonstrate s/he had:

• Five years of experience in the practice of public accountancy out of the ten years immediately preceding the date of the license application (called the 5-in-10 provision) or 
• Three years of experience in the practice of public accountancy out of the five years immediately preceding the date of the license application (called the 3-in-5 provision).

You may use your experience at the Washington CPA firm to meet the Board's current experience requirements. This requirement is based on the applicant obtaining experience supporting the attainment of seven core competencies. See Board Policy #2001-2 for more information.

You may not use the experience at the Washington CPA firm to qualify under the 5-in-10 or the 3-in-5 provisions.  These provisions may only be used for those years in which you were in public practice. Washington State defines public practice as using the title "CPA" and providing, or offering to provide, accounting, attest, tax, or consulting services to the public.  Since you were not using the "CPA" title while you worked at the Washington CPA firm, your experience does not meet the definition of public practice and, therefore, your experience at the Washington CPA firm cannot be used to qualify under the 5-in-10 or the 3-in-5 provisions.

Can my experience in private industry (or government) which qualified me for a license in my original state of licensure be accepted in Washington?

Yes.  See the Board's Policy 2001-2 for complete information on how to obtain your experience in private industry, academia, or government.  Also see RCW 18.04.180.

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Renewal

I  hold a Washington State CPA-Inactive certificate.  How do I renew my CPA-Inactive certificate and what are the requirements to convert my CPA-Inactive certificate to a license?

In January of the year that your CPA-Inactive certificate expires, a Certificate Renewal Application form will be mailed to your address of record. (Note: please ensure you notify the Board of any changes in your address.)  If you do not receive a Certificate Renewal Application form in January of the year that your CPA-Inactive certificate expires, please contact the Board to confirm your official address of record is your current address and to request another form.  By inserting your name or CPA-Inactive certificate number on the Licensee Search on this web site, you may determine the year that your CPA-Inactive certificate expires.

To renew your CPA-Inactive certificate, you must:

• Certify on the Certificate Renewal Application form that you completed 4 CPE hours in ethics applicable to the practice of public accounting in Washington State within the three calendar year period preceding renewal,
• Submit a complete Certificate Renewal Application to the Board by the due date, and
• Include the appropriate fee ($230 renewal fee and, if applicable, $100 late fee.)

As a CPA-Inactive certificateholder, the 2001 changes in the Public Accountancy Act require you to use the title "CPA-Inactive."

If you did not complete the required 4 CPE hours in ethics applicable to the practice of public accounting in Washington State by December 31st of the preceding year, you may request a CPE waiver from the Board providing you with additional time to complete the CPE. However, the Board has very limited authority to grant CPE waiver requests.  If the Board approves your request for a CPE waiver, you will be allowed to renew your CPA-Inactive certificate based upon your attestation that you will complete the 4 CPE hours in ethics applicable to the practice of public accounting in Washington state by a specified date. If the Board denies your CPE waiver request, you may either retire your CPA-Inactive certificate or allow it to lapse.

You may elect to retire your CPA-Inactive certificate by signing the appropriate section of the Certificate Renewal Application form and returning the form to the Board.  There is no fee to retire your CPA-Inactive certificate and you may renew your CPA-Inactive certificate at a later date by meeting the then current requirements for renewal of a retired CPA-Inactive certificate. (See WAC 4-25- 793)

If you do not return the form to the Board's office postmarked by June 30th, your CPA-Inactive certificate will lapse.  If you allow your CPA-Inactive certificate to lapse, you may at a later date apply for reinstatement based on the then current requirements for reinstatement of a CPA-Inactive certificate. (See WAC 4-25-792)

You may seek to convert your CPA-Inactive certificate to a license at any time. (Note: If you convert your CPA-Inactive certificate to a license, you do not have the option to convert your license back to a CPA-Inactive certificate.)

There is no fee to convert your CPA-Inactive certificate to a license; however there are other requirements.  If you previously held a Washington State CPA license, to convert your CPA-Inactive certificate to a license you need to:

• Obtain the required CPE, and
• Submit a complete Application to Return to Previously Held Status as a Licensee

If you have not previously held a Washington State CPA license, you will need to:

• Meet the experience requirements for licensure,
• Obtain the required CPE, and
• Submit a complete Certificateholder License Application

Note, if you want to convert your CPA-Inactive certificate to a license during the renewal period (i.e., the Board has mailed you a Certificate Renewal Application form), you need to submit a completed Certificate Renewal Application and renewal fee to the Board before your application to convert to a license can be processed.

Please be aware: if you convert your CPA-Inactive certificate to a license, you may not convert back to a CPA-Inactive certificateholder status.

I currently hold a Washington State CPA license. What are my renewal options?

In January of the year that your license expires, a License Renewal Application form will be mailed to your address of record. (Note:  WAC 4-25-550 requires you to notify the Board of any changes in your address.)  If you do not receive a License Renewal Application form in January of the year that your license expires, please contact the Board to confirm your official address of record is your current address and to request another form.  By inserting your name or license number on the Licensee Search on this web site, you may determine the year that your license expires.

To renew your license, you must:

• Verify on the License Renewal Application that you completed the required CPE within the 3 calendar year period preceding the year of renewal (120 CPE hours, limited to 24 CPE hours of non-technical subjects and including 4 CPE hours in ethics applicable to the practice of public accounting in Washington State),
• Submit a completed License Renewal Application to the Board by the due date, and
• Submit the appropriate fee ($230 renewal fee and $100 late fee if appropriate).

If you did not meet the CPE requirements for renewal, you may request a CPE waiver from the Board providing you with additional time to complete the required CPE.  However, the Board has very limited authority to grant CPE waiver requests. If the Board approves your request for a CPE waiver, you will be allowed to renew your license based upon your attestation that you will complete the required CPE hours by a specified date.  If the Board denies your CPE waiver request, you may either retire your license or allow it to lapse.

You may elect to retire your license by signing the appropriate section of the License Renewal Application form and returning the form to the Board.  There is no fee to retire your license and you may renew your license at a later date by meeting the then current requirements for renewal of a retired license. (See WAC 4-25-793.)

If you do not return the form to the Board's office postmarked by June 30th, your license will lapse.  If you allow your license to lapse, you must immediately discontinue using the title "CPA" on July 1 of the year of renewal.  You may at a later date apply for reinstatement based on the then current requirements for reinstatement of a license. (See WAC 4-25-792.)

I hold a Washington State CPA license.  Can I convert my license to a CPA-Inactive certificate?

No.  Licensees do not have the option to convert to the CPA-Inactive certificateholder status.

If I let my license lapse, do I have to retake the CPA Exam?

No. However, if you apply for reinstatement you must meet the then current requirements for reinstatement.  See How To Apply for Reinstatement of a License and Reinstatement Form.

How do I determine when I need to renew my license and CPA-Inactive certificate?

If you are a CPA-Inactive certificateholder, check the notification card you received from the Board at your last renewal.  This card states the date your CPA-Inactive certificate expires.  You may also check your status using the Board's "Licensee Search."  If your CPA-Inactive certificate expires this year, you need to submit a renewal form prior to June 30 to avoid your CPA-Inactive certificate from becoming void through lapse.

If you are a licensee, check your license.  The license states the expiration date.  You may also check your status using the Board's "Licensee Search." If your license expires this year, you need to submit a renewal form prior to June 30 to avoid your license from becoming void through lapse.

If you cannot locate the above information, contact the Board office at (360) 753-2586.

Please Note:  Because renewals, complete with certification of compliance with the CPE requirements, and fees are due April 30, renewal applications received after April 30 will be assessed a late filing fee of $100.  Incomplete CPA-Inactive certificate/license renewals will be assessed a late filing fee of $100.

I am a licensed CPA and I am changing my employment from public accounting to private industry.  If I drop my CPA license, how can I get it back? (04/2004)

Provided you discontinue the use of the CPA title, you may submit notification to the Board that you wish to retire your license.  If at a later date you wish to return to your previous status as a licensee, you must meet the then current requirements to renew a retired license.  If you elect to allow your license to lapse (rather than notify the Board that you wish to retire your license), then to return to your previous status as a licensee you must meet the then current license reinstatement requirements.

What do I do if I don’t have enough CPE for renewal?

The Board may in limited cases provide an extension to complete the CPE requirements.  Extensions may be granted for reasons of individual hardship including health, military service, or other reasonable cause. You must complete the Waiver Request Form to make your request.

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Practice of Public Accounting

We are a management consulting firm and there are no CPAs working for our organization.  Can we offer services to the public and issue reports using the terms audit, review and compilation in the report titles without violating the provisions of RCW 18.04.345(6) and (7)?

Yes, provided you do not advertise to provide such services as a CPA firm or by a CPA and you are not issuing a report on financial information.

The Board interprets the provisions of RCW 18.04.345(6) and (7) to prohibit a non-CPA individual or firm from using the terms "audit," "review," or "compilation" when designating a report customarily prepared by someone knowledgeable in accounting or in relationship to services (and reports on services) defined in:

• Statement on Auditing Standards issued by the AICPA,
• Statements on Standards for Accounting and Review Services issued by the AICPA,
• Statement on Standards for Attestation Engagements issued by the AICPA, and
• Governmental Auditing Standards issued by the U.S. General Accounting Office unless the individual and firm are licensed by the Washington Board of Accountancy.

The Board does not interpret the provisions of RCW 18.04.345(6) and (7) as prohibiting the use of the terms "audit," "review," and "compilation" for reports on activities clearly outside of the scope of these specific provisions such as reports on performance, project(s), and/or program(s).  However, only a licensed CPA in a licensed CPA firm may issue audit, review, or compilation reports on financial statements.  Non-CPAs may utilize the safe harbor language as provided for in the Board's Policy 2003-1.

We are a management consulting firm. We are not a licensed CPA firm; however, we have several CPAs working for our organization.  Can we offer the services to the public and issue reports using the terms audit, review and compilation in the report titles without violating the provisions of RCW 18.04.345(6) and (7)?

Yes, provided you do not advertise to provide such services as a CPA firm and a CPA* does not sign the report and you are not issuing a report on financial information.  

The Board interprets the provisions of RCW 18.04.345(6) and (7) to prohibit a non-CPA individual or firm from using the terms "audit," "review," or "compilation" when designating a report customarily prepared by someone knowledgeable in accounting or in relationship to services (and reports on services) defined in:

• Statement on Auditing Standards issued by the AICPA,
• Statements on Standards for Accounting and Review Services issued by the AICPA,
• Statement on Standards for Attestation Engagements issued by the AICPA, and 
• Governmental Auditing Standards issued by the U.S. General Accounting Office unless the individual and firm are licensed by the Washington Board of Accountancy.

The Board does not interpret the provisions of RCW 18.04.345(6) and (7) as prohibiting the use of these terms for reports on activities clearly outside of the scope of these specific services such as: reports on performance, project(s), and/or program(s).  However, only a licensed CPA in a licensed CPA firm may issue audit, review, or compilation reports on financial statements.  Non-CPAs may utilize the safe harbor language as provided for in the Board's Policy 2003-1.

*CPAs offering or performing "audit," "review," and "compilation" services are required to (a) offer or perform such services in a CPA firm licensed by the Board of Accountancy, (b) meet the individual licensing requirements of the Washington State Board of Accountancy, and (b) comply with professional standards.

I am a licensee and want to use the CPA title. I offer human resource services to the general public. I specialize in locating, interviewing and recommending accounting and financial staff.  I do not perform any attest, accounting, or tax work. Does the Board consider this activity to be included in "the practice of public accounting?"

Yes. In order to use the CPA title when offering those services, you must hold a valid individual CPA license.

I am a licensee and want to use the CPA title. I provide training and seminars to CPAs and CPA firms both directly and through professional associations.  I offer training in tax, auditing, accounting and other related fields.  I do not perform any attest, accounting, or tax work.  Does the Board consider this activity to be included in the "practice of public accounting?"

Yes. In order to use the CPA title when offering those services, you must hold a valid individual CPA license.

I am a licensee and want to use the CPA title.  I provide open-enrollment and in-house seminars and training programs for banks and credit unions.  My seminars focus on cash flow and financial statement analysis.  I do not perform any attest, accounting, or tax work. Does the Board consider this activity to be included in the "practice of public accounting?"

Yes. In order to use the CPA title when offering those services, you must hold a valid individual CPA license.

I am a licensee and want to use the CPA title.  I provide merger and acquisition consultation to the general public.  Does the Board consider this activity to be included in the "practice of public accounting?"

Yes. In order to use the CPA title when offering those services, you must hold a valid individual CPA license.

I am a licensee and I work in a law firm, not a CPA firm.  May I prepare a tax return and sign the return with the CPA title?

Yes provided you hold a valid individual Washington state CPA license to practice public accounting.

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Using the Title

I currently hold a Washington State license to practice public accounting in Washington State through June 30, 2003. I am also licensed in Montana and I am moving to Montana to practice public accounting. I am not interested in maintaining my license in the state of Washington. I was planning to submit an application for retired status. However, WAC 4-25-793 states that while retired: "you may not use the title CPA or CPA-Inactive or exercise the privileges related to those titles until you return to your previous status." Can I use the title CPA in Montana while I am in retired status in Washington state?

You are not required to obtain a license in Washington State in order to use the title CPA in another state provided you do not represent that you hold a Washington State CPA license, or use the CPA title in any manner that would be deceptive or misleading (i.e., indicate that you hold a CPA license in Washington State).

Situation for Questions (A) thru (D):  In 1986 I became a Washington Certificateholder. (My renewal cycle ends on June 30, 2003.) Since that date I have maintained my Washington State certificate. In 1986 I was licensed in Hawaii. And, since 1986 I have been employed by an international firm and I have been stationed in Hong Kong. I anticipate returning to the U.S. in November 2004.

(A)   If I move to Washington State and practice public accounting, do I need to obtain a Washington license to use the title CPA?

Yes, you must hold a CPA license in order to practice public accounting as a resident of Washington state.  Also, as a Washington State CPA-Inactive certificateholder you must use the title CPA-Inactive if you have not completed the process to convert your CPA-Inactive certificate to a license.

(B) If I move to Hawaii, do I need to obtain a Washington license to use the title CPA in the state of Hawaii (rather than the title CPA-Inactive)?

No, as long as you do not represent that you hold a license to practice as a CPA in Washington State, or use the CPA title in any manner that would be deceptive or misleading (i.e., indicate that you hold a CPA license in Washington state).

(C) May I use the title CPA and give my Hawaii licensee number in job applications to Washington employers?

No.  As a Washington CPA-Inactive certificateholder you may only use the title CPA-Inactive provided you maintain your CPA-Inactive certificate.  To use the title CPA you must first obtain a Washington State CPA license.  However, you may place a statement of fact within the body of your resume that you hold a Hawaii CPA license, however you must not place the information on the resume in any manner that would be deceptive or misleading (i.e., indicate that you hold a CPA license in Washington state).

(D) When interviewing for jobs in Washington State may I use a business card that states US CPA (based on my Hawaii license)?

No.  As a Washington CPA-Inactive certificateholder you may only use the title CPA-Inactive provided you maintain your CPA-Inactive certificate.  To use the title CPA you must first obtain a Washington State CPA license.  As a Washington CPA-Inactive certificateholder you may use the title CPA-Inactive provided you maintain your Washington CPA-Inactive certificate.  However, you may not use the title CPA-Inactive when offering or providing accounting, tax, management consulting, or similar services to the public.

I am a licensed CPA in the State of Washington. I also am a Chartered Accountant, issued by the Institute of Chartered Accountants of British Columbia. May I use the title "CA" on my business cards along with the CPA title?

No.  RCW 18.04.345(4) states that no person may hold himself/herself out to the public, or assume or use along, or in connection with his/her name, or any other name, the title or designation "chartered accountant" or the abbreviation "CA" because of the likelihood that the designation may be confused with CPA.

My CPA CPA-Inactive certificate (or license) lapsed. Can I put “retired CPA” or "retired CPA-Inactive" on my resume?  (04/2004)

No.  If you allowed your CPA-Inactive certificate or license to lapse, you have no legal usage of the title.  You may not put “retired CPA” or "retired CPA-Inactive" on your resume.  However, if you submitted appropriate notification to the Board and have retired your CPA license or CPA-Inactive certificate, you may note that as a statement of fact on your resume.

I am a CPA-Inactive certificateholder (or licensee). I notified the Board that I am retired. Can I put “retired CPA” on my resume?  (04/2004)

You may include the words “retired CPA” on your resume provided the information is not provided in a misleading manner.  For example, you may not put the words “CPA-Retired” or "Retired-CPA"  by your name in the manner of a title.  Also, you may not use the words “CPA-Retired” or "Retired-CPA" on your business card.  However, you may place the information within your resume as a statement of a fact.

I’m a CPA-Inactive certificateholder who sells insurance.  Can I use the "CPA-Inactive" title?

Yes, provided you maintain your CPA-Inactive certificate in a status that allows for title use.  However, if you provide retirement, estate, and/or financial planning concurrent with the selling of insurance, you need a valid CPA license to use the CPA title.

I passed the CPA exam. Can I call myself a CPA or CPA-Inactive?

No.  See Legally Using the CPA Title.

I allowed my CPA-Inactive certificate (or license) to lapse. Can I put "Member, Washington Society of CPAs" on my resume?

You may put the words "Member, Washington Society of CPAs" on your resume provided the information is factual and is not provided in a misleading manner.  For example, you may not put the words "Member, Washington Society of CPAs" by your name in the manner of a title.  Also, you may not use the words "Member, Washington Society of CPAs" on your business card.  However, you may place the information within the resume as a statement of a fact.

I have passed two parts of the CPA exam and I have 2,000 hours of experience. Can I put "passed two parts of the CPA exam and completed 2,000 hours of experience for a CPA license" on my resume and in my cover letter?

Yes.

I am a Washington State CPA-Inactive certificateholder.  I do not hold a CPA license.  May I prepare and/or sign a tax return using the CPA title?

No.  Only licensed CPAs or CPAs practicing in Washington under a valid grant of practice privileges may use the title CPA when offering to perform, or performing, public accounting services.  The practice of public accounting includes: tax, tax consulting, management consulting, accounting, auditing and other attest services.  The Board has provided guidance on what other services are included in the practice of public accounting.  See Practice of Public Accounting.

I am a Washington State CPA-Inactive certificateholder.  I do not hold a CPA license. May I prepare and/or sign a tax return using the CPA-Inactive title?

No. See response above.

I am a Washington State CPA-Inactive certificateholder. I do not hold a CPA license. May I prepare and/or sign a tax return without using the CPA or CPA-Inactive title?

Yes.  CPA-Inactive certificateholders not using the title CPA or CPA-Inactive may perform tax, tax consulting, management consulting, and accounting services; however, they may not use the title CPA or CPA-Inactive in any manner.

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Safe Harbor Report Language for Use by Non-CPAs

Yes.  See Board Policy 2003-1 Safe Harbor Report Language for Use by Non-CPAs.

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Solicitation

WAC 4-25-660(2) states: "If you are a licensee using the CPA title to perform or solicit services via a website, you must either include a statement on the website that you hold a current Washington state license or provide a name and contact information for an individual in your organization who will respond to inquiries regarding individual license information within seven business days.  The required information must be clearly visible and prominently displayed."  What triggers the requirement to post the statement?

If you use the CPA title in connection with offering or providing services you must post the required statement on your website.  You are not required to make disclosure on all email correspondence.

I am a CPA-Inactive certificateholder and want to advertise via a website and use the title.  Are there any restrictions in doing this?

Yes.  WAC 4-25-660(3) states: 

If you are a CPA-Inactive certificateholder using the CPA-Inactive title to perform or solicit services via a website you must clearly, visibly, and prominently display the following on the website:

1. That you hold a current Washington state CPA-Inactive certificate;
2. That you do not hold a license to practice public accounting; and that
3. That Washington state law does not allow a CPA-Inactive certificateholder to offer or provide accounting, auditing, attest, reports on financial statements, tax preparation or advisory, management advisory, consulting or similar services to the public in association with the use of the title "CPA," "Certified Public Accountant," "CPA-Inactive," or "Certified Public Accountant-Inactive." 

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Complaints

I have a complaint against a Washington CPA, who should I contact?

Contact the Board at (360) 664-9194 or complaints@cpaboard.wa.gov. See Complaint Process and Consumer Information.

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Compensation/Ethics

A licensee has an attest client. One of the owners of the attest client has asked the licensee to provide him with personal investment advisor services on a commission fee basis. Would the provision of commission fee services to the owner of an attest client impact the licensee independence? (10/04)

In response the Board considered and referenced the following Board rules:

WAC 4-25-410 defines independence as:

"Independence" means an absence of relationships that impair a licensee's impartiality and objectivity in rendering attest services.

WAC 4-25-622 requires licensees to maintain independence so that attest services will be impartial and viewed as impartial by parties expected to rely on the attest report:

"When performing attest services, CPAs and CPA firms are responsible for maintaining independence so that attest opinions, reports, conclusions, and judgments will be impartial and viewed as impartial by parties expected to rely on the attest report."

WAC 4-25-610 requires licensee to be independent in fact and appearance when providing attest services:  

"Objectivity - Objectivity is to be maintained by a person representing oneself as a CPA, CPA-Inactive certificateholder, or using the CPA or CPA-Inactive title, CPA firms, and firm owners.  Specifically, a person representing oneself as a CPA, CPA-Inactive, or using the CPA or CPA-Inactive title, CPA firms, and firm owners must:  
(1) Avoid rendering professional services where actual or perceived conflicts of interest exist; 
(2) Be independent in fact and appearance when providing attestation services."

And, WAC 4-25-620 requires a licensee remain free of conflicts of interest: 

"When offering or performing services, CPAs, CPA-Inactive  certificateholders, CPA firms, and firm owners must:

• Remain honest and objective;
• Not misrepresent facts;
• Not subordinate their judgment to others; and
• Remain free of conflicts of interest unless such conflicts are specifically permitted by board rule or professional standards listed in WAC 4-25-631."

The Board believes that the provision of commission-based services to the owner(s) could:

• Impair a licensee's impartiality and objectivity
• Create an impermissible conflict of interest
• Result in a relationship that would preclude the licensee from being impartial
• Result in parties not viewing the licensee as impartial 
• Create a lack of independence in fact or appearance

Because of this, the Board is concerned that the provision of commission-based services could lead to a violation of WAC 4-25-622, 610, and 620.

If I sell a commission product to a company for whom I perform compilation services, is it acceptable as long as it is disclosed in the accountant's report that I am not independent to the company? (10/03)

Yes.

I am a licensed CPA and I provide professional services to the public, including attest services, while working at a licensed CPA firm.  I have passed the NASD Licensing exams and I am now an Investment Advisor Representative.  Can I provide investment advisory services as an employee of a licensed CPA firm?

Neither the Public Accountancy Act or the Board's rules prohibit such investment advisory services provided the licensed CPA meets the requirements of WAC 4-25-626 which prohibits the provision of services for commission or contingent fees to attest clients.  This prohibitions applies during the period in which the CPA, the CPA's firm, the owner's firm, or the firm is engaged to perform the attest services and the period covered by any historical financial statements involved in the attest services.  However, the Board makes no representations regarding other federal or state licensing requirements and recommends you seek legal council to ensure you have met all legal requirements.

I am a licensed CPA and also an Investment Advisory Representative. I want to offer public accountancy services to the public, including attest services, as a licensed CPA (in a licensed CPA firm) during the business hours of 8:00 a.m. to noon.  And then, from noon to 5:00 p.m. I want to offer services as an Investment Advisory Representative from a separate Investment Advisory firm (which is not a CPA firm). I will have separate offices, separate business cards, and separate letterhead for each business. However, I imagine I will have clients that will utilize my services from both firms and the Investment Advisory including potentially attest clients. Is this allowable?

As a CPA you are bound by the Public Accountancy Act and the Board's rules.  Whether you are practicing in a CPA firm or providing services in a separate non-CPA firm, it is a conflict of interest and a violation of WAC 4-25-626 to perform attest services for a client and gain a commission or contingent fee from that client.  Regardless of whether the clients is an attest client, the Board's rules regarding objectivity, integrity, conflict of interest, and public trust apply. Services that a CPA is prohibited from offering or providing due to a conflict of interest cannot be offered or provided to the client through a non-CPA firm.  For example, should the CPA provide commission/contingent based services for a client from either the CPA firm or a non-CPA firm, the CPA is prohibited from providing attest services (which include compilation services) in the future should the financial statement period to which the CPA would be attesting including the time period in which the CPA obtained the commission/contingent fee.  However, provided the CPA complies with Washington state law, a CPA may have a separate non-CPA business.

I am licensed to practice public accounting. May I accept a commission on the sale of securities?

See WAC 4-25-626 and Board Policy--Compensation Arrangements.

Can I receive stock or other non-cash compensation or services provided to non-attest clients?

Yes.

Many firms indemnify clients against the adverse impact of the CPA's work.  For example, a CPA firm might say that they will complete your tax return for a fee, and if there is a problem with the tax return, they will pay any interest or penalty.  Is this a contingent fee?

No, because the fee is not dependent upon the finding or result of such service.  Additionally, WAC 4-25-626 states a fee is not regarded as contingent:  "if determined based on the results of judicial proceedings or the findings of governmental agencies."

If a CPA prepares a tax return for a client (the CPA's work) and will not release the tax return to the client until a past due bill is paid, is this in violation of Board rules?

No, the tax return is the CPA's work product and therefore it is not a violation of WAC 4-25-640 or RCW 18.04.390.  However, upon the client's request, the CPA must return any client records.

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