CBA Proposes Rulemaking to Remove the Second Signature Requirement for Licensure


By Dimitri Davis

On October 21, 2022, the California Board of Accountancy (CBA) published notice of its intent to amend sections 12 and 12.5 of title 16 of the California Code of Regulations (CCR) relating to experience requirements for Certified Public Accountant (CPA) Licensure. According to the initial statement of reasons, these proposed changes are to relieve an unnecessary burden on licensure candidates, allowing for more efficient and accurate information being gathered for the purpose of licensure.

Currently, as codified in the Business and Professions Code, applicants for CPA licensure must complete a minimum of 12 months of general accounting experience, and those seeking the authority to sign reports on attest engagements must complete a minimum of 500 hours of attest experience. All applicants must have their experience documented on a Certificate of General Experience and, if seeking attest authority, a Certificate of Attest Experience. Currently, there are four forms, two Certificate of General Experience forms and two Certificate of Attest Experience forms, that differ based on where the applicant completes their experience. Two forms are designated for applicants completing general accounting or attest experience in a public accounting firm, and the other two forms are designated for applicants completing general accounting or attest experience in private industry or government. Experience completed in a public accounting firm requires the second person signing the form to be a licensed CPA. Experience completed in a private industry company or a government agency does not require the second person signing the form to be a licensed CPA and instead requires this individual to have more authority than the supervisor.

The proposed changes seek to eliminate the second signature requirement from Title 16, Division 1, CCR sections 12 and 12.5; update the Certificate of General Experience and Certificate of Attest Experience to reflect this elimination; and repeal two of the required four forms, resulting in only one for general accounting experience and one for attest experience. CBA believes that the second signature no longer reflects industry standards because the second signer, from another accounting firm, or a higher authority, may not have worked with or supervised the candidate, yet may be asked to verify if the information is true. CBA also believes this will reduce the possibility of delay caused by incorrect forms being submitted and that this requirement is an unnecessary burden for the candidate.

CBA anticipates that these proposed changes would not have a fiscal impact on federal or state funds.

The public comment period will end on December 5, 2022. CBA has not scheduled a public hearing on this proposed action. CBA will hold a hearing if it receives a written request for a public hearing from any interested person no later than 15 days before the close of the written comment period.


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